Privacy Notice and Policy

Introduction

Welcome to 360AI. Your privacy is of paramount importance to us. This document outlines how we collect, use, and protect your personal data, and informs you of your rights under GDPR, UK GDPR, and CCPA.

This Privacy and Cookies Policy ("Policy") sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by 360AI, the operators of the 360AI platform, available at www.360ai.io.

360AI platform is operated by 360AI Ltd (Company No. 16314764), located at Unit 4 Willows Gate Stoke Lyne Road, Stratton Audley, Bicester, United Kingdom, OX27 9AU. In this Policy, "We," "Us," or "360AI" refers to 360AI Ltd.

Data Collection

We collect data in the following ways:

Publicly Available Data

We aggregate publicly available data from various websites and social media platforms to create comprehensive profiles of potential candidates. This data includes, but is not limited to:

• Name
• Professional background
• Contact information
• Social media profiles
• Employment history
• Skills and expertise

Customer Data

When professional recruiters register as customers on our platform, we collect data such as:

• Name
• Contact information
• Company details
• Payment information (if applicable)
• Usage data on our platform

We also utilise GDPR-compliant data providers to enrich our data as needed.

Purpose of Data Processing

Our primary purposes for processing data are:

• To assist professional recruiters in connecting with relevant individuals for recruitment purposes only.
• To manage our relationship with our customers, provide access to our services, and ensure a seamless user experience on our platform.

Legal Basis for Processing

The legal basis for processing your data is:

• Our legitimate interest (GDPR Article 6.1(f)) in facilitating connections between recruiters and candidates.
• Contractual necessity for customer data to fulfil our obligations to our customers.
• Data made "manifestly public" by the data subject (GDPR Article 9.2(e)).

Data Controller/Business

For the purpose of the GDPR and the CCPA:

• In respect of the personal data of visitors to the Website and users of the Services, business contacts, and prospects of 360AI, the Data Controller or Business under the CCPA is 360AI.
• In respect of the personal data of candidates who apply for, or who a Customer of 360AI contacts in respect of an opening, or in regard to Customer's employees' data, 360AI shall process personal information as a data processor on behalf of its Customers, who use our Services to assist with their recruitment processes and employee onboarding, or as Service Provider. When you apply for a role with one of 360AI's Customers, our Customer's privacy policy, rather than this Privacy Policy, will apply to our processing of your personal information.

Sources of Personal Data

We collect personal data about you from:

• You: When you provide such information directly to us, when you set up an Account with us to use the Services, and when personal data about you is automatically collected in connection with your use of our Services.
• Our Affiliates: When they provide us with personal data about you.
• Third Parties: GDPR-compliant data providers, service providers, social networks connected to the services, advertising partners, and other third parties.

Information We Collect from You

We collect and process some or all of the following types of information from you:

• Information that you provide by filling in forms on the Website.
• If you contact us, we may keep a record of that correspondence.
• Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs, and other communication data.
• The provision of your full name and email address, your employer and/or your place of work, and the URL of the business that you work for is required from you when you register to use our Services.

Lawful Basis for Processing

Under the GDPR and the UK GDPR, the lawful bases we rely on for processing your personal data include:

1. Legitimate Interest: For purposes such as assisting job applicants in finding a new job, providing and improving the Services, and advertising our products and services.
2. Contract: To provide the services and meet our contractual obligations towards you.
3. Consent: For specific purposes where we have obtained your consent.
4. Legal Obligation: To comply with a legal or regulatory obligation.

Your Rights

Subject to local data protection laws, and in particular under the GDPR and the UK GDPR, you have a number of important rights free of charge. These include rights to:

• Access your personal data.
• Correct any mistakes in your information.
• Erase personal data in certain situations.
• Receive personal data in a structured, commonly used, and machine-readable format.
• Object to processing of personal data for direct marketing.
• Restrict processing of personal data in certain circumstances.
• Claim compensation for damages caused by a breach of data protection laws.

For further information on each of those rights, see the General Data Protection Regulation (GDPR) Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the UK GDPR.

Google API Services

360AI's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Uses Made of Your Information

We use information held about you in the following ways:

• To ensure that content from the Website is presented in the most effective manner.
• To provide you with information, products, or services that you request from us.
• To notify you about changes to our Services.
• To provide you with information about our Services for marketing purposes.

Aggregate Data

We may use anonymised and/or aggregate data collected through your use of the Services for statistical purposes, improvement of the Services, research, or any other lawful purpose. Aggregate Data is not considered personal data.

Disclosure of Your Information

We may disclose your personal information to any member of our business and third parties in the following circumstances:

• If we sell or buy any business or assets.
• If we are under a legal obligation to disclose or share your personal data.
• To protect the rights, property, or safety of 360AI, the Platform, our users, and any third party with whom we interact.

