1. Introduction

1.1 This Privacy Policy (the "Policy") explains how personal information is collected, used, disclosed, transferred, retained and protected when you use the openjobs platform at openjobs.ai and its related web and mobile applications and services (the "Platform").

1.2 openjobs connects AI talent with companies deploying next generation AI.

1.3 This Policy applies to three groups: (a) candidates and applicants whose information is processed for sourcing and hiring purposes; (b) individuals engaged by openjobs as employees or independent contractors to perform work for a client, whose information is additionally processed for engagement, payment, tax and statutory compliance purposes; and (c) employers, recruiters and client organizations that use the Platform to post roles, source candidates and engage contract personnel through openjobs.

1.4 "you" means the individual to whom the personal information relates. In this Policy, "individual" means any person whose personal information is processed through the Platform. That includes a Candidate, as that term is defined in the openjobs Terms of Service, and any person who uses the Platform for or on behalf of an employer, recruiter or client organization.

2. The entity responsible for your personal information

2.1 The Platform is operated by Jean Martin Inc. and Jean Martin Systems India Private Limited. The entity that acts as data fiduciary or controller in respect of your personal information, and the law that governs this Policy, are determined by the country in which you are established or resident:

2.2 Meaning of "openjobs". In this Policy, "openjobs", "we", "us" and "our" mean the entity identified at clause 2.1 in respect of your personal information, and where the context requires, its affiliates.

2.3 Where openjobs determines the purposes and means of processing your personal information, it acts as data fiduciary or controller. This includes operating and securing the Platform, surfacing roles to candidates and candidate profiles to employers, operating its artificial intelligence features, and improving its services. Where openjobs processes personal information on behalf of an employer or client using the Platform, for example in managing their candidates and workers, it acts as a data processor and processes that information on their instructions and under its agreement with them, including the Data Processing Agreement.

2.4 Where openjobs engages an individual as an employee or independent contractor to perform work for a client, openjobs acts as data fiduciary or controller in its own right in respect of that individual's engagement, payment, tax, statutory and record-keeping data. That processing is necessary for the performance of that individual's engagement agreement and for compliance with the legal obligations of openjobs.

3. Personal information collected

3.1 "Personal information" means any information relating to an identified or identifiable individual. Because the Platform supports sourcing, hiring, engagement and contractor payment, the categories collected are broader than those of a typical job board.

3.2 Some information collected, such as payment, banking and tax identifiers, may be sensitive or special-category personal information, which is processed only with your consent or as otherwise permitted by Applicable Law. openjobs does not currently collect biometric information, run background checks or identity verification, or monitor the activity or productivity of any individual. Certain providers listed in the sub-processor schedule to the openjobs Data Processing Agreement are capable of providing those services. Those features are not enabled. If openjobs enables any of them, this Policy will be updated and any consent required by Applicable Law will be obtained before the feature operates.

3.3 The categories collected are:

(a) Account and contact information

Name, email address, password, phone number, country, city, organization and your role on the Platform. Account data may be received through a social or single sign-on login.

(b) Candidate and profile information

Resume or curriculum vitae and profile details, including work experience, education, skills, certifications, current and past remuneration or pay rate, availability, and information you provide through forms or surveys. openjobs asks you not to include information that is not needed to consider you for a role, such as your date of birth, government identification or passport numbers, bank details, full residential address, photograph, marital status or health information, and you may ask openjobs to remove any such information at support@openjobs.ai.

(c) Career discovery and practice interview information

Where you choose to use the optional career discovery or practice interview features, the responses you provide and any feedback generated for you. These features exist for your own benefit. openjobs does not use them to evaluate, screen, score or rank you, their output is not shared with employers, and they play no part in whether your profile is surfaced to any employer.

(d) Digital signature and document information

Signed documents, signer identity, and signing metadata such as timestamps.

