Updated: August 11, 2023

Our Policy:

Welcome to the web site (the “Site”) of inspHIRE IO Corp. dba Candidly (the “Company”, “we”, “us” and/or “our”). This Site is operated by the Company and has been created to provide information about the Company, websites; applications; and other products and services under our control or offered by us (the “Company Services”) to our Site visitors and the users of the Company Services (“you”, “your”) as outlined in our Terms of Service. This Privacy Statement sets forth the Company’s policy with respect to information including personally identifiable data and other information that is collected from Site visitors.

Information We Collect:

When you interact with us through the Site, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Site: We collect Personal Data from you when you voluntarily provide such information, such as when you create an account on the Site, contact us with inquiries, register for access to the Company Services, or use certain Company Services. “Personal Data” means information that alone or when in combination with other information may be used to readily identify you. We do not consider Personal Data to include information that has been de-identified or aggregated so that it does not allow a third party to easily identify a specific individual. The Personal Data we collect may include individually or collectively, but is not limited to, your name, date of birth, address, social security number, email address, phone number, current and prior job titles, current and prior employers, schools attended, information about your student debt and other information related to your financial situation.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Statement.

Credit Report Information: Personal Date also includes credit report information we obtain. When you create and maintain an Account with us, you provide written instructions in accordance with the Fair Credit Reporting Act and other applicable law, for the Company, and our agents to request, receive, and retain a copy of your consumer credit report and score from consumer credit reporting agencies (i.e., Experian, TransUnion and/or Equifax).

Financial Account Information: Some Company Services require you to give us access to your financial account information. When you connect your financial accounts through our website, you will give us and/or necessary third party account aggregation service providers that have been vetted by the Company, identifiers and login information required by the provider and/or servicer of your account, such as your username and password, or a security token. In some cases, you will also provide your Social Security number, date of birth, phone number, email address, security questions and answers, and one-time password (OTP) to help verify your identity and connect your financial accounts. When providing this information, you give us and/or the aggregator the authority to act on your behalf to access and transmit your information from the relevant bank or other entity that provides your financial accounts to us. You may also provide us with identifiers and other information, including your name, email address, and phone number, when you contact us or enter any such information on our websites. The information we receive from the financial product and service providers that maintain your financial accounts varies depending on a number of factors, including the specific Company Services you are using and the particular aggregator we may use, as well as the information made available by the aggregator. But, in general, we collect identifiers, commercial information, financial information, and professional information from your financial product and service providers, which include the following types of information:

• General account information regarding ownership, identification, contact details, guarantors, type, status and servicer;
• Account holdings, loan types, credit vehicles, insurance contracts, balances, prices, cost-basis, transactions, history, payments, limits, liens, rates, fees, and terms;

The data collected from your financial accounts may include information from all accounts (e.g., checking, savings, investment, loan and credit card) accessible through a single set of account credentials.

Information Collected Through Passive Technologies:

Passively Collected Information: When you access or use the Site, we and certain third parties that provide functionality on the Site, such as Facebook, Twitter, Google and ad networks, may engage, receive, collect, and store certain types of information through automatic data collection tools including cookies, pixel tags, web beacons, embedded web links, and similar technology. Such information is collected passively using various technologies, and may include but is not limited to your Internet Protocol (IP) address, browser type, the date and time that you access the Site, referring/exit pages and URLs, and number of clicks. The Company may store such information itself or such information may be included in databases owned and maintained by Company affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of your Internet service providers.

When you visit the Site, we and third parties that provide certain functionality on the Site may engage, receive and record information from “cookies” and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Managing Cookies and Do Not Track: Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Statement whether or not a DNT signal is received.

Aggregated or De-Identified Personal Data: In an ongoing effort to better understand and serve the users of the Company Services, the Company and third parties that provide services to the Site and Company Services may conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to or possessed by us. This research may be compiled and analyzed on an aggregate and/or de-identified basis, and the Company may share this data with its affiliates, agents and business partners. The Company may also disclose this data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information:

Company uses the Personal Data you provide in a manner that is consistent with this Privacy Statement. Company does not sell Personal Data.

Internal and Service-Related Use. We use information, including Personal Data, for our internal use and to provide the Company Services. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided.

Communication. If you contact us by email, chat, text, phone or other means, we may use the Personal Data you provide to deliver existing services, greater personalization, answer your question, resolve your problem and/or generate/provide guidance and insights. The Company and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data, passively collected data, and personally non-identifiable information collected through the Site to help us improve the content and functionality of the Site, to better understand our users and to improve the Company Services.

