Privacy & Cookie Policy

Last revised: July 3, 2024

Huntly.ai Inc., together with its affiliates, associates, and partners (collectively "Huntly" or "we", "us") is a digital platform that unites tech product companies, IT recruiters, and specialists in the information technology field. With our help IT businesses accelerate their hiring process, recruiters generate income, while software developers make rewarding careers. During its business, Huntly collects some information that could be used to identify you. We call this information "personal data".

We encourage you to carefully read this Privacy & Cookie Policy (hereinafter referred to as "Policy") that explains (1) what personal data we collect; (2) how we use, maintain and otherwise handle your personal data; (3) the conditions under which we may disclose your personal data to others; (4) how we keep your personal data secure; and (5) the rights available to you regarding your personal data. Any use of our website, platform, services and any information or content included therein is subject to this Policy. By accessing or using the website, platform or our services, you agree to the application of this Policy. If you do not agree with this Policy, please do not use our website, platform or services.

We control the collection and processing of personal data relating to individuals who interact with us ("data subjects" or "you"). The data subjects may include (without limitation): candidates for current or future positions at the employer's companies ("candidates"); users who provided their personal data while submitting information regarding the candidates on our platform ("recruiters"); and any other visitors and users of our website available at https://huntly.ai (collectively "users"); as well as individuals and/or organizations seeking information related to hiring or human resources, seeking candidates, or seeking to make available information regarding positions openings, on their behalf or other’s behalf, including but not limited to agencies purchasing for multiple parties and employment agencies (collectively "employers"). 

We do not act as an employment agency, or any other type of agent, by providing this platform. We provide this platform solely as an independent contractor and do not have the authority to act or make employment decisions on behalf of employers or candidates. Nothing in these Policy or on the platform should be construed as creating an agency relationship between us and employers.

ℹ️ Note: if you interact as a recruiter or a candidate with Huntly, please, pay attention to the Section "Special rules when personal data is not collected directly by Huntly".

As we operate in many countries around the world, our privacy practices may vary among the regions to reflect local practices and laws. However, in no case will they be less strict than those provided in this Policy.

Please note that some Huntly activities may be performed in conjunction with other companies (for instance, with employers), in which case respective companies may also receive your personal data which will be used according to their terms of use and privacy policies and, if applicable, other agreements between Huntly and such companies. You may find more details in the Section "Sharing and transferring personal data".

Please pay attention that our website uses cookies. You may find more details in Section "Use of cookies" herein below.

PERSONAL DATA THAT WE COLLECT

The personal data we receive during our business may include the following:

• contact details – such as full name, physical address, e-mail address, postal address, phone number, and user IDs in messengers and telecommunication applications (e.g., Skype);
• demographic information – such as age, gender, country of temporary and/or permanent residence, and immigration status;
• information referring to the professional background – such as education data, professional experience & skills, credentials, references, former or current job title, role, occupation, industry, employers and/or customers, participation in various projects;
• other information – such as interests and preferences, as well as any other personal data provided by the data subject at their own initiative.

Please note that the specific range of personal data we collect varies on a case-by-case basis, and, among other things, depends on how you interact with us and for which purpose.

Moreover, we can collect some amount of information about you (such as your language preferences, operating system, device settings, geolocation, etc.) using the cookies and other similar technologies on this website (please see details in Section "Use of cookies" herein below).

PERSONAL DATA THAT WE DO NOT INTENTIONALLY COLLECT

Of course, you are free to decide which information to share with us. However, we ask you to consider the following warnings:

• Sensitive personal data: we do not deal with any sensitive personal data, meaning data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data concerning sex life or sexual orientation. We do not require such information and ask you to avoid its disclosure. If it happens so that you have disclosed any personal data that you consider sensitive, please inform us (please see details in the Section "Contacts" herein below).
• Personal data of children: we do not knowingly solicit, collect, or process personal data about children. If you are under 18, please do not give us any information about yourself. If we find out that we somehow gained access to the personal data of children, we will delete such data without further delay.

HOW DO WE COLLECT THE PERSONAL DATA

We receive your personal data especially when:

• recruiters share with us the personal data that they received from you (as a candidate) on the basis of your explicit consent to such transfer and further processing;
• you use our website as a recruiter or user and provide your personal data in this respect (e.g. your contact details);
• you visit our website and participate in its interactive features (including and without limitation by using the cookies and other similar technologies as further explained in Section "Use of cookies" herein below);
• you contact us directly by any means (e.g., via e-mail, by post, etc.);
• you provide a testimonial for our companies, business, or services;
• you request us to provide any other information;
• you contact us for any other purpose;
• you communicate with us through the website’s chat.

