Privacy policy

Oli and its affiliates (defined below) respect privacy, and the security of your Information (“Information”) and business information (“Business Information”) (collectively, “Information”) is important to us. We protect your Information by maintaining physical, organizational and technological safeguards appropriate to the sensitivity of your Information. Except as stated herein, Information may only be accessed by persons within our organization and other authorized third parties who require such access to provide you with the services indicated below.

This Privacy Policy describes how OliveCorp Software Inc. doing business as “Oli”, a company incorporated federal in Canada and located at 2500-1 Dundas St West, Toronto, ON M5G 1Z3, and our affiliates and subsidiaries (as applicable) (“we,” “us,” or “Oli”), processes Information that we collect through the Oli Platform and/or the Oli Services.

1. DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).

2. INFORMATION WE COLLECT

2.1 Information needed to use the Oli Platform.

We collect Information about you when you use the Oli Platform or when you provide it to us through other means (such as when you contact us or create a User Account). Without this Information, we would be unable to provide you with all the services provided by the Oli Platform.

This information includes:

• ‍Identification Information, Account, Profile Information. Such as your first name, last name, articles of incorporation, business registration documents, phone number, home address, email address, date of birth and some of which will depend on the services you use. ‍
• Identity Verification and Background Checks. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, previous addresses, licenses and certifications, and academic and professional qualifications. ‍
• Occupational Information. Such as CV/resume, employment references, cover letter, occupational history, names and contact details of employer(s), immigration status, work authorizations, visas, immunization records and other medical documentation (as required by the Listing or position being hired for), insurance documentation, any background and criminal record checks relevant to your use of the Oli Platform, social insurance number, tax forms related employment (such as TD1 and TD1ON tax forms), and information collected during interviews and/or interactions with others on or through the Oli Platform. ‍
• Payment Information. Such as bank account or payment account information, void cheques, direct deposit forms from your bank, recordings of your communications with us, and your transaction history. ‍
• Other Information. Such as any other information that is necessary for our identified purposes set out below and that is collected hereunder or as permitted by law.

2.2 Information voluntarily provided to us.

You may choose to provide us with additional Information. This information may include:

• ‍Additional Profile Information. Such as marital status, gender, race, ethnic origin, preferred language, military status, disability status or any other field that is not a required field during your Oli account setup or during our information collection process or in the process of creating a User Account (please see Terms of Service for more information). ‍
• Non-personal information. Such as any information that does not directly or indirectly reveal your identity or directly relate to an identified individual, including demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific feature or engaging in a specific activity. ‍
• Other Information. Such as when you fill in a form, create a User Account, create a Listing, submit an Application, add information to your User Account or profile, respond to surveys, participate in promotions, communicate with us and other Users, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Automatically Collected Information

When you use the Oli Platform, Payment Services, and the Oli Services, we automatically collect Information that is sent to us by your web browser. We use this information to better understand how users use the Oli Platform, and to improve the Oli Platform to better meet your needs.

The amount of information sent to us by your web browser depends on the browser and the settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this. This information may include: ‍

• ‍Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. ‍
• Usage Information. Such as the pages or content you view, searches for other User profiles, Listings you have created or interacted with (as applicable), Applications you have submitted or reviewed (as applicable), interviews scheduled, and other actions on the Oli Platform. ‍
• Log Data and Device Information. Such as details about how you’ve used the Oli Platform (including if you clicked on links to third party applications or vendors), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Oli Platform. We may collect this information even if you haven’t created a User Account or logged in. ‍
• Cookies and Similar Technologies. Such as text files with small pieces of data, such as your username and password or as related to marketing and advertising by Oli, that are used to identify your computer or mobile device as you access and use the Oli Platform. The Oli Platform uses “cookies” and other technologies to enhance your online experience, including personalizing the content that you see on the Oli Platform. Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access certain features on the Oli Platform. We never place Information in any cookies. ‍
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address

associated with your use of Payment Services, banking email address, your address and other related transaction details.

