Privacy Statement

Introduction

e2f, inc. and its affiliates respect your privacy and are committed to protecting it. We provide this Privacy Statement to inform you of our policy and practices and of the choices you can make about the way your information is collected and used. This Privacy Statement applies to the sites accessible from e2f.com and any other affiliated e2f websites that link to or refer to this Privacy Statement ("Site," collectively, "Sites") and data we receive from you via the Site in our capacity as a data controller. We ensure that any personal data received will be processed in accordance with the applicable privacy and data protection laws including the California Consumer Privacy Act (CCPA), Data Protection Act 2018, Regulation 2016/679 of the European Parliament the General Data Protection Regulation (GDPR), the Philippines Data Privacy Act, the Australian Privacy Act and any other laws that apply to our collection and handling of personal data (collectively, "applicable data protection laws"). Links to third-party websites provided within the Sites are not covered by this Privacy Statement. This Privacy Statement explains how we may collect, use and share information that we obtain about you directly or indirectly in accordance with applicable data privacy laws. If You provide personal data to us or use our online services, you are deemed to have accepted the terms of this Privacy Statement.

Scope of Privacy Statement

This Privacy Statement sets forth when collection of Your personal data triggers our obligations as well as explains various ways in which your personal data may be collected and managed in compliance with application data protection laws.

When this Privacy Statement Applies

This Privacy Statement applies to the following: 1) your use of any of our services; 2) when you apply to us for a job or work placement; 3) when you provide services to us that includes any personal data; 4) as a result of your relationship with one or more of our clients; and/or 5) when we collect personal information from third parties.

This Privacy Statement also applies to the Sites and any online services provided through those Sites on which this Privacy Statement appears ("online services") and through which we may collect personal information. Please note that our online services make use of cookies and similar technologies as described below.

Our Use of Cookies

A cookie is a small piece of text-based information that is generated by our web server and is stored within the memory of your computer to be later retrieved by your web browser and automatically used to communicate with the web server that issued it. We use cookies to enhance your interaction with our Sites and do not use cookies to record any personal information. Cookies only store information about a current or prior web session. Any statistical data aggregated and used by our web monitoring service provider is intended to improve our services. At no time do we personally identify you as the source of that data. You may refuse to accept our cookies by activating the appropriate setting on your web browser. However, refusing cookies may limit access and/or quality of the interaction with certain parts of our Sites. Absent the refuse cookies setting, our systems will automatically issue you cookies when you visit our Sites and you are deemed to have consented to our use of this cookie. Sessions using cookies are deleted and destroyed at the end of the session. Any other cookie-based information may be stored and recovered by your web browser.

How We Collect Your Personal Data

"Personal data" is any information that can be used to identify you or that we can link to you. When you use our services, we collect personal data directly from you. We may also collect personal data from third parties such as your employer, regulatory authorities, recruitment agencies, credit reporting agencies and publicly available records. Additional Personal Data may be collected when you communicate with us via email or other channels, sign up for newsletters, alerts, webinars, other event or when you respond to requests for information. The information you provide may include current and historical personal data, including but not limited to, your name, contact details, title, identification, employment, positions held and information about organizations with which you are affiliated. We may collect information from other sources such as social media platforms that provide feedback to us about how you interact with our social media content. We handle any unsolicited information in a legally compliant manner including destroying or de-identifying such information when required to do so. When you use our online services, we may collect the following information from the forms you complete:

• Your credit or debit card number, expiry date and security code.
• Your name, username, addresses and email addresses.
• Your delivery address (if different to above).
• Your contact telephone number in case we need to call you.
• Your age, date of birth, gender, education, race, nationality, preferred currency for payment and preferred payment method.
• City, state and country of birth. Country where you have lived the most.
• Whether you have pets.
• Information you provide regarding languages spoken including natural language, when you learned to speak English, languages spoken at home and previous translation experience.
• Information you provide regarding the number of family members aged between 18 and 100 that could participate in data collection tasks.
• Information as to whether you are willing to be exposed to sensitive content in the course of performing services.
• If you have been blocked as a user, notations as to why.
• Information you provide by your participation in competitions, live chats or message boards.
• Information you provide to us if you contact us, for example to report a problem with our online services or raise a query or comment.
• Details of visits made to our online services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.
• Where our online services require that you enter a password or other information in order to access certain features, we will collect such credentials when you enter them.
• Biometric data means personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images, iris patterns or dactyloscopy/fingerprint data.