In addition, we may receive your personal data when you register or update your account on our website. You can easily access, update or delete your personal data stored in such account, including amending or deleting specific information, through your user's electronic cabinet or contacting us (please see details in Section "Contacts" herein below).

In general, you are not obliged to provide your personal data to us. However, most probably we will not manage to fulfill your requests or provide you with the services (in whole or in part) unless you do so. If you ask so, we will advise you whether the provision of your personal data is mandatory in that particular case (and of possible consequences if you do not provide us with it). Please note that we may combine personal data about you collected from different sources.

SPECIAL RULES WHEN PERSONAL DATA IS NOT COLLECTED DIRECTLY BY HUNTLY

We may get your personal data indirectly (for example, when a recruiter submits information about you as a candidate filling out a position opened at the company of one of the employers etc.).

You may be assured that when any portion of your personal data is not collected directly from you, we will always notify you at the point of collecting personal data in such a manner or, at the latest, within a month from the moment of collection of that data. We will process such personal data for the purpose for which it was gathered until you ask that we remove it. However, in such a case Huntly will have the right to keep some personal data to the extent required by the provisions of domestic and/or international law.

Moreover, we always oblige recruiters to share the candidates' data with us only based on the candidates' explicit consent to such transfer and further processing of the said data as described herein. Consequently, the recruiter who has provided us with your data is responsible for having received your consent. However, if you have not agreed to it, please inform us (please see details in the Section "Contacts" herein below).

NOTE: if you are a recruiter, please, make sure to get the candidate's consent before sharing his/her/their personal data with us. The candidate's consent should be explicit, freely given, specific, informed, and unambiguous and cover transferring of the candidate's personal data to us and employers (who should be defined) and the processing of the candidate's personal data by us and these employers according to this Privacy Policy. In case of any requests regarding the compliance of processing the candidates' personal data, you should be able to demonstrate appropriate evidence of the candidates' consent upon request.

HOW WE USE THE PERSONAL DATA

Huntly may use your personal data for the purposes described below.

• To provide, maintain, administer, support, protect, and improve our services, to carry out relevant transactions.
• To facilitate our business activities, such as by:
  • filling out a position opened at the company of one of the employers;
  • keeping a register of candidates for the positions that potentially may be available in the foreseeable future;
  • monitoring recruitment statistics;
  • communicating with you to propose our services;
  • contacting you for future opportunities that may be interesting for you;
  • organizing further cooperation with you in case you are interested in our services.
• To manage our website, namely by doing the following:
  • allowing users to visit and search through our website;
  • enabling users to participate in its interactive features (when they choose to do so);
  • improving the website operation and enhancing the user experience;
  • creating, publishing, and improving content most relevant to users;
  • troubleshooting, investigating, and fixing website-related errors.
• For our own marketing purposes, including and without limitation:
  • evaluation of the effectiveness of ongoing marketing campaigns (for instance, by gathering information on how you interact with our website or respond to our e-mails);
  • customizing, analyzing, and improving the informational content, filling out our website.
• To meet the requirements set forth in domestic and/or international law (for example health and safety, taxation, accounting, reporting, anti-money laundering laws, etc.) to comply with the court orders and other legitimate requests of authorized bodies.
• To protect the rights, property, and safety of Huntly and third parties (e.g., prevent fraud and other prohibited or illegal activities).
• To communicate with you, pursuing without limitation the following purposes:
  • to send you a notice about the information of the processing of your personal data;
  • to provide customer support;
  • to update your details;
  • to seek your views or comments on the services we provide.
• To respond to your requests for exercising your data subject rights under applicable data protection laws (you may find more details in Section "Your rights with respect to personal data" herein below).
• To protect the security or integrity of our website, our business, and our services.

This list is not exhaustive, and we may seek to process your personal data for any other purpose as disclosed to you, to which you specifically agreed, or as required or permitted by the provisions of domestic and/or international law.

LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA

The legal basis upon which we collect, use, store, and otherwise process your personal data will depend on the personal data concerned and the specific purpose for which it is needed.

In general, we rely on one of the following grounds:

• Our legitimate interest in:
  • the effective delivery of information and services to satisfy your demands;
  • growing and improving our business by approaching new specialists for available positions at employers' companies; or
  • the lawful operation and development of our business.

You may be assured that we use your personal data in ways that you would reasonably expect, and our legitimate interest serves as a legal basis for the collection and processing of your personal data only if, and to, the extent it does not interfere with your rights and freedoms.

You have the right to object to these grounds of the processing of your personal data by contacting us (please see details in Section "Contacts" herein below), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing).

• Your explicit consent: in other words when you allow us to process your personal data for a specific purpose.