(e) Engagement, onboarding and workforce information

Onboarding records and dashboard activity generated during your use of the Platform and, where openjobs engages you, the information necessary to operate that engagement, including your engagement agreement and assignment records, timesheets and recorded hours, leave and availability records, statutory and payroll identifiers, bank details, tax identifiers and declarations, statutory contribution records, right-to-work evidence, and records required to be retained by Applicable Law.

(f) Payment and financial information

Information used for contractor payments, invoicing, auto-debit, tax and cross-border compliance, which may include bank or payment details, tax identifiers and billing information. Card and bank payment details may be handled by regulated payment providers rather than stored by openjobs.

(g) Sourced candidate information

Information about candidates processed through the search and sourcing features of the Platform. Where candidate information is obtained other than directly from the individual, openjobs takes the steps required by Applicable Law, including providing notice where required.

(h) Usage, device and technical information

Log information, IP address, device and browser information, approximate location, and information collected through cookies and similar technologies, as described in the Cookie Policy.

(i) Communications

Records of your communications with openjobs, and information you provide when using the Platform to communicate with other users, such as recruiter and candidate messaging.

(j) Feedback and survey information

Responses, ratings, opinions and other information you provide when you complete a feedback form, survey, poll, review or research request.

4. How personal information is collected

4.1 Personal information is collected: directly from you, when you register, complete your profile, use the optional career discovery or practice interview features, or use other Platform features; from authentication providers, where you register or sign in using a third-party login, from which openjobs receives basic account and profile information; automatically, through your use of the Platform, including logs, cookies and similar technologies; from employers or recruiters, where they provide information about candidates or workers they manage on the Platform; from third-party service providers, such as payment providers; and through the search and sourcing features of the Platform.

4.2 Where openjobs engages you, information is additionally collected from you in connection with your engagement, onboarding, payment and statutory compliance, and from clients, where they approve recorded hours or provide information relating to an engagement.

5. How personal information is used

5.1 Personal information is used only where there is a lawful basis to do so. Depending on how you interact with openjobs, it is used to:

• (a) provide the Platform and its features, including search, sourcing, surfacing of roles and profiles, applicant tracking, onboarding, digital signatures, contractor payments and related services;
• (b) surface roles to candidates, and surface candidate profiles to employers, based on the information candidates provide and the criteria employers specify. openjobs does not score, rate or rank candidates in deciding who is sourced, surfaced, shortlisted or presented to an employer. Where you choose to run an optional tool on your own information, such as the resume analyzer, it may generate a score for you. That output is shown only to you, is not stored by openjobs, is not shared with any employer, and plays no part in sourcing, surfacing or selection;
• (c) process payments, invoicing, payroll, statutory contributions, tax and cross-border compliance for contractor and worker payments;
• (d) where openjobs engages you, operate your engagement: agree and record your rate, issue assignments, record and verify hours, calculate and make payment, administer statutory deductions, contributions and benefits, meet tax and reporting obligations, and maintain the records required by Applicable Law;
• (e) provide customer support and respond to your requests;
• (f) maintain security and prevent, detect and investigate fraud, misuse and violations of the openjobs terms;
• (g) improve and develop the Platform, including its artificial intelligence features, and conduct research and analytics;
• (h) send service communications necessary to operate your account and the Platform, such as security alerts, transaction confirmations, reminders and important updates, which you cannot opt out of while you have an account, and marketing communications, including newsletters and promotional messages, which you can opt out of at any time. Where you have given the required consent, marketing and promotional messages may be sent by SMS, WhatsApp and other messaging platforms; message and data rates may apply, and you may opt out at any time;
• (i) comply with legal obligations and establish, exercise or defend legal claims; and
• (j) create and use aggregated, de-identified data that does not identify you, in order to operate, analyze, develop and improve the Platform and its search and artificial intelligence features.

6. Legal bases for processing

6.1 Where Applicable Law requires a lawful basis, openjobs relies on one or more of: your consent, including for certain sensitive processing and for marketing; performance of a contract with you, with your employer, or with the client for whom you are engaged; compliance with a legal obligation; and its legitimate interests, for example securing and improving the Platform, where these are not overridden by your rights. Where openjobs relies on consent, you may withdraw it at any time, which does not affect processing already carried out.