The Company and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. The communications we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Our Disclosure of Your Personal Data and Other Information:

We may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Agents, Consultants, Unaffiliated Third Parties and Related Companies: Company, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. We may also share your Personal Data with approved third-party servicers for purposes consistent with this Privacy Statement. For certain account types, the Company may utilize account linking and aggregation services through Plaid Inc. (“Plaid”). By using account linking and aggregation services, you acknowledge and agree that the terms of Plaid’s Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy-policy) will govern Plaid’s use of such information, and you expressly agree to the terms and conditions of Plaid’s Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide these services to you.

Marketing: The Company and its affiliates may use information to contact you in the future to tell you about services or offers we believe will be of interest to you.

Legal Requirements: The Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of the Company, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability

We may also provide certain functionalities and/or opportunities for disclosure of your information, such as sharing your profile on third-party social media websites or showcasing your profile on public pages of our Site. We will provide you the opportunity to opt-out of participating in such opportunities.

Tailored Advertising: We may use third-party advertising technologies that allow for the delivery of relevant content and advertising on the Service, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

We may also allow other third-parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick, Quora Pixels and others) to serve tailored ads to you on the Service, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service.

If a third-party advertiser asks the Company to show an ad to Users based on demographics or other interests, the Company will determine the target audience. The Company will only provide anonymous aggregated data to the advertiser. However, if you respond to such an ad, the advertiser may conclude that you are a member of the target audience for the advertisement.

You can learn more about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, by visiting the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To opt out of tracking via the Quora Pixels, please click here. The Company does not control any of these-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that to the extent advertising technology is integrated into the Service, you may still receive advertisements even if you opt out. In that case, the advertising will not be tailored to you or your interests.

Your Choices:

You can use the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Company Services.

Exclusions:

This Privacy Statement does not apply to any Personal Data collected by Company other than Personal Data collected through the Site. This Privacy Statement shall not apply to any unsolicited information you provide to Company through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Legal Age:

Company does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Statement by instructing their children never to provide Personal Data on this Site without their permission. If you have reason to believe that an individual under the age of 18 has provided Personal Data to Company through this Site, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites:

This Privacy Statement applies only to the Site. This Site may contain links to other web sites not operated or controlled by Company (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. We do not own, control, or operate the Third Party Sites, and we are not responsible for the privacy policies or practices of such sites. The links from this Site do not imply that the Company endorses or has reviewed any Third Party Sites. We encourage you to read the privacy policies of the Third Party Sites before disclosing your personal information, as those privacy policies will apply to information collected through those sites, and we suggest contacting those sites directly for information on their privacy policies.

Security:

The Company takes reasonable steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free, and we cannot ensure or warrant the security of any information you provide to the Company. In particular, e-mail sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to the Company via the Internet.

By using the Site or providing Personal Data to the Company, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or by sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at legal@getcandidly.com.

Other Terms and Conditions:

Your access to and use of this Site is subject to the Terms of Use.

Changes to Company’s Privacy Policy and Practices:

The Site and our business may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy or practices concerning your Personal Data, as described further below.

Notice of Changes to Privacy Statement: Company reserves the right to update or modify this Privacy Statement at any time and from time to time. To the extent any updates are material, the Company will provide you with notice of such update via e-mail (sent to the email address specified in your account), notice on the Site, or other reasonable means prior to the change becoming effective Please review this statement periodically, and especially before you provide any Personal Data. This Privacy Statement was last updated on the date indicated above. Your continued use of the Site after any changes or revisions to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

New Uses of Personal Data: From time to time, the Company may desire to use Personal Data for uses not previously disclosed in our Privacy Statement. If the Company’s practices change regarding previously collected Personal Data in a way that would be materially less restrictive than stated in the version of this Privacy Statement in effect at the time the Company collected the information, the Company will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Access to Information; Updating Information; Contacting Company:

If you would like to update or modify any Personal Data you have submitted via this Site, you can do so by emailing us at legal@getcandidly.com. We will take reasonable steps to update or correct such Personal Data in our possession.

Please also feel free to contact us if you have any questions about the Company’s Privacy Statement or the information practices of this Site.

You may contact us as follows: legal@getcandidly.com

International Users:

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that by providing your information to this Site you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Statement.

Your California Privacy Rights:

Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us as follows: legal@getcandidly.com; Candidly, 228 Park Ave S., PMB 54085, New York, NY 10003-1502. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

CCPA Notice

https://getcandidly.com/ccpa-notice/