NOTE: you are free to withdraw your consent at any time by contacting us (please see details in Section "Contacts" herein below), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing). If you withdraw your consent, it will not affect the lawfulness of the prior processing of your personal data based on your consent before you withdrew it.

• To perform our obligations under a contractual arrangement with you, or comply with our legal obligations, including and without limitation:
  • to satisfy any requirement of domestic and/or international law (for example health and safety, taxation, accounting, reporting, anti-money laundering regulations, etc.);
  • to comply with court orders or other legitimate requests of authorized bodies; or
  • to assert and/or defend against legal claims.

Please be assured we will handle your personal data only in line with the purpose for which it was collected. If at any moment we intend to process your personal data for any other purpose, we will not do this without sending you respective notification / your prior explicit consent (subject to the exclusions and limitations which may be provided in the provisions of domestic and/or international law).

If you have any questions or need more information concerning the legal basis on which we collect your personal data, please contact us to clarify further details (please see details in Section "Contacts" herein below).

HOW LONG WE KEEP YOUR PERSONAL DATA

To determine the appropriate retention period for your personal data, we consider (1) the amount, nature, and sensitivity of the personal data in question; (2) the potential risk of harm from unauthorized use or disclosure of your personal data; (3) the purposes for which we process your personal data; (4) whether we can achieve those purposes through any other means; and (5) the applicable legal requirements.

We do not keep your personal data for any longer than is necessary (a) to fulfill the purpose for which we collected it (you may find more details in Section "How we use the personal data" herein above); (b) to comply with domestic and/or international law, or other regulatory obligations (for instance, accounting or reporting requirements) that apply to our business and services we provide; or (c) to assert and/or defend against legal claims.

For example:

• we will keep your personal data, collected based on your consent, for the term you explicitly agreed with;
• we will keep your personal data obtained in connection with your subscription to our e-mails until you unsubscribe;
• we will keep your personal data obtained in connection with your inquiry, request and/or complaint – until the matter of such inquiry, request and/or complaint is resolved.
• we will keep your personal data obtained in connection with your registration on our website, until you delete it through your user's electronic cabinet, or ask us to delete your account, or we delete your account for reasons described in the Terms Of Use, or 2 years of inactivity have elapsed, whichever comes first.

Normally, the retention period will not exceed 2 years. However, if it happens so that we are legally required to hold some types of personal data to fulfill our statutory obligations (for instance, taxation, accounting, or reporting purposes) – then we will hold your personal data in our systems for as long as necessary for the relevant activity. Moreover, in some cases, we may anonymize your personal data (in such a manner that you are not or no longer identifiable) for research or statistical purposes, in the event which we may use this information indefinitely without further notice to you.

We review our personal data retention periods on a regular basis. If you have any questions about how long we keep your personal data, you may contact us (please see details in Section "Contacts" herein below) to clarify all the questions you have.

YOUR RIGHTS WITH RESPECT TO PERSONAL DATA

As a data subject, you have certain rights under domestic and/or international law in relation to the personal data we hold about you. Where the processing of your personal data is subject to the European Union data protection legislation, including the General Data Protection Regulation (for instance, when you are physically located in one of the European Union/ European Economic Area countries) or to the United States data protection legislation, including privacy regulations of particular states (for instance, when you are physically located in the United States), at a minimum you have the set of data subject rights provided below.

Right of access

If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (along with other details). There are some limitations and exceptions concerning this right: for example, where information is legally privileged, or if providing you with the information would reveal any personal data of another person.

Right to data portability

In certain circumstances, you have the right to receive your personal data provided by you to us and reuse it elsewhere, or send such data to another organization (or ask us to do so if technically feasible); this is regarding where (1) our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you, and (2) the processing is carried out by automated means.

Right to rectification

You may require us to update or correct any inaccurate personal data or complete any incomplete personal data concerning you. If you do, we will take reasonable steps to check the accuracy and correct your personal data. Please let us know if any of your personal data changes so that we can keep it accurate and up to date. If you are entitled to rectification and if we have shared your personal data with others, we will let them know about the rectification where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly. Also note that Huntly is not required to notify third parties to whom your personal data has been disclosed of any rectification when such notification involves an unreasonable burden or disproportionate effort. A large portion of recruiter’s personal data can be updated through your user’s electronic cabinet.

Withdrawal of consent (right to opt out)

If we rely on your explicit consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time by contacting us (please see details in Section "Contacts" herein below). Your withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.

If it happens so that we process your personal data on a legal basis other than your explicit consent, you have the right to opt out (unless we have a separate legitimate ground for further processing) of data processing by contacting us (please see details in Section "Contacts" herein below). It will not affect the lawfulness of processing before you decided to opt out.

