Privacy Notice

Apli Inc., a company based in Delaware, United States of America; and/or Apli México S. de R.L. de C.V. and/or Apli Servicios México S. de R.L. de C.V., companies based in Mexico City, Mexico; and/or Apli Colombia S.A.S., a company based in Bogotá, D.C., Colombia; and/or Apli Tecnologia em Recrutamento LTDA, a company based in Sao Paulo, Brazil, collectively referred to as "APLI" or "we", are responsible for processing your personal data, its use and protection.

Name and Address of the Data Controller

For United States of America: Apli Inc., located at 2035 Sunset Lake Road Suite B-2 Newark, Delaware, 19702, United States of America.
For Mexico: Apli México S. de R.L. de C.V. and/or Apli Servicios México S. de R.L. de C.V., located at Lago Alberto 320 T7 D606 Anáhuac, Miguel Hidalgo, CDMX, 11320.
For Colombia: Apli Colombia S.A.S., located at Calle 94 No. 21 – 76, Bogotá, D.C., Colombia, 110221.
For Brazil: Apli Tecnologia em Recrutamento LTDA, located at Alameda Santos 1165, Room 11, Bela Vista, São Paulo, São Paulo CEP: 01419002.

Our Commitment to Your Personal Data Protection Rights

APLI is a provider of online software as a service (SaaS) to corporate users, primarily as an automated tool for candidate sourcing, screening, onboarding, and training of staff and optimizing talent management (referred to as the "Service").APLI recognizes the importance of protecting the personal data of individuals it interacts with and whose data is processed by APLI, including candidate and corporate users using the websites, among others, in the United States, Mexico, Colombia, and Brazil.APLI acknowledges that all individuals with whom APLI interacts have a constitutional and legal right to the protection of their personal data and commits to protect such data as per laws, regulations, decrees, agreements, circulars, proclamations, guidelines, general provisions on personal data protection currently in force in the country where users' personal data is processed, any applicable legal norms, and any modifications, additions, or replacements in the future (the "Data Protection Regulations").

Definitions

To clarify this document, we will use defined terms. For the purposes of this privacy notice, the capitalized terms not differently defined elsewhere in this document, will have the following meaning:"Notice": Refers to this comprehensive privacy notice, issued in any format by the controller and made available to the data subject before processing their personal data.
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"Notice": Refers to this comprehensive privacy notice, issued in any format by the controller and made available to the data subject before processing their personal data.
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"Database": Organized collection of personal data referring to an identified or identifiable person.
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"Personal Data": Any information relating to an identified or identifiable natural person.
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"Sensitive Personal Data": Personal data that affects the most intimate sphere of the data subject, or whose misuse can lead to discrimination or pose a serious risk to the person.
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"Processor": The natural or legal person who processes personal data on behalf of the controller.
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"Digital Platforms": The website located at the URL https://www.apli.jobs/ and its subdomains (the "Website") and any portals, conversational interfaces, additional or auxiliary developments or programs that APLI uses directly or indirectly to provide its services.
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"Data Protection Regulations": The data protection laws applicable in the United States, Mexico, Colombia, and Brazil, as well as any other jurisdiction where APLI provides its services.
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"Controller": The private natural or legal person who carries out the processing of personal data, which, for the purposes of this notice, will be APLI."Processing": The collection, use, disclosure, or storage of personal data by any means. The use covers any action of access, handling, use, transfer, or disposal of personal data.
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"Transfer": Any communication of personal data made to a person other than the controller or processor.
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"Service or SaaS Service" refers to the online software solution for use and access through a network connection (commonly referred to as "software as a service" or by the acronym "SaaS"), which APLI provides directly to Corporate Users, the main purpose of which is to be an automated software tool that allows, among other functionalities, candidate sourcing, applicant screening, onboarding and training of staff and the optimization of talent management.
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"Users" refers, jointly and indistinct and interchangeably, to Candidate Users and Corporate Users. 
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"Candidate Users" refers to individuals who respond to any Job Postings from Corporate Users.
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"Corporate Users" refers to individuals and legal entities that enter into a Commercial Agreement with APLI for the purpose of the latter providing the SaaS Service, in order for Candidate Users to apply to Job Postings from the Corporate Users..
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1. Who is this Notice for?

This Notice explains how APLI uses your personal data and your associated rights. This Privacy Notice applies to our website located at www.apli.jobs and any other platform, application, or website where this Notice is published (e.g., our Facebook page), indicating that such application, platform, or site is operated or controlled by APLI (each, one of our "Websites"). The Notice is relevant for both Corporate Users and Candidate Users. Unless otherwise indicated, the term "you" includes both Corporate Users and Candidate Users.

