Privacy Policy

1. INTRODUCTION

1.1 Website Owner. This Privacy Policy (“Policy”) describes how Better Placement, LLC, a Limited
Liability Company registered in Illinois (“Company,” “we,” “our,” or “us”) collects, uses, and

discloses personal information when you visit or use our website http://www.better-
placement.com/ (the “Site”), which primarily facilitates recruiting services for companies.

1.2 Scope and Jurisdiction. This Policy applies to all users of the Site, including job seekers,
employers, and general visitors. Our primary operating jurisdiction is Illinois, and this Policy is
designed to comply with the laws of this jurisdiction. By accessing or using our Site, you agree to this
Policy. If you do not agree with our policies and practices, your choice is not to use our Site.

1.3 Changes to Privacy Policy. We reserve the right to amend this Policy at any time. We will post
any revised version of the Policy on this page and, if the changes are significant, we will provide a
more prominent notice (including, for certain services, email notification of privacy policy changes).
The revised version will be effective as of the updated date stated at the top of this Policy. We
encourage you to review this Policy periodically.

2. PERSONAL INFORMATION WE COLLECT

2.1 Categories of Personal Information. We collect various categories of personal information from
and about users of our Site, including:

(a) Identifiers: Such as name, postal address, email address, telephone number, unique personal
identifier, online identifier, Internet Protocol address, or other similar identifiers.

(b) Professional or Employment-Related Information: Such as current or past job history,
educational background, professional certifications, work experience, skills, and references.

(d) Protected Classification Characteristics: Such as age, race, color, ancestry, national origin,
citizenship, marital status, sex (including gender, gender identity, gender expression), sexual
orientation, or veteran or military status, to the extent voluntarily provided or as required by law.

(e) Internet or Other Electronic Network Activity Information: Such as browsing history, search
history, and information regarding your interaction with our Site.

(f) Geolocation Data: General location derived from IP address.

(g) Sensory Data: Audio or visual information, such as video interview recordings, if applicable.

(h) Inferences: Drawn from any of the information identified above to create a profile reflecting

your preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.

2.2 Sources of Personal Information. We obtain the categories of personal information listed above
from the following sources:

(a) Directly from you when you provide it to us, such as when you create an account, submit a job
application, or upload a resume.

(b) Indirectly from you when you interact with our Site.

(c) From third parties that interact with us in connection with the services we perform, such as
reference providers or background check services.

3. USE OF PERSONAL INFORMATION

3.1 Business Purposes. We may use the personal information we collect for one or more of the
following business purposes:

(a) To facilitate job matching and recruiting services, including analyzing your qualifications against
job requirements and presenting your profile to potential employers.

(b) To create, maintain, customize, and secure your account with us.

(c) To provide you with support and to respond to your inquiries, including to investigate and
address your concerns and monitor and improve our responses.

(d) To personalize your Site experience and deliver content relevant to your interests, including
targeted job recommendations and career development resources.

(e) To help maintain the safety, security, and integrity of our Site, products and services, databases
and other technology assets, and business.

(f) For testing, research, analysis, and product development, including to develop and improve our
Site, products, and services.

(g) To respond to law enforcement requests and as required by applicable law, court order, or
governmental regulations.

(h) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other
sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal information held by us about our Site users is
among the assets transferred.

3.2 Sale of Personal Information. We do not sell your personal information to third parties for
monetary or other valuable consideration.

4. DISCLOSURE OF PERSONAL INFORMATION

4.1 Categories of Third Parties. We may disclose your personal information to the following
categories of third parties:

(a) Employers or hiring companies that use our Site for recruiting purposes.

(b) Service providers and other third parties we use to support our business, including:

• Cloud storage providers
• Data analytics providers
• Email service providers
• Customer relationship management systems
• Applicant tracking systems
• Background check providers

(c) Third parties to whom you or your agents authorize us to disclose your personal information in
connection with products or services we provide to you.

(d) Government or regulatory authorities, as required by law.

4.2 Legal Requirements. We may disclose your personal information if required to do so by law or in
response to valid requests by public authorities (e.g., a court or government agency).

5. DATA RETENTION

5.1 Retention Period. We will retain your personal information only for as long as reasonably
necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying
any legal, regulatory, tax, accounting, or reporting requirements. Specific retention periods are as
follows:

(a) Account information: For as long as your account is active, plus 2 years after account closure.