Right to object

You can ask us to stop processing your personal data and we will abide so if we are:

• relying on our legitimate interest to process your personal data, except if we can demonstrate other compelling legal grounds for the processing; or
• processing your personal data for direct marketing purposes.

Right to erasure

You can ask us to delete your personal data in some circumstances, for instance, if you withdraw your consent or decide to opt out of data processing (where applicable). For situations where, in accordance with the provisions of domestic and/or international law, we fulfill your request and Huntly will delete your personal data without undue delay. If you are entitled to erasure and if we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you whom we have shared your personal data with, so that you can contact them directly. Also, note that Huntly is not required to notify third parties to whom your personal data has been disclosed of any deletion when such notification involves a disproportionate effort or unreasonable burden.

Right to restriction of processing

You can ask us to ‘block' or suppress the processing of your personal data in certain circumstances (such as where you contest the accuracy of that data or you object to us), so that we no longer process that personal data until that restriction is lifted. If you are entitled to restriction and if we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you whom we have shared your personal data with, so that you can contact them directly.

Rights in relation to automated individual decision-making, including profiling

You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, unless these are necessary for entering into, or the performance of, a contract between you and us, or unless we do so based on your explicit consent (still such consent can be withdrawn as described in Subsection "Withdrawal of consent" herein above).

Right to file a complaint 

If you have a concern with respect to the way we process your personal data, you can report it to the relevant supervisory authority (please see details in Section “Complaints” herein below).

Please note that these rights are not absolute and in certain cases are subject to conditions as specified in the provisions of domestic and/or international law. For instance, it may happen if we have an overriding interest or legal obligation to continue to process your personal data.

You can exercise the above rights, where applicable, by contacting us directly (please see details in Section "Contacts" herein below). We will respond to your request within the statutory period and typically seek to resolve the matter within one month. We will require you to provide satisfactory proof of your identity in order to ensure that your personal data is disclosed only to you.

While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests, or to impose restrictions or requirements upon such requests if required or permitted by provisions of domestic and/or international law but will explain "why" if we do so.

SHARING AND TRANSFERRING PERSONAL DATA

If you are physically located in one of the European Union/ European Economic Area countries, please note that your personal data may be transferred and processed in states which are not recognized as providing the appropriate level of data protection in the meaning of the General Data Protection Regulation, including, without limitation, in the US. You may be sure that at any given moment such processing will be subject to appropriate safeguards that are prescribed by the applicable legislation, in particular those specified in Article 46 of the General Data Protection Regulation (such as the application of the standard contractual clauses available on the European Commission website).

Huntly may exchange your personal data with its affiliates, associates and partners. Moreover, we may share your personal data with (where and to the extent necessary in connection with the purposes described in this Policy):

• employers (together with their affiliates, associates and partners);
• independent contractors, consultants and agents of Huntly and/or our affiliates, associates and partners; and
• any other third parties for the purposes described in this Policy.

Anyway, you may be assured that we do not share personal data with third parties, except as (a) necessary for our legitimate professional and business needs; (b) necessary to carry out your requests; (c) necessary to provide our services to you; (d) pursuant to your explicit consent; (e) required or permitted by law; and/or (f) as otherwise described in this Policy. Huntly will only transfer personal data to such persons when they meet our strict standards on the processing of personal data and security and pass those same standards down to their sub-processors.

Where we believe that processing or other business activities on our behalf or in our interest are better performed by third parties ("third-party service providers"), we may outsource respective operations to them and, consequently, transfer your personal data to those persons, such as our IT systems providers, website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers. We only share personal data that they reasonably need to provide their services and will not transfer your personal data to any third parties for their own direct marketing purposes. We ensure that third-party service providers are authorized to use your personal data only as necessary to provide services on our behalf or in our interest.

Please note that the storage of your personal data on servers and/or on software made available or hosted by third-party service providers shall not be considered a disclosure of your personal data to third parties as far as third-party service providers do not have direct access to it. In all events, we shall ensure by contract that our third-party service providers protect your personal data that is shared with them.

In an ongoing effort to better understand users of our website, we may analyze anonymous and aggregate information in order to operate, maintain, manage, and improve our website and/or the services that we render. This aggregate information does not identify you personally. We may share this aggregate data with our clients, third-party service providers and other persons. We may also disclose aggregated user statistics in order to describe the services of Huntly (or pursuing other lawful purposes) to current and prospective business partners, clients and other persons.

You may at any time decide to opt out of sharing and transferring (unless we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law) of your personal data by contacting us (please see details in Section "Contacts" herein below). It will not affect the lawfulness of data sharing and transferring before you decided to opt out.

In certain situations, we may be required to disclose your personal data where we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law. For instance, we may disclose your personal data to assert and/or defend against legal claims.

