Professiony Privacy Policy

Professiony (“Professiony,” “we,” “us,” or “our”), is an online Platform that facilitates connections between users and pros for mock interviews, career advice, and other career preparation services.  Professiony has adopted this Privacy Policy (the “Policy”) to explain how we collect, use, safeguard, and share Personal Information from or about our Clients, Pros, and anyone else who may access or use our Platform and/or our Website (“all users”) www.professiony.com (“Website”) (together the Platform and Website constitute the “Services”).

This Policy also addresses how we and others may use Personal Information, under what circumstances we may disclose Personal Information to third parties, and the instances in which we may allow third parties to collect Personal Information from you directly. Depending on your activities when using or accessing our Services, you may, from time to time, be required to agree to additional terms and conditions.

Please note that this Policy applies to anyone who uses or accesses our Services, regardless of whether you use the Services via a computer, mobile device, tablet, or other medium (collectively, your “Equipment”).

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Our Website and Services are hosted in and directed at individuals in the United States. If you are located outside of the United States, you should not access or use our Website or Services.

Please read this Policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your Personal Information, you agree to the collection, use, and sharing of your Personal Information as described in this Privacy Policy. This Policy may change from time to time. Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the Policy periodically for updates. If you do not agree with this Policy, please do not use our Services. We reserve the right to update this Policy at any time. The “Last Modified” date above provides you with notice of when this Policy was most recently updated.

1. INFORMATION WE MAY COLLECT

When you use our Services, we may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”). Personal Information does not include information that is publicly available or de-identified.

You may always choose not to share your Personal Information with us. Please note, however, that if you choose not to share required Personal Information, then you may not be able to use some of our Services. If you have questions about what Personal Information may be required to use our Services, please contact us at support@professiony.com.

a. Clients and All Users

We may collect the following information from or about Clients of our Services and all users:

• Identifiers. Such as your first and last name, email address, account password (encrypted), Internet Protocol address, or other similar identifiers.
• Other Personal Information. Such as information about your education, current employment, employment history, credit or debit card number or other financial information to provide payment for the Services.
• Commercial Information. Such as records of the Services you have accessed, viewed, or purchased from us, including your purchasing history or tendencies.
• Internet or Other Electronic Network Activity Information. Such as your browsing history and information about how you use and your interactions with our Services, emails, or advertisements, the IP address(es) you use to access the Services, the MAC address(es) and other device IDs associated with your access of our Services, the operating system, and other information about the Equipment you use to access the Services.
• Location Information. Such as your imprecise location via your time zone, city and state, or zip code.
• Professional or Employment-Related Information. Such as a resume, education history, and employment history.
• Sensory Information. Such as audio and visual information through recordings via the Services.
• Profile Information. Such as your preferred industries, sub-industries, your Service preferences, and any feedback you provide regarding our Services or the Pro(s) you engage.
• Booking and Session Information. Such as the Service booked, materials accessed, scheduled time (and time zone), date, and duration of your connection with a Pro, which Pro you connected with, whether you rescheduled or missed your session, session recordings related to the sessions you request and complete with the Pro(s) (including transcripts of those recordings and written summaries generated by a third-party artificial intelligence provider from those transcripts), cost of your sessions(s), and payment history.
• Sensitive Personal Information. Such as your account log-in information (password is encrypted), financial account, debit card, or credit card number in combination with any required security or access code to process payment, and the content of your rescheduling messages sent through the Platform between you and your respective Pro.

b. Pros

We may collect the following information from or about Pros that use our Services:

• Identifiers. Such as your first and last name, email address, phone number, account password (encrypted), Internet Protocol address, Social Security number, signature, or other similar identifiers.
• Other Personal Information. Such as information about your education, current employment, employment history, credit or debit card number or other financial information to provide payment for the Services.
• Characteristics of Protected Classifications. Date of birth (used only for background check purposes).
• Commercial Information. Such as records of personal property (only for background check purposes), the Services you have accessed, viewed, or offered through us, including your tendencies and services you intend to and/or have offered.
• Internet or Other Electronic Network Activity Information. Such as your browsing history and information about how you use and your interactions with our Services, emails, or advertisements, the IP address(es) you use to access the Services, the MAC address(es) and other device IDs associated with your access of our Services, the operating system, and other information about the Equipment you use to access the Services.
• Location Information. Such as your imprecise location via your time zone, city and state, or zip code.
• Professional, Employment, and Education Information. Such as your LinkedIn™ profile URL, resume or CV, education history (university, college, degree earned, major, graduation month and year), and employment history, relevant experience related to Services provided through the Platform, current role(s) and past roles, including: industry, sub-industry, group name, title, company name or company description, location, month and year of start date.
• Sensory Information. Such as audio and visual information through recordings via the Services.
• Profile and Dashboard Information. Such as your preferred industries, sub-industries, and preferred mock interviews; calendar and availability Information; voluntary syncing of your Google calendar or Microsoft calendar (through an API); time zone; personal materials related to the services you provide and other content you submit through the Services; your photograph and any information you share about yourself in your Professiony profile, such as your current and past role(s), including: industry, sub-industry, group name, title, company name or company description, location, month and year of start date.
• Booking and Session Information. Such as your hourly rate and the date, time, Client, duration, price, fees, booking links, availability, whether you cancelled, rescheduled, or missed a session, and session recordings related to the sessions you offer and complete with Clients (including transcripts of those recordings and written summaries generated by a third-party artificial intelligence provider from those transcripts).
• Sensitive Personal Information. Such as your account log-in information (password is encrypted), financial account, debit card, or credit card number in combination with any required security or access code to process payment, Social Security number, and the content of your rescheduling messages sent through the Platform between you and the respective Client.

If required under applicable law, we will collect and process Sensitive Personal Information only with your consent.

2. HOW WE COLLECT INFORMATION

We collect Personal Information from or about all users, including Clients and Pros, in the following ways:

• Directly from you. For example, when you complete forms (such as to create an account); complete your profile; book a session; complete a purchase; sign in to an account using your Google credentials; connect your Google Calendar to our Services; share information or documents via the Services with your Pro (e.g., when you upload a resume, or other documents to support your session with a Pro); access, or use our Services; participate in a session conducted or recorded (with your consent if required) through the Services; provide feedback, complete surveys, or request customer service; post comments, photos, videos, or other information to our social media pages or when you review us; or when you otherwise communicate with us via the Services. Note that information posted on publicly available sites, like social media sites, is not subject to this Policy.
• Automatically from your Equipment. When you access or use our Services, information associated with you and/or your Equipment may automatically be collected or received through device-based tracking technologies such as cookies, pixels, tags, beacons, or other technology. We may also automatically collect or receive such information any time you interact with our advertising and content on other websites and platforms. Advertisers and other third parties may also collect information from your interaction with advertising on our websites, applications or other Services.
• From third parties. We may receive information about you from vendors and service providers we hire to help us run our business, including the companies that host or operate our Services, process payments for us, send emails for us, provide marketing, complete background checks of Pros, facilitate account sign in and verification, connect calendars, provides analytics and advertising services, or host our content. We may also receive personal information from your engagement with our advertisements or interactive games or other offerings on third-party sites or social media platforms. We may combine that information with information we collect directly from you. We may also obtain Personal Information about you from advertising networks and search information providers. Additionally, other users of our Services may provide us with your Personal Information so that we may invite you to use our Services.

3. COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

We may automatically receive and store certain types of Personal Information whenever all users, including Clients and Pros, access, interact with, or use our Services. For example, we may use "cookies" and "web beacons" (also called "clear gifs" or "pixel tags"), to obtain certain information when you use or access our Services. We may use information collected via these technologies to:

• Estimate our audience size and usage patterns.
• Store your preferences, so that we may customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Services.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services. For more information, see Interest-Based Advertising.