(b) Job application data: 1 year after the position is filled or the application is withdrawn.

(d) Communication records: 3 years from the last interaction.

(e) Financial transaction data: 7 years, as required by tax laws.

5.2 Criteria for Retention. To determine the appropriate retention period for personal information,
we consider:

(a) The amount, nature, and sensitivity of the personal information.

(b) The potential risk of harm from unauthorized use or disclosure of your personal information.

purposes through other means.

(d) The applicable legal, regulatory, tax, accounting, or other requirements.

6. YOUR RIGHTS AND CHOICES

6.1 Access and Data Portability Rights. You have the right to request that we disclose certain
information to you about our collection and use of your personal information over the past 12

months, and to receive a copy of that information in a structured, commonly used, and machine-
readable format.

6.2 Correction Rights. You have the right to request that we correct any inaccurate personal
information about you, taking into account the nature of the personal information and the purposes
of the processing of the personal information.

6.3 Deletion Rights. You have the right to request that we delete any of your personal information
that we collected from you and retained, subject to certain exceptions provided by law.

6.4 Restriction of Processing. You have the right to request that we restrict the processing of your
personal information under certain circumstances, such as when you contest the accuracy of your
personal information.

6.5 Right to Object. You have the right to object to our processing of your personal information
based on our legitimate interests, including profiling, and for direct marketing purposes.

6.6 Right to Withdraw Consent. Where we rely on your consent to process your personal
information, you have the right to withdraw your consent at any time.

6.7 Exercising Your Rights. To exercise the rights described above, please submit a verifiable
consumer request to us using the contact information provided in Section 11. We will respond to all
legitimate requests within one month.

6.8 Verification Process. We may need to request specific information from you to help us confirm
your identity and ensure your right to access your personal information (or to exercise any of your
other rights). This is a security measure to ensure that personal information is not disclosed to any
person who has no right to receive it.

7. DATA SECURITY

7.1 Security Measures. We have implemented appropriate technical and organizational measures
designed to secure your personal information from accidental loss and from unauthorized access,
use, alteration, and disclosure. These measures include:

(a) Encryption of data in transit and at rest using industry-standard encryption protocols.

(b) Regular security assessments and penetration testing of our systems.

(d) Regular employee training on data protection and security best practices.

(e) Physical security measures to protect our data centers and offices.

7.2 Limitations. The safety and security of your information also depends on you. Where we have
given you (or where you have chosen) a password for access to certain parts of our Site, you are
responsible for keeping this password confidential. We ask you not to share your password with
anyone.

7.3 Disclaimer. Despite our best efforts, no method of transmission over the Internet or method of
electronic storage is 100% secure. While we strive to use commercially acceptable means to protect
your personal information, we cannot guarantee its absolute security.

8. COOKIES AND SIMILAR TECHNOLOGIES

8.1 Use of Cookies. We use cookies and similar tracking technologies to track activity on our Site
and hold certain information. Cookies are files with small amount of data which may include an
anonymous unique identifier. Cookies are sent to your browser from a website and stored on your
device. We use the following types of cookies:

(a) Strictly Necessary Cookies: These cookies are essential for you to browse the website and use its
features, such as accessing secure areas of the site.

(b) Preferences Cookies: These cookies allow the website to remember choices you have made in
the past, like what language you prefer or what your user name and password are so you can
automatically log in.

(c) Statistics Cookies: These cookies collect information about how you use a website, like which
pages you visited and which links you clicked on. None of this information can be used to identify
you. It is all aggregated and, therefore, anonymized.

(d) Marketing Cookies: These cookies track your online activity to help advertisers deliver more
relevant advertising or to limit how many times you see an ad.

8.2 Cookie Preferences. You can instruct your browser to refuse all cookies or to indicate when a

cookie is being sent. However, if you do not accept cookies, you may not be able to use some
portions of our Site. You can learn more about cookies and the following third-party websites:

• AllAboutCookies: http://www.allaboutcookies.org/
• Network Advertising Initiative: http://www.networkadvertising.org/

CHILDREN’S PRIVACY

Our Site is not intended for children under 16 years of age. No one under age 16 may provide any
personal information to or on the Site. We do not knowingly collect personal information from
children under 16. If we learn we have collected or received personal information from a child under
16 without verification of parental consent, we will delete that information. If you believe we might
have any information from or about a child under 16, please contact us using the information
provided in Section 11.