In the event of a sale, merger, receivership or transfer of all assets of Huntly, we reserve the right to assign or share your personal data with such third parties and their advisors. Please be assured that you will be sent notice of such an event should it occur with the ability to opt out of such a transfer unless Huntly and/or such third parties have a separate legitimate ground for such transfer and further processing of your personal data.

PERSONAL DATA SECURITY

Huntly has security measures in place to protect the information we process (including your personal data), which involve preventing, detecting, investigating, and resolving security threats, both during transmission and once we receive it.

We do our best to protect your personal data, whether in electronic or tangible form (e.g., hard copy), by sticking to appropriate internal policies and using state-of-the-art technical and organizational measures that follow the requirements present within the European Union/ European Economic Area and the United States for the safe and lawful processing of personal data.

Moreover, we restrict access to your personal data to authorized individuals among internal personnel, agents, or contractors of Huntly who need to access your personal data to perform specific tasks. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who are required to keep the information confidential.

Although we use industry-standard precautions to safeguard your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but 100% complete security does not presently exist anywhere online or offline. For this reason, you should take care in deciding what information you send to us, especially when you do so at your own initiative.

If you have any questions about security, you may direct them to us (please see details in Section "Contacts" herein below).

USE OF COOKIES

This Section explains how and why cookies and any other tracking technologies may be stored on and accessed from your device when you visit or use our website.

Please read this Section carefully before using our website.

What are "cookies"? Cookies (or similar technologies) are tiny text files containing small amounts of data about you and your interaction with our website. Cookies work by assigning users with unique reference codes (identifiers) that are placed on their devices when they access the website. Later (if they last longer than a web session) they are sent back to the originating website on each subsequent visit, or to another website that recognizes them.

Please note that our website may also contain other tracking technologies such as "pixels" (or "web beacons"). These are typically small transparent images that provide us with website statistics. They are often used in conjunction with cookies, though they are not stored on your device in the same way. As a result, if you disable cookies, pixels may still load, but their functionality will be restricted. For simplicity, all such technologies are further collectively referred to as "cookies".

Some cookies are critical for the proper functioning of our website ("Necessary Cookies"), whereas others help us personalize and improve your experience while using the website (such as "Preference Cookies", "Statistic Cookies", and "Marketing Cookies"). A list of cookies employed by us and third parties through our website is described in the Subsection "What cookies are used on this website" herein below.

Cookies can remain on your device for different periods of time. Some of them are "Session Cookies" – they are only stored on the device during your browser session. In other words, they are automatically erased when you close your browser. Other ones like "Persistent Cookies" will remain on your device even after your browser session has ended until you manually erase them, or as they expire. They are used, for example, to remember you when you return to the website.

Our website uses both 'first' and 'third' party cookies depending on the domain placing/providing them. First-Party Cookies are those set directly by this website, whereas Third-Party Cookies are placed or provided by other domains (please see the list of such third parties herein in Subsection "Third parties"). Please note that we have no (or limited) control over Third-Party Cookies.

If you are accessing our website from the United States or other non- European Union/ European Economic Area countries, you have the right to restrict us from of storing and accessing any cookies, pixels and other tracking technologies which do not refer to Necessary Cookies by contacting us (please see details in Section "Contacts" herein below).

If you are accessing our website from the European Union/ European Economic Area, you will see a cookie banner on your first visit.

By clicking 'Accept' on the cookie banner, you give us your consent to store and access cookies as described in this Section.

By clicking 'Reject' on the cookie banner, you do not allow us to store and access any cookies, pixels and other tracking technologies which do not refer to Necessary Cookies. However, it may disrupt the normal functioning of our website (and have an adverse impact on your user experience).

Data collected. Our website uses cookies to record web-session information including:

• the date and duration of your visit to the website;
• the webpages which you viewed during your visit;
• your IP address;
• your preferences (such as the language selected to view the website);
• the type and version of browser which you used; and
• your device's operating system and other settings.

We use the information that we gather in order to evaluate the website's usage, content, navigability, and composition. This statistical analysis allows us to improve our website, make your user experience more enjoyable, and provide value-added services.

How we use cookies. We use cookies for a number of reasons, like ensuring the proper functioning of our website, improving your user experience, trend analysis, and measuring the effectiveness of this website. The purposes for which we use each category of cookies are described in more detail in the Subsection "What cookies are used on this website" herein below.

What we don't do with cookies. We never share or sell any information about you (including your personal data) except as and to the extent expressly stated in our policies and/or communications with you. Please also be assured that cookies cannot be used to run programs or deliver viruses to your devices.