This Privacy Notice does not constitute a job offer, a solicitation for service provision, an employment contract, or a service contract.

2. When is APLI the Data Controller?

Depending on the specific circumstances when Users' Personal Data is collected, APLI may be considered the Data Controller or Processor.

If APLI directly collects Personal Data from Users, APLI will be considered the Data Controller and will provide this comprehensive Privacy Notice to Users through Digital Media and before obtaining the respective data. APLI may use remote or local electronic or digital communication mechanisms to automatically collect Users' Personal Data when the User contacts Digital Media.

However, if Corporate Users directly collect Personal Data from Candidate Users, APLI will be considered the Processor of such information. In that case, the Corporate User's privacy notice will govern the provision of the Service, the way Personal Data is collected from Users, the processing it will undergo, and the rights granted to Candidate Users by the Data Protection Regulation. APLI must maintain the confidentiality of Users' Personal Data and adhere to the guidelines set out in the Corporate User's privacy notice.

We have sufficient administrative, technological, and physical security measures for the protection, confidentiality, and safeguarding of your Personal Data, as well as to restrict access to it to unauthorized people.

3. What personal data do we collect from you?

For the purposes set out in this Notice, APLI could collect the following personal data from you; the data we collect varies, depending on whether you are a Corporate User or a Candidate User:

1. Identification Data: Information that differentiates you from other individuals; these data include: full name; for Candidate Users, we request name, gender, marital status, nationality, date of birth, photograph and presentation video; personal identification information or numbers including: tax records, official identification or ID document, birth certificate, proof of address, curriculum vitae, criminal record certificate, social security number, driver's license and identification data of your dependents. Depending on the process, we may ask for copies of credentials associated with the mentioned documents or others.
2. Contact Data: Information that allows us to stay in touch with you; these data include: address and postal code, email and telephone numbers (mobile and landline).
3. Work Data: For Candidate Users, information concerning your previous or current jobs, duration, salary, position or commission in the company you work for; performance indicators, professional experience, information about training you've taken, evaluations, professional profile, professional references and reasons for termination of your previous employment relationships.
4. Academic Data: For Candidate Users, information that allows us to know your professional orientation including: your education, educational background, specialization, level of specialization, titles, certificates, recognitions, and professional license.
5. Results of personality, soft skills, and hard skills evaluations: For Candidate Users, occasionally we will obtain personality and skills estimations through psychometric tests and other online assessments.
6. Financial and Patrimonial Data: bank account data (to facilitate payments between Users).

6. Principles of Personal Data Processing

APLI, during its business activities, collects, uses, stores, transmits, and performs various operations on User's Personal Data. All Personal Data Processing carried out by APLI (including responsible parties, in-charge parties, and/or third parties to whom personal data is transferred or sent according to this Notice) must adhere to the principles and rules set out in the Data Protection Regulations and in this Notice to ensure User's habeas data rights and meet obligations imposed by Data Protection Regulations on APLI. These principles include:

1. Prior Authorization: Personal Data Processing will occur only after obtaining prior, express, and informed consent from the data owner, unless the Data Protection Regulation establishes an exception. In cases where personal data has been obtained prior to the application of Data Protection Regulations, APLI will seek suitable means to solicit data owners for their retroactive authorization.
2. Authorized Purpose: All Personal Data Processing activities must adhere to the purposes mentioned in this Notice or in specific documents regulating each type or process of User's personal data processing. The purpose of processing particular data must be informed to the data owner at the time of obtaining their consent. Personal Data cannot be processed beyond the purposes informed and consented to by the data owners.
3. Data Quality: Personal Data undergoing Processing must be truthful, complete, accurate, updated, verifiable, and understandable. APLI will abstain from processing any personal data that is partial, incomplete, fractional, or misleading, or will request its owner to complete or correct the information.
4. Data Owner Information: APLI must provide information about the existence of personal data pertaining to the data owner when they request it. The APLI Data Protection Committee will handle this information delivery.
5. Restricted Circulation: Personal Data can only be processed by authorized APLI personnel or those whose duties involve conducting such activities. Personal Data cannot be delivered to unauthorized individuals or those not enabled by APLI to perform the processing.
6. Confidentiality: APLI will carry out processing by employing necessary technical, human, and administrative measures to maintain data confidentiality and prevent unauthorized individuals or authorized individuals acting fraudulently from tampering, modifying, viewing, using, accessing, deleting, or knowing the personal data, or causing the data to be lost. Every new project involving Personal Data Processing must consult this Notice to ensure compliance with this rule.
7. Confidentiality and Subsequent Processing: Any personal data that is not public data must be treated as confidential, even after the contractual relationship or bond between the User and APLI has ended. Upon termination of such bond, personal data must continue to be treated according to this Notice and the Data Protection Regulation.
8. Necessity: Personal Data can only be processed as long as and to the extent that the purpose of its processing justifies it.