7. Artificial intelligence and automated processing

7.1 The Platform uses artificial intelligence for automated sourcing, search and the surfacing of roles and profiles, resume and plagiarism or artificial intelligence content detection, and optional candidate-facing career discovery and practice interview tools.

7.2 openjobs does not vet, evaluate, assess, screen, score or rank candidates and does not make or recommend hiring decisions. Employers set their own criteria and make their own decisions.

7.3 Artificial intelligence content and plagiarism detection is used only to flag items for review, never to reject a candidate automatically. A human reviews any flag before it affects an outcome. Where a candidate is flagged, they are given an opportunity to respond, and an audit record of review decisions is retained.

7.4 Where Applicable Law gives you the right, you may request human review of, or contest, a decision based solely on automated processing, and obtain meaningful information about how it works.

7.5 Third party artificial intelligence providers. Content you upload, including your resume, may be transmitted to and processed by a third party artificial intelligence provider engaged by openjobs to return a result. openjobs requires each such provider not to use that content to train its own models. A provider may hold the content for a limited period for security and abuse monitoring before deleting it, in accordance with its agreement with openjobs. Providers are listed in the sub-processor schedule to the openjobs Data Processing Agreement.

8. How personal information is shared and disclosed

8.1 Access to personal information is limited to those who need it in order to operate the Platform. Personal information may be shared with:

• (a) Employers and recruiters, where your profile and application are relevant to a role, consistent with your use of the Platform; Employers and recruiters receive your profile for their own evaluation and hiring purposes only. They are not permitted to publish it, post it on social media, list it on any other job board or website, or pass it to their own customers or partners, and openjobs does not consent on your behalf to any such use.
• (b) Candidates and workers, where an employer or recruiter shares information necessary for hiring, onboarding or management;
• (c) Payment, payroll and financial providers, in order to process payments, invoicing, payroll and tax and compliance functions;
• (d) Service providers, including cloud hosting, communications, analytics and similar vendors who process data on behalf of openjobs under contract;
• (e) Clients, where you are engaged by openjobs to perform work for a client, the information necessary to operate the engagement, including your recorded hours and the professional information relevant to your role. The rate openjobs pays you is not disclosed to the client;
• (f) Tax, revenue and statutory authorities, where openjobs is required to report, withhold or remit in respect of your engagement;
• (g) Between Jean Martin Inc. and Jean Martin Systems India Private Limited, where necessary in order to operate the Platform, to deliver an engagement, or to meet a legal or tax obligation, subject to appropriate safeguards and an intra-group agreement;
• (h) Authorities and legal parties, where required in order to comply with Applicable Law, respond to lawful requests, or establish, exercise or defend legal claims; and
• (i) Successors, in connection with a merger, acquisition, financing or sale of assets.

8.2 Applicant tracking. openjobs operates an applicant tracking system as part of the Platform, and your profile, resume and application information are processed through it. Where an employer or client is interested in you, it may carry out the next steps of its recruitment process within the openjobs applicant tracking system or, where its own applicant tracking system is integrated with the Platform, within its own system, in which case your information is transferred into that system and is then processed under its own privacy practices. openjobs does not submit applications to roles in your name.

9. International data transfers

9.1 openjobs is a cross-border platform. Personal information may be transferred to, stored in, or accessed from countries other than the one in which you are located, including the United States and India, and other countries in which service providers operate. Where personal information is transferred across borders, openjobs does so in accordance with Applicable Law and takes steps to ensure that it remains protected.

10. Data retention

10.1 Personal information is retained only for as long as necessary for the purposes described in this Policy and to meet legal, regulatory, tax, accounting or contractual obligations. When information is no longer needed it is deleted or anonymized in accordance with Applicable Law.