Consent for cookies. In most cases, we will need your consent in order to use cookies on this website. The exception refers to Necessary Cookies that are needed to carry out the transmission of a communication over a network, or essential to the inherent functionality of the website – such cookies are used automatically, by default, once you access our website.

Third parties. As mentioned above, if you visit a website and another entity sets a cookie through that website, this would be a Third-Party Cookie. Some of the cookies we place on our website could be provided by trusted third parties. As a result, such other entities may obtain and process some data about you as set out in their policies – you may find more details in this regard in the table below.

Third-Party	Useful Links	Details
GOOGLE	GOOGLE PRIVACY POLICY DATA TRANSFER FRAMEWORKS	PURPOSE. WE HAVE INTEGRATED GOOGLE ANALYTICS, A WEBSITE ANALYSIS TOOL PROVIDED BY GOOGLE LLC AND ITS AFFILIATES INTO OUR WEBSITE, TO COLLECT AND ANALYZE USER ACTIVITY DATA. DATA PROCESSED. GOOGLE ANALYTICS USES COOKIES, WHICH COLLECT INFORMATION TO EVALUATE YOUR USE OF THE WEBSITE AND PROVIDE ONLINE REPORTS AND OTHER RELEVANT SERVICES; THIS ENABLES US TO UNDERSTAND HOW YOU INTERACT WITH THE WEBSITE, FOR EXAMPLE, INFORMATION ABOUT THE WEBSITE YOU CAME FROM, THE WEBPAGES YOU HAVE VISITED, OR HOW OFTEN AND FOR HOW LONG A PARTICULAR WEBPAGE WAS VIEWED. THIS INFORMATION MAY INCLUDE USAGE DATA SUCH AS: (1) USER ID (CONSISTING OF A STRING OF NUMBERS UNIQUE TO EACH USER ON OUR WEBSITE); (2) NUMBER OF TIMES AND TIME OF DAY OF PREVIOUS VISITS TO OUR WEBSITE; (3) INFORMATION ABOUT HOW THE USERS FOUND OUR WEBSITE, THEIR SEARCH, AND BROWSER HISTORY; IP ADDRESSES. WHERE THE DATA IS PROCESSED. THE INFORMATION COLLECTED MAY BE TRANSMITTED AND STORED IN DATA CENTERS LOCATED ALL OVER THE WORLD (LISTED ON THE FOLLOWING WEBPAGE), IN PARTICULAR IN THE UNITED STATES, BY GOOGLE LLC, ITS AFFILIATES, AND/OR THIRD-PARTY SERVICE PROVIDERS ACTING ON THEIR BEHALF. HOW TO OPT OUT. YOU MAY OPT-OUT OF GOOGLE ANALYTICS FEATURES BY FOLLOWING THE LINK. MOREOVER, THE COOKIES PLACED AND PROCESSED AS A RESULT OF THE INTEGRATION OF THIS AND OTHER SERVICES PROVIDED BY THE SAME SUPPLIER COULD BE DISABLED THROUGH YOUR DEVICE SETTINGS (AS DESCRIBED IN SECTION "DISABLING COOKIES").
Meta (Facebook)	Meta Data Policy Meta FAQs on GDPR Facebook business tools terms Facebook Data Processing Terms	Purpose. We've integrated Facebook Pixel, a tool provided by Meta Platforms, Inc., to help us track conversions from Facebook ads, optimize ads based on collected data, create target audiences for future ads, and remarket for prospective customers. Data processed. The information includes contact data and information about the actions of users on the website, which is described in more detail in Section 1(a) of Facebook business tools terms. Where the data is processed. The information collected may be transmitted and stored in data centers located all over the world (listed at the following webpage), in particular in the United States, Europe, and Singapore, by Meta Platforms, Inc. and/or third-party service providers acting on its behalf (you may see the list of Facebook ads data sub-processors via the following link). How to opt out. You may delete and prevent usage of Facebook Pixel through your device settings (as described in the Section "Disabling cookies").
LinkedIn	Privacy Policy LinkedIn Cookie Table LinkedIn Insight Tag: FAQ LinkedIn Ads Agreement European Union, European Economic Area, and Swiss Data Transfers	Purpose. We have integrated LinkedIn conversion tracking (LinkedIn Insight Tag) which is an analytics and behavioral targeting service provided by LinkedIn Ireland Unlimited Company or LinkedIn Corporation (depending on the location where you access our website from) that connects data from the LinkedIn advertising network with actions performed on this website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn Ads and enables targeting groups of users on the basis of their past use of our website (you may find more information about the LinkedIn Insight Tag via the link).Moreover, the website may employ LinkedIn Ads – an advertising service provided by LinkedIn Ireland Unlimited Company or by LinkedIn Corporation (depending on the location this website is accessed from). It offers access to LinkedIn social networks through various sponsored posts and other methods.Data processed. The information includes device information, as well as tracker and usage data, which is described in more detail in LinkedIn Cookie Table. Where the data is processed. The information collected is transmitted and stored in data centers located in the United States, by LinkedIn Ireland Unlimited Company or LinkedIn Corporation (depending on the location this website is accessed from) and/or third-party service providers acting on their behalf (please see the list of LinkedIn sub-processors on the following webpage). How to opt out. You may opt-out of behavioral targeting features through your LinkedIn account settings. Moreover, you may disable LinkedIn cookies by managing your device settings (as described in the Section "Disabling cookies").
Hotjar	Privacy Policy Cookies Set by the Hotjar Tracking Code	Purpose. We use Hotjar services (via the official Google Tag Manager integration) rendered by Hotjar Ltd. in order to better understand the behavior of our website users, in particular: (1) to determine if the user has visited the website before, or if it is a new user of the website; (2) to count how many times a website has been visited by the visitor; (3) to define average time spent by the user on our website; (4) to identify what pages have been read by the user.Data processed. The information may include the following: (1) the time the user visits our website; (2) the quantity of visits of our website; (3) URL & title of webpages viewed by the user; (4) user ID unique to our website, etc. Where the data is processed. The information collected may be transmitted and stored in data centers located all over the world, including in countries outside the Europe, by Hotjar Ltd. and/or by third party service providers acting on its behalf (you may find more information in this regard on Data Storage page). How to opt out. You may opt out of processing of your data by Hotjar Ltd. following the link. Moreover, the cookies placed and processed as a result of integration of this and other services provided by the same supplier could be disabled through your device settings (as described in Section "Disabling cookies").