Cookies are small files that we may transfer to your Equipment's hard drive or to your web browser's memory to enable our systems to recognize your browser and to provide convenience and other features to you. We may also use cookies to provide additional features or functionality to your experience when you use our Services, for example, storing your preferences and other information about you when you use the Website. You may block or limit the storage of cookies via browser controls or other software. You may also delete cookies manually from your device through your internet browser, operating system, or other programs you use to access the Services. Please note that some portions of our Services may not function properly or be available if you block or delete certain cookies.

Web beacons (also known as web bugs, clear GIFs, or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, or to provide other information.

To the extent any of these automated technologies are considered a Personal Information sale, targeted advertising, or profiling, under applicable laws, depending on in which state you are a resident, you may opt out from use of these automated technologies for such uses as described in Your Rights and Choices below. Please note that some Service features may be unavailable as a result.

Additionally, when you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your Equipment. These third parties may include advertisers, ad networks, and ad servers, analytics companies, your Equipment manufacturer, your internet or mobile service providers, etc. These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

4. HOW WE USE & SHARE INFORMATION

Use and Disclosure of Personal Information

We may use or disclose Personal Information for the following purposes:

• To provide you with Services that you have requested, including creating and managing your accounts, processing payments, connecting you with Pros, scheduling, administering, and supporting sessions, and providing you with updates about the status of your service(s).
• With your consent if required, to record sessions conducted through the Services, including transcribing session recordings and summarizing those sessions using a third-party artificial intelligence provider (Note: we do not use such recordings to identify or authenticate you by voiceprint or faceprint).
• To manage our relationship with you, which may include notifying you about changes to our Services, Terms of Service, Privacy Policy, or our services, providing you with notices about your account, asking you to provide feedback or take a survey, or addressing any questions you may have about our services.
• To deliver relevant content, advertisements, and messaging to you and to measure or understand the effectiveness of such content, advertisements, and messaging.
• To provide you with notices about your account.
• To complete a background check on Pros to confirm their identity and credentials.
• To respond to your requests to us, including to exercise any data subject rights you may have, or to fulfill any other purpose for which you provide the information.
• To improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them (our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing with third parties for model training).
• To improve our marketing, customer relationships, and experiences.
• To contact you about our own or third parties' products and services that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• With your consent, consistent with applicable law.
• For any other purpose as may be permitted by law or that we describe when you provide the information.

We may also use or disclose Personal Information in the following circumstances:

• To comply with any court order, law, or legal process, including responding to any legal government or regulatory request.
• To enforce our Terms of Service, this Policy, or other applicable policies or agreements with you.
• To protect the rights, property, or safety of our business, employees, customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
• To investigate suspected violations of any law, rule or regulation, or the terms or policies for our website.

To Whom We Disclose Personal Information

We may disclose Personal Information as follows:

Service Providers and Contractors. We may share Personal Information with vendors who help us with certain services, including customer support, email and text message deployment, videoconferencing, recording and transcription services, research and analytics, marketing and advertising services, data processing, management, background checks, fraud prevention, transaction and payment processing, and survey administration.

For example, we use Daily, Co. to host and transmit the video sessions and, with your consent if required, to provide recording and transcription services. For more information about Daily’s privacy practices, please visit https://www.daily.co/legal/privacy/.

Business Partners, Advertisers, and other Third Parties. With appropriate consent where required, we may share Personal Information with or make it available to our sponsors, partners, advertising networks, advertising servers, social media platforms, and analytics companies or other third parties in connection with our and their marketing, promotional and other commercial purposes and offers, as well as product information.

Further, you have the option to create an account with us using your own email and password or you may sign in and authenticate your identity with Google using your Google credentials. If you choose to access your account using your Google credentials, please note that your information will be shared with Google to provide sign-in and verification services and may be used by Google for their own purposes, including for cross-contextual (behavioral advertising). Subject to your privacy settings within Google, we may receive from Google your name, email address, and profile picture. You are not required to sign in using your Google credentials. If you choose to do so, you are agreeing to Google's applicable Terms of Use and Privacy Policy.

Additionally, as noted, you may voluntarily sync your Google or Microsoft calendars with the Platform to assist with scheduling. If you choose to do so, you agree to Google's and Microsoft's applicable Terms of Use and Privacy Policies.