10.2 Where openjobs has engaged you, engagement, payment, tax and statutory records are retained for the periods required by employment, tax and companies legislation in the relevant jurisdiction, which may be longer than the period for which other information about you is retained. Those records cannot be deleted on request during that period.

10.3 Career discovery and practice interview responses are retained for the period needed to provide those features to you and any applicable statutory period, after which they are deleted or anonymized.

11. Your rights

11.1 Subject to Applicable Law, you may have the right to: access, and obtain a copy of, your personal information; correct or update inaccurate or incomplete information; request deletion of your information, subject to legal exceptions including those at clause 10.2; withdraw consent where processing is based on consent; object to or restrict certain processing, and request data portability where applicable; request human review of certain automated decisions, as described at clause 7.4; nominate another person to exercise your rights on your behalf where Applicable Law provides for this; and lodge a complaint with the relevant data-protection authority.

11.2 To exercise your rights, contact openjobs using the details at clause 15. openjobs may need to verify your identity before acting on a request. You may also delete your account using the settings in your account. These rights are subject to the conditions and exceptions in Applicable Law.

12. United States state privacy rights

12.1 If you are a resident of California or another United States state with a comprehensive privacy law, you may have the following additional rights: to know the categories and specific pieces of personal information collected, used, disclosed and, if applicable, sold or shared, and the categories of sources and recipients; to delete and to correct your personal information, subject to legal exceptions; to opt out of the sale or sharing of your personal information and of targeted advertising, where applicable; to limit the use of sensitive personal information to what is necessary to provide the services; to be free from discrimination for exercising your rights; and to use an authorized agent to submit requests and to appeal a decision on your request where Applicable Law provides.

12.2 The categories of personal information collected and the recipients to whom it is disclosed are described at clauses 3 and 8. To exercise any of these rights, or to opt out of any sale or sharing, contact support@openjobs.ai. Requests will be verified as required by Applicable Law.

13. Security

13.1 openjobs maintains physical, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse or alteration, including access controls, encryption of data in transit and, where appropriate, at rest, monitoring, and confidentiality obligations on staff and service providers. Service providers acting on behalf of openjobs are required to maintain appropriate safeguards. No method of transmission or storage is completely secure and absolute security cannot be guaranteed. Where a personal data breach is likely to affect you, openjobs will act in accordance with Applicable Law.

14. Children, third-party sites and changes to this Policy

14.1 Children. The Platform is intended for users who are at least 18 years of age, or older where Applicable Law requires. openjobs does not knowingly collect personal information from anyone below the applicable minimum age. If you believe a minor has provided personal information, please contact openjobs so that appropriate action can be taken.

14.2 Third-party sites and services. The Platform may link to or integrate with third-party sites and services governed by their own privacy policies. openjobs is not responsible for the privacy practices of those third parties. Once content is shared to, or interaction occurs on, a third-party platform, that content and interaction are governed by the terms and privacy practices of that third party.

14.3 Changes to this Policy. openjobs may update this Policy from time to time. Any update applies from the date the updated Policy is posted on the Platform and, where required by Applicable Law, additional notice will be provided. The "Last updated" date shows when it was last revised.

15. Contact and grievance redressal

15.1 For questions, requests or complaints about this Policy or your personal information, or to exercise your rights, contact the Grievance Officer and Data Protection Contact: Eswari Velayutham, Grievance Officer and Data Protection Contact, openjobs, support@openjobs.ai. openjobs will acknowledge a complaint and will respond within a reasonable period, and in any event within any period required by Applicable Law.

15.2 Jean Martin Inc., 260 Madison Avenue, Floor 8, New York, NY 10016, United States.

15.3 Jean Martin Systems India Private Limited, No. 37, TTK Road, CIT Colony, Alwarpet, Chennai, Tamil Nadu 600018, India, CIN U72200TN2004PTC053085.

16. Severability

16.1 If any provision of this Policy is found invalid or unenforceable, it will be limited or removed to the minimum extent necessary and the remaining provisions remain in full effect.