2.4 Information Collected From Third Parties.

We collect Information from other sources, such as: ‍

• ‍Third-Party Services. If you use any Third-Party Services (as defined in the Terms) in connection with the Oli Platform, you direct such Third-Party Services to send us information such as your registration and profile information as controlled by that service or as authorized by you. ‍
• Background Information. To the extent permitted by applicable laws and with your consent where required, we may obtain the local version of police, background, or other checks. We may use your information, including your full name and date of birth, to obtain such reports. ‍
• Additional Users. If you are referred to Oli on behalf of another User, the User that referred you may be able to submit Information about you such as your name, age, home address, email address or other contact information.‍
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or other information to help detect fraud and safety issues from Third-Party Services and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Oli Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

2.5 Minor’s Personal Information.

‍The Oli Platform and the Oli Services are not intended for or directed to minors under the age of majority (as applicable based on the laws of your jurisdiction). We do not knowingly collect personal information directly from minors under the age of majority without parental consent. If we become aware that a minor under the age of majority has provided us with personal information, we will delete the information from our records. Please contact Oli if you believe we have collected personal information from an individual under the age of majority.

3. HOW WE USE YOUR INFORMATION

3.1 Provide, Improve, and Develop the Oli Platform.

We use Information to: ‍

• enable you to use the Oli Platform and Oli Services,
• processing the registration of your User Account,
• make and receive payments (as applicable to the User),
• supply you with requested services,
• facilitate placement of Listings and/or submission of Applications,
• approve Oli User Accounts
• perform analytics, debug and conduct research,
• provide Oli Services and respond to your inquiries,
• determine Professional’s qualifications, skills and background for a particular Listing,
• (if applicable) processing payroll, compensation and benefits,
• send you messages, updates, security alerts, and account notifications,
• verify identity and other information submitted by you or any third parties, for fraud detection and prevention,
• personalize and customize your experience based on your interactions with the Oli Platform and use of the Oli Services, your Listing or Application history (as applicable), your profile information and preferences, and other content you submit, and
• to carry out any other purposes that are disclosed to you and to which you consent.

3.2 Maintaining Security and Safety.

We use the information to: ‍

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our employees and members of the public,
• resolve disputes between Users,
• enforce our agreements with third parties,
• comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.5),
• perform quality assurance checks,
• enforce our Terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with us, your profile information and other content you submit to Oli, and information obtained from third parties.

3.3 Advertising and Marketing.

We may use Information to: ‍

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer promotional programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Oli or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

3.4 Provide Payment services.

Information is used to enable or authorize third parties to: ‍

• provide Payment Services,
• detect and prevent money laundering, fraud, abuse, identity theft and security incidents.
• conduct security investigations and risk assessments,
• comply with legal obligations,
• enforce our Terms, Payment Terms, and other payment policies,
• with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preference, and
• improve the Payment Services.

4. SHARING, DISCLOSURE & RETENTION

4.1 Sharing With Third Parties.

We may share your information with third parties, such as when authorizing a third-party application or website to access your Information or participating in promotional activities by Oli partners or third parties.

Where permissible with applicable law, we may use certain information about you, such as your email address, transaction data and credit data, de-identify it (where required by applicable law), and share it with social media platforms, to generate leads, drive traffic to Oli or otherwise promote our products and services, and third-party resellers, to deliver data and products or access personal data and Collective Content.

4.2 Sharing Between Users.

To help facilitate the provision of the Oli Platform and Oli Services or other interactions between Professionals and Companies, we may need to share certain Information such as:

• When an Application is submitted, certain information may be automatically shared with Companies, including the Professional’s full name, home address, phone number, email address, CV/resume, cover letter, employment references, occupational history, immunization records and other medical documentation (as required by the Listing or position being hired for), and other information you choose to share and submit.
• When a Listing is created, additional information is shared to assist with the creation and publication of a Listing, such as the company name, address, links to certain websites or URLs and Listing history.
• When an interview is requested, additional information may be shared to assist with the scheduling of an interview, including your precise or approximate location, your address, and any other information you submit to Oli to assist with scheduling.

4.3 Information You Publish in Profiles and other Public Information.

Certain information will be publicly visible to others, such as your public profile page, which includes your full name or company name, phone number, email address, CV/resume, location, images of your likeness, immunization records and other select medical references, academic and professional qualifications, criminal record check (including vulnerable sector check), and any additional information you share on your public profile.

4.4 Images and Promotional Materials.

We may display certain promotional material and other Collective Content you make with your name, likeness or intellectual property on third-party sites, platforms and apps. Some of this information may be indexed through third-party search engines.

4.5 Third-Party Services.

User personal information uploaded on the Oli Platform (such as names, addresses, occupational history and contact details) may be shared with such third-party service providers as well, at Oli’s sole discretion. These service providers may change over time.