We may also disclose Personal Information in the following circumstances:

• Law Enforcement, Regulators, Courts, and other Governmental Authorities. We may share any of the categories of Personal Information we collect, pursuant to applicable law, to respond to subpoenas, court orders, legal process, and other law enforcement measures, to comply with other legal obligations, to respond to an emergency, or otherwise to protect our or the rights, property, safety, or security of other parties, visitors to or users of our Services, or the public.
• Business or Asset Transfers. If we are involved in a merger, acquisition, transfer of control, bankruptcy, reorganization, or sale of assets, or diligence associated with such matters, we may share Personal Information with relevant stakeholders. For example, if another entity acquires us or all or substantially all of our assets, or assets relating to any of our businesses, your information may be disclosed to that entity as part of the due diligence process and may be transferred to that entity as one of the transferred assets.

Note that we do not sell or share (as those terms are defined by applicable law) Sensitive Personal Information.

5. INTEREST-BASED ADVERTISING

Some content or applications within our Services, including advertisements, may be served by third parties, including advertisers, ad networks, servers, content partners, or application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. If they collect information, it may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. Such information may be used to provide you with interest-based (behavioral) advertising or other targeted content. Additionally, our partners may use non-cookie technologies on which browser settings that block cookies might have no effect. Your browser may not permit you to block such technologies.

You may block the collection and use of information related to you by advertising companies for the purpose of serving interest-based advertising of certain companies by visiting the following websites of self-regulatory programs of which those companies are members: (1) the Digital Advertising Alliance's website (www.aboutads.info); or (2) the Network Advertising Initiative's website (www.networkadvertising.org/choices). For information on how to block non-essential cookies from your Equipment, please refer to the Cookies and Other Data Collection Technologies section above.

Finally, please note that certain browsers may offer the option of providing notice to websites that you do not wish for your online activities to be tracked for interest-based advertising purposes (Global Privacy Control Notice or universal opt out mechanisms). Should we engage in the sale or sharing (as those terms are defined by applicable law) of Personal Information for targeted advertising, we will respond to and abide by the signals sent through universal opt out mechanisms that are consistent with applicable law.

6. PAYMENT PROCESSING

When you purchase our Services, we will collect Personal information from you to process that payment. While we do not store your payment information, we will provide the Personal Information necessary to process your payment to our third-party payment processor, and that payment processor may store and process that Personal Information.

7. YOUR RIGHTS AND CHOICES

We have created mechanisms to provide you with the following control over your information:

• Marketing Information: If you do not want us to use your email address or other contact information to promote or recommend our own products and Services, or third parties' products or services, you may opt-out by replying to any promotional email we have sent you or following the opt-out links on that message. This opt-out generally will not apply to information provided to us to complete a purchase, Service experience, or other Service-based transaction.
• Accessing, Updating, and Deleting Your Information: You may contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of Personal Information about you in our possession or control, consistent with your rights as described below. If you are a Pro, you may also access, delete, and update some of your Personal Information through your account. We may not accommodate a request to change information if we believe the change may violate any law or legal requirement or negatively affect the information's accuracy.
• Cookies and Automatic Data Collection Technologies. Please see Cookies and Other Data Collection Technologies above for information on how to manage these technologies.
• Interest-Based Advertising. Please see Interest-Based Advertising above for information on how to opt-out of interest-based advertising.
• Location Data. You can choose whether to allow the Services to collect and use real-time information about your Equipment's location through your device settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

Data Subject Access Rights

Depending on in which state you are resident, you may have the following rights related to your Personal Information. These rights include:

• The right to know what Personal Information we process about you.
• The right to request certain Personal Information that we process about you be deleted.
• The right to request we correct Personal Information we have about you which you believe is incorrect.
• The right to have certain Personal Information we process about you returned to you in an accessible and useable format upon your request, if such request is technically feasible.
• The right to opt-out of having your Personal Information processed in such a way that enables us to create a profile of inferences about you or for targeted advertising purposes.
• The right to limit the use of your Sensitive Personal Information.
• The right to opt-out of the sale of your Personal Information.
• The right to opt-out of any profiling in furtherance of decisions that produce legal or similarly significant effects.
• The right to exercise your data subject rights free from discriminatory treatment.

