Privacy Policy

We at Correlation One, Inc. (“Correlation One”, “us”, “our”, or “we”) are strongly committed
to transparency, and we want you (“you” or “your”) to understand how we collect, use, share
and protect your personal information, as well as how you can manage the personal information
we collect. This Privacy Notice applies to your interactions with us or your use of our websites;
(correlation-one.com, correlation1.com, c1-connect.com, ds4a.com, datathon.com, and
c1games.com), products, services, apps, or features, either online or offline (collectively, our
“Services”). Please see Section 12 for the contact details of our data protection officer for the
purposes of EU and UK privacy laws.

By using our Services, you acknowledge the terms of this Privacy Notice. If you do not agree to
the terms of this Privacy Notice, please do not use our Services. If you do not understand, or if
you have questions about, this Privacy Notice, please contact us before using, or continuing to
use, our Services.

We reserve the right to change our Privacy Notice from time to time by posting the changes here.
If we choose to amend this Privacy Notice, we will revise the Last Updated date at the top of this
Privacy Notice when we post the updated version. We may also provide you with notice by
prominently posting on our website, via email or both, if we make any significant changes to this
Privacy Notice. We may also highlight those changes at the top of this Privacy Notice and
provide a prominent link to it for a reasonable length of time following the change. Your use of
our Services after we have informed you in one of these ways that we made changes to our
Privacy Notice will mean that you have accepted those changes.

1. TYPES OF INFORMATION WE COLLECT
2. HOW WE COLLECT PERSONAL INFORMATION
3. HOW WE USE PERSONAL INFORMATION
4. WHY WE USE PERSONAL INFORMATION
5. HOW WE SHARE PERSONAL INFORMATION
6. HOW WE PROTECT PERSONAL INFORMATION
7. DATA TRANSFERS
8. CHILDREN’S PRIVACY
9. YOUR CALIFORNIA PRIVACY RIGHTS
10. YOUR CHOICES
11. THIRD PARTY WEBSITE AND APPS
12. EUROPE
13. CONTACT US

TYPES OF INFORMATION WE COLLECT

We collect two basic types of information from you when you provide it to us or when you use
or interact with our Services: personal information and non-personal information.

Personal information includes all information that relates to you or which are opinions about you
personally and either identifies or may be used to identify you personally (collectively,
“personal information”). We may collect the following types of personal information from you
depending upon the device you are using and how you interact with us or use or interact with our
Services, such as your:

• Contact Information. Name, mailing address, email address, phone number, and other
  contact information.
• Demographic Information. Date of birth and gender. You may also voluntarily provide
  us with racial or ethnic background information.
• Device Information. IP address, browser type and version, browser plug-in types and
  versions, operating system and platform, device type and device identifiers.
• Account Information. If you create an account, we may store and use your name, email
  address, zip or postal code and other personal information you may provide with your
  account. You can modify some of the personal information associated with your account. If you believe that someone has created an unauthorized account, you can request its
  removal.
• Resume / Employment Information. Some of our Services permit you to create or upload your resume or provide employment-related information that would typically be found within
  a resume (i.e., current income, previous employment, education information, etc.). Some
  of the information contained within your resume may be considered personal
  information.

HOW WE COLLECT PERSONAL INFORMATION

• Visit our website or use our Services;
• Register for an account or create a profile to access one of our training, assessment or competition(s);
• Correspond with us in any way, including through surveys and promotions;
• Sign up to receive our newsletter or promotional information;
• Ask for customer service, support or other assistance;
• Interact with third party links and/or third party services accessible via our Services; or
• Interact with us in any other way, online or offline, including through our Services, e-mail, SMS/text messages, or otherwise.

RESUME BUILDER AND AI ASSISTANT 

Information We Collect: We collect the following types of information when you use our AI-powered Resume Assistant:

• Personal Information: We collect personally identifiable information (PII) such as names, email addresses, mailing address, and phone numbers. This information is provided by you voluntarily during the interaction with our Resume Assistant. We also extract relevant data inputs from your application to Correlation One when you applied to one of Correlation One’s training programs.
• Contextual Information: When you engage with our AI Assistant, we share information about the job you are interested in tailoring a resume for, as well as all the information from your in-progress resume with external parties for the purpose of connecting you with potential job opportunities. This may include sensitive information related to your professional background and work history.
• Chat History: We store the entire chat history between you and our AI Assistant, including any personal or sensitive information shared during the conversation.

How We Use Your Information: We use the information collected to:

• Provide you with tailored resume assistance based on the job context and your input.
• Improve and enhance our AI-powered resume assistant's capabilities.
• Analyze user interactions to optimize the user experience.
• Store your resume information securely in our database for your convenience.
• Conduct research, develop new algorithms or any other legally permissible use cases.

Data Storage

• We may store the contextual information, in-progress resumes, and chat history in OpenAI's cloud. OpenAI's privacy policy is also applicable to the data stored in their cloud, and you can refer to it here. y

Cookies

Like many websites and apps, we use “cookies”, which are small text files that are stored on
your computer or equipment when you visit certain online pages that record your preferences and
actions, including how you use the website. We use this information for analytics purposes
which allows us to improve your browsing experience. The information we collect through these
technologies will also be used to manage your session. Out of these cookies, the cookies that are
categorized as "necessary" are stored on your browser as they are essential for the working of
basic functionalities of the website. These necessary cookies cannot be disabled.