If you apply for a job or seek placement services with us then you likely will provide information about your education, employment, racial background and state of health. You will be asked to provide your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We also may do screening checks (including reference, background, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions. We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers and your current and previous employers. We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us. Where relevant we will highlight to you those details that we are obligated to collect.

Legal Basis for Usage of Personal Data

Where we intend to use your personal data, we rely on the following legal grounds:

Use of Information

• We use your information in order to improve our services including the use of information to process orders, select vendors, deal with any enquiry and/or to send you information about our products and offers from time to time.
• To use your credit card or other payment details which are taken through a secure process for processing by your payment provider, our payment processor and our bank.
• To respond to your enquiries.
• To carry out our obligations arising from any contracts entered into between you and us.
• To facilitate our internal business operations including to fulfil our legal or regulatory requirements.
• To maintain and develop our relationship with you.
• For our business purposes including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
• To maintain and update our records including our database of contacts.
• To evaluate, recruit and hire personnel.
• To measure the popularity and effectiveness of services such as newsletters and seminar invitations in order to improve what we offer to you and other recipients.
• To ensure that content from our online services is presented in the most effective and secure manner for you and the device on which you are accessing our services, and to troubleshoot and improve such online services.
• To allow you to use or access interactive features or secure areas of our online services when you choose to do so.
• For research, planning, service development, security or risk management.
• As we believe reasonably necessary or appropriate to: comply with our legal obligations, respond to legal process or requests for information issued by government authorities or other third parties or protector yours, ours, or others' rights.
• Without including sensitive personal information, for aggregate reports to customers regarding vendor attributes distribution.

Subject to the above, the information collected about you will not be used for any other purposes and will not be sold or otherwise disclosed to any other organizations, unless required by law. If we transfer ownership or management of a Site to a third party we may also transfer your data to such third party provided such third party agrees to observe this Privacy Statement.

Disclosure of Your Information

We may, in providing our services and operating our business, allow access to your personal data to the different entities within our group for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organization with services, provided in all instances that such processing is consistent with this Privacy Statement and applicable law. We may exchange your personal data with third-party service providers contracted to us where any of the following apply:

• You have consented to us sharing your personal data in this way.
• We deem reasonably necessary to provide you with the services that you have required at any particular time.
• Such sharing is provided for under contract, including our terms and conditions for any particular service that we may provide to you.
• Such sharing is to law enforcement bodies or other government authority.
• We need to enforce or apply our terms and conditions to which you have agreed (or other terms that have been agreed to apply to our relationship with you or your employing organization).
• It is necessary to protect the rights and interests, property, or our safety or the safety of our clients or others.
• It is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (such as jointly sponsored events, external venues, or caterers).
• Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
• We use third party service providers to provide services that involve data processing including legal, accounting, financial and business consulting, mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services.
• If our assets are merged with or acquired by a third party, or we expand or re-organize our business.
• We are under a legal, regulatory or professional obligation to do so.

Any third parties we may share your data with are obliged to keep your details secure, and to use them only to fulfil the service they provide you on our behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with our policy unless they are themselves under a legal obligation to retain the information. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent unless we are legally required to do otherwise. We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organization with unaffiliated entities for their independent use except as expressly described in this Privacy Statement or with your express prior permission.

Retention of Your Data

We retain the information we collect no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.