We may share Information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification or occupational documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Oli Services through third-party platforms and software tools (such as data analytics, data security, communications

and customer support), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess potential, threatened or actual legal claims, insurance claims or similar claims. These providers have access to your personal information to perform these tasks.

4.6 Complying with Law.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Oli, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to enforce and administer our agreements with Users, or (v) to protect the rights, property or personal safety of Oli, its employees, its Users, or members of the public. For example, if permitted due to the forgoing circumstances, User tax information may be shared with tax authorities or other governmental agencies.

Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Oli, our Users, or expose Oli to a claim of obstruction of justice.

For jurisdictions where Oli facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose information about transactions and Taxes to the applicable tax authority, such as User names, addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) from Users, and contact information.

Some or all of the Information we collect may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from courts, law enforcement, governmental or public authorities, tax authorities or authorized third parties in those jurisdictions according to laws in those jurisdictions.

4.7 Retention of Information.

We retain Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements (see Section 6.3). We destroy Information when it is no longer needed.

4.8 Business Transfers.

If Oli undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (i.e., due diligence). In this event, we will notify you before your Information is transferred and becomes subject to a different privacy policy.

4.9 Affiliates and Subsidiaries.

Certain personal data may be disclosed among various affiliated and subsidiary companies of Oli for the purposes set out in this Privacy Policy and our Terms.

5. OTHER IMPORTANT INFORMATION

5.1 Automated Data Processing.

Oli may perform automated data processing of your personal information in the context of delivering certain Oli Services (such as Oli’s reporting functionality). Where Oli performs this data processing, Oli does not either on the basis of informed consent or performance of a contract. All such data processing is subject to this Privacy Policy and, if you are entitled by applicable law to do so based on your jurisdiction, you may contact Oli to obtain human intervention and/or contest any decision generated by any of Oli’s automated processing.

5.2 Artificial Intelligence.

In delivering the Oli Platform and Oli Services, Oli may use personal information to develop, train, build and use statistical models, including artificial intelligence, to improve the Oli Platform, the Oli Services and user experiences. Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

5.3 Analyzing your Communications.

We may review, scan, or analyze your communications with Oli for reasons outlined in Article 3 of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools.

5.4 Third-Party Partners & Integrations.

Parts of the Oli Platform may integrate with or link to third-party services, not owned or controlled by Oli, such as Google Maps/Earth, Stripe, Vanta and Amazon Web Services. Use of these services is subject to the privacy policies of those providers. Oli does not own or control these third parties and when you interact with them you are providing your information to them, and thereby agree to the privacy guidelines of such third parties.

6. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law. Please note that we may ask you to verify your identity and request before taking further action on your request.

6.1 Data Access and Corrections.

You can access and update some of your Information by contacting Oli and submitting a request. You are responsible for keeping your Information up to date. You can request a correction to your Information if you believe it is inaccurate. If you have submitted Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below.

6.2 Data Erasure.

In certain jurisdictions, you can request that your Information be deleted, or you may withdraw consent at any time. Please note that if you withdraw consent or request the erasure of your Information:

• We may retain your Information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend you from using Oli Platform for fraud or safety reasons, we may retain information gathered from you to prevent you from using Oli Platform in the future.
• We may retain and use your Information to the extent necessary to comply with our legal obligations. For example, Oli may keep information for tax, legal reporting and auditing obligations.
• Information you have shared with others (such as reviews, comments, and forum postings) may continue to be publicly visible on Oli, even after your Oli Account is cancelled, suspended or voluntarily deleted. Some copies of your Information (such as log records) may remain in our database.
• Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your Information may not be removed from our backup systems for a limited period of time.

7. SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your Information against unauthorized access, loss, destruction, or alteration.

8. CHANGES TO THIS PRIVACY POLICY

Oli reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Oli Platform. Changes to this Privacy Policy shall be effective upon posting, and you understand and agree that if you use the Oli Platform after the date on which the Privacy Policy has changed, Oli will treat your access to or use of the Oli Platform as acceptance of the revised Privacy Policy. If you disagree with the revised Privacy Policy, you may terminate this Agreement in accordance with the Terms of Use. If you do not terminate this Agreement, your continued access to or use of the Oli Platform or Oli Services will constitute acceptance of and be subject to the revised Privacy Policy.

9. CONTACT INFORMATION AND RESPONSIBLE OLI ENTITIES

If you have any questions regarding this Privacy Policy or Oli’s handling of your Information, please contact our Chief Privacy Officer by emailing: oli@ocsoftware.ai.

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