6. Authorization to Contact Third Parties (Personal or Professional References)

In the case of Candidate Users, APLI may need to contact your past employers. Therefore, please ensure that the third-party data you provide us is accurate, complete, correct, and updated.

7. How Do We Obtain Your Personal Data?

For our Candidate Users, we obtain your data when you (i) create and complete your profile on any of APLI's Digital Media; (ii) interact with tools that APLI uses to provide the Service; and (iii) interact with the "software as a service" tools that APLI provides directly to Corporate Users.For Corporate Users, we obtain your data directly when you (i) enter any of APLI's Websites, either through cookies or when you freely provide such data when requesting the Service; (ii) communicate with us via phone or email; (iii) respond to our service and quality surveys, usually conducted over the phone; (iv) create an account with us; and (v) enter comments or reviews on our public forums.We may also obtain data from you through third parties by: (i) authentication through social networks, messaging platforms or third-party digital media (e.g., Facebook), (ii) our third-party data aggregators, and (iii) third-party co-sponsors with whom we partner for a specific promotion or offer.In case you provide us with your data through electronic means like our official site, we inform you about the use of cookies and/or similar technologies.A cookie is a data file stored on your computer or electronic communication device when you browse our Digital Media. This exchange of status information between our Digital Media and your browser can reveal session identifiers, authentication, or user preferences, as well as any data stored by the browser about the website. The data obtained in this way allows us to provide you with a better service through our Digital Media. You can manage your cookie preferences in most web browsers. You can adjust your browser to reject cookies or delete specific cookies. You should usually also manage similar technologies in the same way you manage cookies - using your browser preferences. The following links show how to adjust the browser settings of commonly used browsers:

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  Chrome: https://support.google.com/chrome/answer/95647
• Edge: https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879
• Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/
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  Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies

8. What Do We Use Your Personal Data For?

The collection and Processing of your Personal Data vary depending on whether you are a Candidate User or a Corporate User of our websites, as indicated in this clause:

• For Candidate Users, your information is processed for the following primary purposes:
  
  i. To identify you as a Candidate-User, so you can receive proposals and interact directly with Corporate Users through the "software as a service" tools provided by APLI directly to them as part of the Service.
  
  ii. To generate your profile on our Digital Media and to manage and keep your account operational. This includes: (a) providing the Service; (b) creating and managing your registered account with us, including managing benefits related to your account; (c) offering you the chance to contact Corporate Users and send you comments or reviews generated by Corporate Users; (d) keeping a history of your account; (e) offering you personalized proposals according to each Candidate-User's interests; and (f) personalizing the Candidate-User experience on APLI's Digital Media.
  
• For Candidate Users, your information is processed for the following secondary purposes:
  
  i. For marketing or commercial prospecting purposes, including sending updates, notifications, and information about our services.
  
  ii. Personalizing your experience on APLI's Digital Media.
  
• For Corporate Users, your information is processed for the following primary purposes:
  
  i. Identifying you as a Corporate User.
  
  ii. Personalizing your experience on APLI's Digital Media.
  
  iii. Responding to your comments, questions, complaints, and suggestions, and providing any service available to Corporate Users.
  
• For Corporate Users, your information is processed for the following secondary purposes:
  
  i. For marketing or commercial prospecting purposes, including sending updates, notifications, and information about our services.
  

Please note that using your data for managing advertising activities is not essential for maintaining our relationship with you. Therefore, if you disagree with the use of your data for secondary purposes, you can contact us at the email address detailed below to exercise your rights in relation to your data or object to the processing of your personal data.

9. Who do we share your personal data with?

APLI may share or transfer your Personal Data to various entities for the purposes outlined in this Notice. Such sharing and transfers, both domestic and international, may include the following scenarios:

• APLI may partially or completely share your Personal Data with our customers or service providers who assist us in conducting our business, such as recruitment and selection services, accounting or IT firms aiding us in payment administration, and legal or tax consultants. In these cases, APLI ensures these entities uphold contractual obligations for information security and confidentiality.
• Your personal data may be transferred to administrative or judicial authorities when legally necessary to safeguard public interest, protect APLI's rights, protect third-party rights, or for the enforcement or administration of justice.
• If you are a User-Candidate, we may transfer your Personal Data to Corporate Users interested in recruitment proposals via APLI’s “software as a service.”
• Your information may be disclosed or transferred to a third party in the context of a corporate transaction, including a merger, asset sale, or acquisition.
• Your data may be shared with our parent companies, controlling entities, affiliates, and subsidiaries, all of which follow the same data protection standards.
• In other cases, as permitted by applicable laws or with your consent.