9. CONTACT INFORMATION

If you have any questions or comments about this Policy, our privacy practices, or if you would like
to exercise your rights and choices, please contact us at:

Better Placement, LLC
Attn: Privacy Officer
7777 W. Lincoln Highway, Suite A, First Floor
Frankfort, IL 60423
Email: customersupport@better-placement.com
Phone: (708) 696-4060

10. JURISDICTION-SPECIFIC PROVISIONS

10.1 European Union and United Kingdom Residents. If you are a resident of the European Union
or the United Kingdom, you may have additional rights under the General Data Protection
Regulation (GDPR) or the UK GDPR.

10.2 California Residents. If you are a California resident, you may have additional rights under the
California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

11. GLOSSARY OF TERMS

To help you better understand this Privacy Policy, we provide the following definitions of key terms
used throughout:

• Personal Information: Information that identifies, relates to, describes, is reasonably capable of
being associated with, or could reasonably be linked, directly or indirectly, with a particular
consumer or household.

• Processing: Any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means.

• Data Subject: An identified or identifiable natural person to whom the personal data relates.

• Controller: The natural or legal person, public authority, agency or other body which, alone or
jointly with others, determines the purposes and means of the processing of personal data.

• Processor: A natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.

• Consent: Any freely given, specific, informed and unambiguous indication of the data subject’s
wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the
processing of personal data relating to him or her.

• Profiling: Any form of automated processing of personal data consisting of the use of personal
data to evaluate certain personal aspects relating to a natural person.

• Legitimate Interest: The interest of a business in conducting and managing its business to enable it
to give clients the best service/product and the best and most secure experience.

12. SPECIFIC RECRUITING PRACTICES

To provide greater transparency about our recruiting practices, we outline below how we use
personal data throughout the recruitment process:

12.1 Application Submission: When you submit an application, we collect and process the personal
information provided in your resume, cover letter, and application form to assess your suitability for
the role.

12.2 Interview Process: If selected for interviews, we may collect additional personal information
through video interviews, skills assessments, or reference checks. This information is used to further
evaluate your qualifications and fit for the role.

12.3 Background Checks: For certain positions, we may conduct background checks in accordance
with applicable laws. This may involve collecting and verifying information about your employment
history, education, criminal record, or credit history.

12.4 Job Offers: If you are selected for a position, we will use your personal information to prepare
and communicate the job offer, and to establish an employment relationship if you accept.

12.5 Talent Pool: With your consent, we may retain your information in our talent pool for future
opportunities, even if you are not selected for the current position.

12.6 Analytics and Improvement: We analyze aggregated, anonymized data from the recruitment
process to improve our hiring practices, identify trends, and enhance our services.

13. ACCOUNTABILITY AND GOVERNANCE

We are committed to demonstrating compliance with data protection principles and have
implemented the following accountability and governance measures:

13.1 Data Protection Policy: We maintain an internal Data Protection Policy that sets out our
approach to data protection and the responsibilities of our staff.

13.2 Staff Training: All staff members who handle personal data receive regular training on data
protection principles and our privacy practices.

13.3 Data Protection by Design and Default: We integrate data protection considerations into our
products, services, and business practices from the design stage and throughout the lifecycle.

13.4 Data Protection Audits: We conduct regular audits to ensure compliance with this Privacy
Policy and applicable data protection laws.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical, or
business developments. When we update our Privacy Policy, we will take appropriate measures to
inform you, consistent with the significance of the changes we make. We will obtain your consent to
any material Privacy Policy changes if and where this is required by applicable data protection laws.
You can see when this Privacy Policy was last updated by checking the “Last Updated” date
displayed at the top of this Privacy Policy.

By continuing to access or use our Site after those changes become effective, you agree to be bound
by the revised Privacy Policy.

[END OF PRIVACY POLICY]

This Privacy Policy has been carefully drafted to comply with applicable data protection laws and to
provide comprehensive information about our data processing practices. By using our Site, you
acknowledge that you have read and understood this Privacy Policy and agree to be bound by its
terms.

If you have any questions or concerns about this Privacy Policy or our data practices, please don’t
hesitate to contact us using the information provided in Section 11. We are committed to protecting
your privacy and will make every reasonable effort to address your concerns promptly and
thoroughly.

Thank you for entrusting us with your personal information and for using our recruiting services.