California Residents

If you are a California resident, you may have additional personal rights and choices regarding your personal data. For example, California's "Shine the Light" law (Civil Code Section § 1798.83) permits California resident users of a covered website to request certain information regarding disclosure of personal data to third parties for their direct marketing purposes. If we become a covered entity, we will abide by this law and you may, cost-free, opt-out of sharing of your information with third parties for their direct marketing purposes as described in this Policy.

Nevada Residents

Nevada provides its residents with a limited right to opt out of certain Personal Information sales. Residents who wish to exercise their sale opt-out rights may submit a request as provided in the Contact Us section below. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Exercising Your Data Subject Rights

To exercise any applicable data subject rights, please submit a request using the contact information provided in the Contact Us section below.

How We Verify Data Subject Rights Requests

We may require that your identity be verified prior to processing verifiable rights requests. If your request requires verification, we will verify your identity by comparing the information we have about you against the information we receive when you submit your request. If we do not have enough information to verify your identity, we may request additional information from you, consistent with applicable law. We may deny a rights request if we are unable to verify your identity.

Authorized Agents

Some states permit their residents to designate an authorized agent to submit requests to exercise certain privacy rights on the individual's behalf. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your identity depending on the nature of the request and sensitivity of the information at issue.

If you are an authorized agent submitting a request on behalf of an individual, please submit a request using the contact information provided in the Contact Us section below. You must include a copy of the written, signed permission indicating that you are permitted to act on that person's behalf.

Appealing a Denied Data Subject Rights Request

In some circumstances, we may deny your request to exercise one or more of the rights described above. If you reside in a state that grants appeal rights and if legally required, if you disagree with our decision to deny your request or any portion of your request, you may appeal our decision within sixty (60) days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than sixty (60) days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit a timely appeal, we will respond within forty-five (45) days of our receipt of your appeal.

If you wish to appeal a decision, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal using the information provided in the Contact Us section below. We will review your appeal and either amend or uphold our decision. In either case, we will provide a written explanation of the reason for the decision. This decision will be final.

8. DATA SECURITY

The security of your Personal Information is very important to us. We use appropriate physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse, and unauthorized access, use, alteration, or disclosure. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will be accessed or used in an unauthorized way.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your information against unauthorized use, disclosure, and access.

9. NOTICE OF FINANCIAL INCENTIVES

We do not offer financial incentives or pricing discounts for providing your Personal Information to us or creating an account with us.

10. MINORS' INFORMATION

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect, sell, or share (as those terms are defined by applicable law) the Personal Information of any individual under 18. If you are under 18, do not use our Services or provide any information to us. If you believe we may have any information from or about an individual under 18, please contact us using the information in the Contact Us section below.

11. RETENTION

We keep the categories of Personal Information described in this Policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain Personal Information. At the end of the retention period, Personal Information will be deleted, destroyed, or deidentified.

12. THIRD-PARTY WEBSITES

Our Services may contain links to other third-party websites, including social media sites. This Privacy Policy only applies to our Website and Services. If you click a link on our Website or through our Services that takes you to another website that we do not control, you should review their terms and privacy practices before sharing any information with that site.

13. MODIFICATIONS AND MATERIAL CHANGES

We keep this Policy posted on our Website and Platform. You should review this Policy frequently, as it may change from time to time and without notice. Any changes will be effective immediately upon the posting of the revised Policy and will apply to all personal information collected subsequently to the posting of the revised Policy. When you use our Services, you agree to this Policy as it is posted. If you do not agree with any changes to this Policy, please stop using our Services. We will provide notice of any material changes to the Policy as required by law. All changes will be effective upon posting of the updated Privacy Policy on our Website or Platform. If you object to any change, please stop using the Services.

14. CONTACT US

If you have any questions about this Policy or about our privacy practices, or to exercise any of your data subject rights as described in the Your Rights and Choices section above, please contact us at:

legal@professiony.com