Such transfers are necessary to maintain our contractual relationship with you. APLI does not rent or sell your personal data to third parties.

10. Data Subject Rights

You or your legal representative can exercise your ARCO rights (Access, Rectification, Cancellation, Opposition) or revoke your consent for the processing of your personal data through our online form at https://apli.typeform.com/to/ft57BR. The form contains all elements necessary to facilitate your request in accordance with regulations. The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information. A request also must include sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.APLI's Data Protection Committee will respond within 20 working days.

11. APLI's Data Protection Committee

The Committee is available to assist you with data subject rights, consent revocation, and/or limitation-disclosure of your personal data. It also ensures the protection of your personal data within the organization. You can reach them at the addresses listed in the previous sections of this document, or by email at privacy@apli.jobs.

12. What options do I have to limit how APLI uses my personal data?

APLI provides options to control how your Personal Data is used. You can choose to stop receiving our commercial messages, offers, and advertisements. If you wish to stop receiving email messages, text messages, or other communications about our new products, promotions, or events, you can unsubscribe following the instructions provided in the email or message you received. You can also limit or opt-out of receiving advertising messages via phone or email, or update or delete your account information at any time by emailing us at privacy@apli.jobs.

13. Rights under the California Consumer Privacy Act (CCPA)

If you are a resident of California, you have specific rights regarding your personal data, under the California Consumer Privacy Act (CCPA). These rights include:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you. You also have the right to know the categories of sources from which the personal data was collected, the business purpose for collecting or selling the data, and the categories of third parties with whom we share personal data.
• Right to Delete: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions defined in the CCPA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services, charge you different prices or rates for goods or services, or provide you a different level of quality of goods or services.
• Right to Opt-out of the Sale of Personal Information: If we sell your personal information, you have the right to opt-out at any time. We do not sell the personal information of minors under 16 years of age without affirmative authorizati

To exercise your CCPA rights, you can submit a verifiable consumer request to our Data Protection Committee at privacy@apli.jobs. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information

The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information. A request also must include sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

For any further information, or if you have any concerns about our data policies, please contact our Privacy Committee. You can reach them at the addresses listed in the previous sections of this document, or by email at privacy@apli.jobs.

Please note that these CCPA rights are subject to various exclusions and exceptions under the law. The rights under CCPA are in addition to any other rights you may have under other applicable data protection laws

14. GDPR - Rights for Users in the European Economic Area

If you are a resident of the European Economic Area (EEA), you have certain data protection rights, in accordance with the General Data Protection Regulation (GDPR). We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

If you are a resident of the European Economic Area (EEA), you have the following data protection rights:

• The right to access, update or delete the information we have on you.
• The right of rectification.
• The right to object.
• The right of restriction.
• The right to data portability.
• The right to withdraw consent.

To exercise your GDPR rights, you can submit a verifiable consumer request to our Data Protection Committee at privacy@apli.jobs. The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information. A request also must include sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

For any further information, or if you have any concerns about our data policies, please contact our Privacy Committee. You can reach them at the addresses listed in the previous sections of this document, or by email at privacy@apli.jobs.

15. LGPD - Rights for Users in Brazil

If you are a resident of Brazil, you have certain data protection rights, in accordance with the Lei Geral de Proteção de Dados (LGPD). We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

If you are a resident of Brazil, you have the following data protection rights:

• The right to access, update or delete the information we have on you.
• The right to confirmation and access of your data.
• The right to correct incomplete, inaccurate, or outdated data.
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD.
• The right to the portability of data to another service or product provider, by means of an express request.
• The right to delete personal data processed with your consent.
• The right to information about public and private entities with which we have shared data.
• The right to refuse consent and be informed about the consequences.
• The right to revoke consent.

16 Security Measures

APLI is committed to keeping your personal data secure. Each of APLI's Digital Platforms has security measures to help protect you from the loss, misuse, and alteration of confidential information.

17. Modifications to the Privacy Notice

APLI reserves the right to make changes or updates to this Privacy Notice at any time. The revised Notice will be published on the APLI website or notified to you via email. We recommend regularly reviewing our website, as your continued use will be considered acceptance of these changes. If you do not agree with the modifications, please contact APLI's Data Protection Committee.