Links to Other Websites

The Sites and communications may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. This Privacy Statement does not cover the information practices of those third-party websites.

Collection of Anonymous Information

We sometimes collect anonymous information from visits to a Site to help us provide better customer service. For example, we measure visitor activity on the Sites, but we do so in ways that keeps the information anonymous. We use the information that we collect to measure the number of visitors to the different areas of our Sites, and to help us make our Sites more useful to visitors. This includes analyzing these logs periodically to measure the traffic through our servers, the number of pages visited and the level of demand for pages and topics of interest. None of the information constituted in such logs will include or constitute personal data and such logs may be preserved indefinitely and used at any time and in any way to prevent security breaches and to ensure the integrity of the data on our servers.

Information Security

We take steps to hold information securely in electronic or physical form. Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All of our employees, officers or contractors and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards. While we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services. It is your responsibility to scan what you choose to download from our Sites to ensure that it is free of such items as viruses, worms, Trojan horses and other similar destructive code. If you communicate with us using a non-secure mechanism, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient. Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorized access, modification or disclosure. You can help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly confidential to you and not be made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.

International Transfers

Where you are submitting personal data from within the European Economic Area ("EEA") or any other particular jurisdiction, such information may be transferred to countries outside that particular jurisdiction. By way of example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with the Section titled Disclosure of Your Information are located, or have their servers located, outside your country or the country from which the data were provided. If we transfer your information outside your jurisdiction in this way, we will take steps to ensure that your privacy rights continue to be protected to the standard required under applicable data protection laws.

Your Rights

Under applicable data protection legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate at the contact details below. Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products and services (or part of them) either at the point such information is collected, (using an appropriate acknowledgment and consent) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the contact details below. You can request:

• access to the personal data we hold about you;
• corrections or updates to your details;
• the erasure of your personal data;
• the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.

You also have the right to object to, or request the restriction of, our use of your personal data. If you would like to exercise any of the rights set out in this Section, please contact us using the details set out below. We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.

Feedback, Including Comments, Questions and Complaints

We value your comments and opinions. If you have any comments, questions or complaints about us or about our use of your information or about this online Privacy Statement, please contact us. Our contact details are as follows:

If you do not receive a response to your inquiry relating to our privacy practices – or if you feel your inquiry has not been satisfactorily addressed, you may submit a complaint to your local data supervisory authority. If you make a privacy complaint with us, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint when you send us, or provide us with personal information via email (that is, in a message containing a question or comment, or by filling out a form that emails us this information) or via telephone, we use it to respond to your requests.

Changes to the Privacy Statement

Please note this Privacy Statement will change from time to time. We expect most such changes to be minor, but there may be changes that are more significant. Regardless, we will post those changes on this page and, if the changes are significant, we will also provide a more prominent notice.

Further Information

At your request, we can confirm what information we have about you and how it is processed. If we hold your personal data, you can request the following information by contacting us at the coordinates below.

• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on our legitimate interests or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• The source of personal data if it wasn't collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

All Data Subject Requests can be made through our company website. Proof of identity is required.

General Disclaimers

Neither we nor any of our affiliates, agents, contractors, employees or other representatives will be liable for losses arising out of or in connection with the use of our Sites to the extent permissible by law. We are only providing our Site and its contents on an "as is" basis and we make no representations and/or warranties of any kind, express or implied, with respect to our Sites or its contents including without limitation warranties of merchantability and/or fitness for a particular purpose. In addition, we do not represent or warrant that the information accessible from or via our Sites is accurate, complete or current. The limitations of liability in relation to our Sites apply to all damages of any kind, including, without limitation, compensatory, direct, indirect or consequential damages, loss of data, loss of opportunity, income, production or profit, loss of or damage to property and claims of third parties. The limitations of liability in relation to our Sites do not limit our liability to the extent that it cannot be limited and/or excluded by applicable law. e2f, inc., 2570 N 1st Street, 2nd Floor, San Jose CA 95131, USA