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Mensch Privacy Notice

TruMensch Inc. ("Mensch", “we”, “us”, “our”) develops and operates a secure cloud-based HR platform that completely automates HR processes throughout the full employee lifecycle (the “Platform”). We respect the privacy of our users and are committed to protect the personal information that our users share with us. An employer that has entered into an agreement with Mensch is our corporate customer (“Employer“) and this Employer’s employees are our users (“Employees”, “you”). This Privacy Notice (the "Notice") describes the types of information we may collect from Employees or that Employees may provide when using the Platform. It also describes our practices for collecting, using, maintaining and processing such information, and the rights and options available to Employees with respect to their personal data on the Platform. Please note that this Notice covers the Platform’s privacy practices in general matters. The Employer usually has an additional privacy notice explaining its own specific privacy practices related to the personal data of its employees (the “Employer’s Notice”). You should also read the Employer’s Notice. You can access it through the link provided to you by the Employer.

Data Controller and Data Processor

The Employer is the data controller of the personal data on the Platform. Generally, Mensch is the data processor on behalf of the Employer. However, Mensch is the controller for Analytics Information. The Employer is the data controller of your personal data on the Platform. It determines the purposes and means of processing your data. You can review the Employer’s contact information in the Employer’s Notice. Mensch is the data processor of your personal data on the Platform, processing the data on behalf of the Employer. However, Mensch is the data controller for the Analytics Information, as explained below. Mensch’s address is 754 Moreno Ave. Palo Alto CA 94303, USA. We can be reached by email at Support@mensch.io

Personal Data Processed

We process information about you relating to your employment by the Employer Depending on what the Employer chooses to collect from you, we will process the following information about you as an employee of the Employer: full name, user name, e-mail address, address, gender, date of birth, financial information (salary level), Curriculum Vitae (resumé), your position, events in the lifecycle of your employment, performance and evaluation data, absence from work, health (sick leave), and other information as specified in the Employer’s notice. Your personal data on Mensch can also originate from other sources, such as recruiting platforms used by the Employer during your recruiting process. For more information about the source from which your personal data originates, contact the Employer, in accordance with the Employer’s Notice. We also collect analytics information about your use of the Platform When you visit or use the Platform, we will record and collect certain information about your interaction with the Platform, including IP address from which you accessed the Platform, time and date of access, type of browser used, language use, links clicked, and actions taken while using the Platform ("Analytics Information").

Who your personal data is used

The Employer will use your personal data to manage HR activities throughout your employment lifecycle. The Employer will use your personal data to manage HR activities throughout your employment lifecycle, in accordance with the Employer’s policies for HR management. Mensch will use your Analytics Information, for its quality assurance and business development purposes of the Platform Mensch will use the Analytics Information for its quality assurance and business development purposes of the Platform.

Who will process your data

We will not share your information with third-party recipients, except in the events listed below, or if you give your explicit consent. Your personal data will be handled by our service provider helping us operate the Platform Our service providers who assist us with the internal operations of the Platform will also take part in processing some / all of your personal data. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own purposes. We do not sell your personal information to third parties. We will share your Information with competent authorities, if you abused your rights to use the Platform, or violated any applicable law. If you have seriously abused your rights to use the Platform, or violated any applicable law, we will share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach. We will share your Information if we are legally required. If we are required to disclose your information by a judicial, governmental or regulatory authority. We will share your Information with third-party in any event of change in Mensch’s structure. If the operation of the Platform is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition, we will share your information only as required to enable the structural change in the operation of the Platform.

Security and data retention

Details of the data retention periods are explained in the Employer’s Notice. In general, the Employer will keep your data throughout your employment period. The storage periods for your personal data and the criteria used to determine them, are specified by the Employer. Mensch will retain your personal data in accordance with the Employer’s instructions. Mensch will delete your personal data within a few weeks after Employer’s account is no longer active, after trial period has ended or upon specific request from the Employer. Please review the Employer Notice for more information about the specified retention periods. We implement measures to secure your Information We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Platform will be immune from information security risks.

International data transfers

We will internationally transfer your Information only in accordance with applicable data protection laws. If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

Additional information for individuals in the EU

Legal basis under EU law for processing your personal data The legal basis under EU law for processing your personal data for the Employer’s HR management purposes is the performance of your employment contract with the Employer, the Employer’s compliance with legal obligations and the Employer’s legitimate interest in managing its HR processes for the proper management of its business. The legal basis under EU law for processing your Analytics Information is Mensch’s legitimate interest in maintaining, developing and enhancing the Platform. The legal basis under EU law for processing your data for the purpose of handling instances of abusive use of the Platform is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business. The legal basis under EU law for processing your data where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us. The legal basis under EU law for us processing your data in the event of a change in our corporate structure is our legitimate interests in our business continuity. You have the right to access, update or delete your information and obtain a copy of your information. If you are in the EU, you may ask the Employer to access the personal information about you that is stored on the Platform, or have the Employer update, correct or delete such information. You are also entitled to obtain from the Employer your information in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact the Employer through the channels listed on the Employer’s Notice. Cross-border transfers Information we collect from you will generally be processed within the European Union. If we transfer your information from the EU to other jurisdictions outside the EU, we will always endeavor to do so using adequate safeguards determined by the EU Commission, such as Privacy-Shield certified companies in the United States. You have a right to submit a complaint to the relevant supervisory data protection authority. Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

Minors

The Platform is not directed to employees under 16. The Platform is not directed to users under the age of 16. We do not knowingly collect or solicit information or data from children under the age of 16 or knowingly allow children under the age of 16 to use the Platform. The Employer will have its own policies regarding underaged employees.

Changes to this Privacy Notice

If we will change this Notice, we and the Employer will make efforts to proactively notify you of such changes. From time to time, we may change this Notice. If we do so, we and the Employer will make efforts to proactively notify you of such changes. In any event, the latest version of the Notice will always be accessible at https://mensch.io/privacy-notice/ Last Update: March 10 , 2019