Usermaven	Usermaven Privacy Policy Usermaven Terms of Sevice	Purpose.  We have integrated Usermaven, a user behavioral analytics tool provided by Usermaven Inc., to collect and analyze data about how the users are interacting with our website, including but not limited to: 1) what webpages the users visit, 2) what the users click on, 3) where the users are located, 4) what browser or platform the users are using, and 5) other forms of behavioral or personal data, described in more detail in Usermaven Privacy Policy. Data processed. The information includes analytics data consisting of device type, operating system used, unique device identifiers, device settings or preferences, geo-location data, and other data which is described in more detail in Usermaven Privacy Policy. Where the data is processed.  The Personal Data collected is primarily stored and processed within the EU, and more specifically in Germany wherever it is possible to restrict the processing the Personal Data. How to opt out. You may delete and prevent usage of Usermaven through your device settings (as described in the Section “Disabling cookies”).
Mixpanel	Mixpanel Privacy Program Mixpanel TRACKING METHODS: SDKS: JAVASCRIPT	Purpose.  We have integrated Mixpanel, an analytics tool provided by Mixpanel, Inc., to collect and analyze data about how the users are interacting with our website, including but not limited to: 1) what webpages the users visit, 2) what the users click on, 3) where the users are located, 4) what browser or platform the users are using, and 5) other forms of behavioral or personal data, described in more detail in Mixpanel Privacy Program. Data processed. The information includes analytics data consisting of user's actions, session time, geo-location data and time zone, search engine, browser (and its version), operating system, device ID, screen height & width, URL protocol, distinct ID. Where the data is processed.  The personal data collected may be stored and processed in your country or region, or in any other country where Mixpanel, Inc. or its affiliates, subsidiaries, or service providers maintain facilities. Mixpanel, Inc. primarily uses data centers in the United States and European Union (you may find more information in this regard in Mixpanel Privacy Program). How to opt out. You may delete and prevent usage of Mixpanel through your device settings (as described in the Section “Disabling cookies”).
Calendly	Calendly Privacy Notice Calendly cookie management and banner	Purpose. We have integrated Calendly, a tool provided by Calendly, LLC to help us schedule calls with our customers. Data processed. The information includes your name, e-mail, and any additional information that you provide us with. Where the data is processed.  If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing Personal Data collection, use, and disclosure that differ from United States laws, please be aware that information collected will be processed and stored in the United States or in other countries where Calendly or its third-party Service Providers have operations. How to opt out. You may delete and prevent usage of Calendly through your device settings (as described in the Section "Disabling cookies").
Tawk.to	Tawk.to Privacy Policy Tawk.to Cookie Policy	Purpose.  We have integrated tawk.to widget, a tool provided by tawk.to, inc. to help us communicate more effectively with the users. Data processed. The information includes your name, e-mail, device type, device ID, device settings or preferences, geo-location data, IP, session time. Where the data is processed. Personal information may be processed in any country where a tawk.to, inc. employee or contractor accesses the tawk.to system. tawk.to, inc. complies with the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework, and the UK Extension to the EU-U.S. Data Privacy Framework, as set forth by the appropriate authorities regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States. tawk.to, inc. has affirmed its commitment to adhere to the principles and safeguards of these frameworks (you may find more information in this regard in Tawk.to Privacy Policy). How to opt out. You may delete and prevent usage of Tawk.to through your device settings (as described in the Section "Disabling cookies").
Pendo	Pendo Privacy Policy Pendo Cookie policy	Purpose. We have integrated Pendo, a tool provided by Pendo.io, Inc., to help us improve the user onboarding process. Data processed. The information includes what webpages the users visit, what the users click on, the number of times and time of day of previous visits to our website, what browser or platform the users are using, and other forms of behavioral or personal data, described in more detail in the Pendo Privacy Policy. Where the data is processed.  Pendo.io, Inc. are a U.S.-based company and many of its service providers, advisers, partners or other recipients of data are also based in the U.S. or outside of Europe. This means that, if you use the Pendo’s services, your personal information will necessarily be accessed and processed in the U.S. and in other countries outside Europe (you may find more information in this regard as well as information about Pendo’s appropriate safeguards in Pendo Privacy Policy). How to opt out. You may delete and prevent usage of Pendo through your device settings (as described in the Section "Disabling cookies").