Storage and Security of Personal Data

We take appropriate security measures to protect your personal data from loss, unauthorised access, or misuse. Access to your personal data is limited to authorised personnel who have a genuine business need and are bound by confidentiality obligations. We have procedures in place to address suspected data breaches and will notify you and the applicable regulator of a breach where legally required.

Retention of Personal Data

We will retain your data for as long as necessary to provide you with our Services, fulfil our obligations to our customers, or as long as necessary to fulfil the purpose for which the data was initially collected. We will also retain and use your personal data to comply with any legal, accounting, or reporting obligations.

Personal Data of Children

We do not knowingly collect or solicit personal data from children under 16 years of age. If you are under 16, please do not register for or use our Services or provide us with any personal data. If we become aware that we have collected personal data from a child under 16, we will promptly delete that information. If you believe that a child under 16 may have provided us with personal data, please contact us at support@360ai.io.

Your California Privacy Rights

If you are a California resident, you have rights outlined in this section. These include the right to:

• Access specific pieces of personal data we have collected.
• Request the deletion of personal data.
• Correct inaccurate personal data.
• Opt-out of the sale of personal data (though we do not sell personal data).
• Limit the use of sensitive personal information.
• Non-discrimination for exercising your CCPA rights.

Transfers of Personal Data

The Services provided by 360AI are hosted and operated in the United Kingdom through 360AI platform, a product of 360AI Ltd. If you are not a resident of the UK, please note that the laws in the UK may differ from the laws of your country. By using the Services, you acknowledge that any personal data about you, whether provided by you or obtained from a third party, is being provided to 360AI Ltd in the UK and will be hosted on UK servers. You authorise 360AI Ltd to transfer, store, and process your information in the UK and possibly other countries.

For transfers of data outside the European Economic Area (EEA) and Switzerland to countries other than the UK, 360AI relies on the European Commission Standard Contractual Clauses (EE SCCs) and other appropriate legal mechanisms as required.

Third Party Websites

The Website may contain links to and from the websites of our partner networks, advertisers, and affiliates. These websites have their own privacy policies and terms of use. We do not accept any responsibility or liability for these policies and terms of use. Before submitting any personal data to these websites, please check their respective policies.

How to Complain

We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation (GDPR) and the UK GDPR also give you the right to lodge a complaint with a supervisory authority, particularly in the European Union (EU) or European Economic Area (EEA) state where you work, normally reside, or where any alleged infringement of data protection laws occurred. In the UK, the supervisory authority is the Information Commissioner's Office (ICO), which can be contacted at ICO Complaints.

Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Any changes we make to our Policy in the future will be notified and made available to you using the Website. Your continued use of the Services and the Website shall be deemed as your acceptance of the revised Privacy Policy.

Contact

If you have any questions about this Privacy Policy or want to report a potential data breach, please reach out to support@360AI.io. Please note that 360AI Ltd's Data Protection Officer (DPO) responds to any requests submitted to support@360AI.io, attention 360AI's DPO.

Cookies Policy

What are Cookies

A cookie is a small file of letters and numbers that we put on your computer if you select to agree at the banner that is displayed to you during the first time you visit our Platform. You may accept or decline being tracked by indicating your preference for this banner. These cookies allow us to distinguish you from other users of the Platform, which helps us to provide you with a good experience when you browse our Platform and also allows us to improve the Platform.

How Do We Use Cookies?

We use cookies to:

• Recognise and count the number of visitors and see how visitors move around the site when they are using it.
• Identify and authenticate a user across different pages of our Platform.
• Retrieve a user’s previously stored data, for example, information that the user previously submitted to the Platform, so as to facilitate reuse of this information by the user.
• Personalise the Platform for you, including targeting advertisements which may be of particular interest to you.

Cookies in Use

When you use and access the Service, we may place a number of cookie files in your web browser. We use the following categories of cookies:

1. Strictly necessary cookies: These cookies are necessary for the Platform to function and are enabled by default at the time you access the Platform.
2. Functional/Preference cookies: These cookies are used to understand how you use the Services, and provide you with certain functionalities of the Services.
3. Analytical/Performance cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site.
4. Advertising cookies: We use these cookies to help us to display advertisements that will be relevant to you.

We also use both session and persistent cookies on the Service:

• Session cookies: Last only for the duration you browse the Platform and are deleted automatically once you quit your browser.
• Persistent cookies: Are cookies saved on your computer and are not deleted automatically when you quit your browser.

Third-party Cookies

In addition to our own cookies, we may also use various third-party cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on. Examples include Google services such as Google Tag Manager and Google Analytics.

What Are Your Choices Regarding Cookies?

Necessary cookies are enabled by default automatically when you access the Platform. For all other categories of cookies, you can expressly consent to their use by clicking “accept” on the cookie banner displayed on the Platform. Additionally, you can also decide whether or not to accept cookies through your internet browser’s settings.

Where Can You Find More Information About Cookies

To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about cookies, please visit ICO or All About Cookies.

If you have any questions or comments about our Cookies Policy, please contact: support@360ai.io.

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