What cookies are used on this website. You can find the details of cookies used on this website below:

1. Necessary Cookies These cookies are essential to allow you to browse around the website and use its features – they enable basic functionality of the website like network management, webpage navigation and access to secure areas of the website. Necessary cookies cannot be turned off in our systems. However, you may disable these by changing your browser settings (as described in Subsection "Disabling cookies" herein below), but this may have an adverse impact on how the website functions.
2. Preference Cookies We use preference cookies in order to remember choices you make when you use the website, like your preferred language. This information changes the way the website behaves or looks and helps to make the visits more tailored and pleasant.
3. Statistic Cookies Statistic cookies collect anonymous information on how people use our website. We integrate these cookies to obtain statistical information that tells us how long users spend on the website, how they use its webpages, which ones are most viewed, and whether any errors occur. In the end, it helps to improve the user experience while browsing our website. The data stored by these cookies is usually anonymized, i.e. doesn't show personal details from which your individual identity can be established.
4. Marketing Cookies Marketing cookies are used to track users' behavior across the website. These cookies collect information about your browsing habits in order to make our or third-party websites more relevant to your particular interests.

Disabling cookies. Most internet browsers are initially set up to automatically accept cookies. You can manage cookies by adjusting the appropriate settings on your browser, although some of our website features may not function as a result.

You can follow the links provided below to manage the cookie settings on your device depending on the browser you use:

• if you use Google Chrome, see the details via the following webpage;
• if you use Mozilla Firefox, see the details via the following webpage;
• if you use Internet Explorer, see the details via the following webpage;
• if you use Opera, see the details via the following webpage;
• if you use Microsoft Edge, see the details via the following webpage;
• if you use Safari (on iPhone, iPad or iPod touch), see the details via the following webpage;
• if you use Safari (on MacBook), see the details via the following webpage;
• if you use Samsung Internet (on your phone), see the details via the following webpage.

Moreover, you can find useful information about managing cookie preferences on the All About Cookies website – it is a free resource which explains:

• what cookies are and how they are used (available at the link);
• how to delete cookies from your browser (available at the link).

LINKS TO OTHER WEBSITES

Our website (including this Policy) may contain links to other websites, and you should review the privacy policies on those sites. We take no responsibility for the policies and practices of those websites.

CHANGES TO THIS POLICY

We may from time to time modify this Policy, upon which we will also update the ‘Last revised' date stated herein above. You are still advised to visit this page regularly for the latest information on our privacy practices.

COMPLAINTS

If you consider that your personal data is processed in contradiction with applicable legal regulations, you have the right to file a complaint directly with the respective personal data protection authority. If you are physically located in one of the European Union/ European Economic Area countries, you can access the contacts of the European Union national data protection authorities at the website of the European Data Protection Board. If you are physically located in the United States, you can either contact the Federal Trade Commission or the General Attorney of your state (or California Privacy Protection Agency if you are within California).

CONTACTS

If you (a) have any questions or complaints regarding this Policy or the way your personal data is processed; (b) would like to report any suspicious activity, including automated messages or calls from parties you cannot identify; or (c) would like to exercise a legal right in relation to your personal data, please contact us by one of the following means:

• Email: contact@huntly.ai
• Postal address: 919 North Market Street, Suite 950, Wilmington, DE 19801, USA