For more information about cookies and how we use them, please see our Cookie Notice.

Cookie Opt-out. You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies, if you opt-out from cookies, or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal. 

Online Analytics

We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Offline Interactions and Other Sources

We also may collect personal information from other sources, such as our partners or third party
service providers, or from our offline interactions with you for the purposes listed in the How
We Use Personal Information section below, including to enable us to verify or update
information contained in our records and to better customize the Services for you. For example, if you apply for a position with us, we may collect information from former employers,
employment/recruiting agencies, credit reference agencies, or other background check agencies.

Social Media Integration

Our Services may, from time to time, contain links to and from social media platforms. You may
choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter,
and when you do, we may collect additional information from you, including the information
listed in the Types of Information We Collect section above. Please be advised that social
media platforms may also collect information from you. When you click on a social plug-in,
such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s
plugin will be activated and your browser will directly connect to that provider’s servers. We
encourage you to review the social media platforms’ usage and disclosure policies and practices,
including the data security practices, before using them.

Surveys

From time to time, and subject to your consent where required by applicable local law, we may
provide you with the opportunity to participate in surveys, some of which might be sponsored or
conducted by a third party. Participation in these surveys is completely voluntary. If you choose
to participate, we will request certain personal information from you. If there is a third party
sponsor involved in the survey, we may provide certain personal information to the third party
sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys
offered by us may be governed by specific rules and terms and conditions that are separate from
and in addition to this Privacy Notice. By participating in any such surveys you will become
subject to those rules, including but not limited to receiving emails containing survey
communications.

HOW WE USE PERSONAL INFORMATION

We may use personal information to do any or all of the following:

• provide you with our Services;
• facilitate your interactions and transactions with us;
• respond to your requests, communications, suggestions, comments, inquiries, and
  requests (including your feedback about our Services);
• administer our relationship with you, including creating and managing your account;
• maintain and improve our Services;
• measure the performance of our Services;
• develop new products, features, and services;
• better understand the preferences of our customers;
• provide personalized Services, including content and ads;
• provide you with, and improve, relevant marketing offers or information from us or
  relevant third parties;
• communicate with you about jobs and opportunities that may be of interest to you;
• facilitate your participation in our surveys and promotions;
• respond to legally binding requests from law enforcement, regulatory authorities, or other
  third parties;
• defend, protect or enforce our rights or applicable terms of service or to fulfill our legal
  or contractual obligations;
• to prevent fraud or the recurrence of fraud;
• assist in the event of an emergency;
• comply with applicable law; or
• any other purpose with your consent.

We may also combine your personal information collected through various sources, including
information collected through our Services, and develop a customer profile that will be used for
the purposes above.

Except as otherwise permitted or required by applicable law, we only retain personal information
for as long as we need to use the information for the purposes listed above, including, for legal,
regulatory, backup, archival, accounting, and/or audit purposes.

If you are a job applicant, we will use your personal information as necessary to determine your
fitness for a position, to make any relevant adjustments during the recruitment process and for
equal opportunities monitoring. If you are an employee, we may process and use your personal
information for legitimate business purposes related to performing the employment contract with
you.

We may use personal information to create non-personal information. We may use non-personal
information for any legitimate business purpose.

SMS/Text Messages

We collect your mobile phone number to communicate and follow-up with you for recruitment
and employment purposes. You may also choose to consent to receive SMS text updates from us
or our third-party providers regarding your application and other employment opportunities. You
may opt out of receiving text messages at any time by texting STOP to the sender. You
understand and agree that you may continue to receive communications from us while we
process your opt-out requests, and you may also receive a communication confirming the receipt
of your opt-out requests.

Use of Special Categories of Personal Information

You may choose to provide us with your racial or ethnic origin, which is considered a special
category of personal information under certain laws. We only collect and process this
information when you voluntarily provide it to us. We use this information to determine whether
you are eligible to receive our Services free of charge.

WHY WE USE PERSONAL INFORMATION

We may use personal information for a number of reasons:

• to fulfill our contractual obligations to you, including to provide our Services to you;
• the individual has given consent for a particular purpose (for example, where an individual has given us consent to send them electronic marketing);
• when using the information is necessary for our legitimate interests or those of a third party, provided we have balanced these against the individual’s rights and interests;
• in the event that we believe it necessary or appropriate to prevent criminal or illegal activity, personal injury, property damage or bodily harm; and in order to comply with a legal obligation (for example, responding to government or law enforcement information requests).

• to effectively administer and manage our business (including our hiring and recruitment process);
• to ensure effective administration and management of the individual’s relationship with us, including providing our Services;
• to understand how our customers use our Services and to manage our Services;
• to carry out research and analysis on what Services or products our customers want or how they would like us to improve our Services and products;
• to understand how our customers use our Services and identify any issues in how the Services are used and how we can improve the customer's usage experience;
• to tell our customers about the various products and Services we can offer;
• to inform our customers about, and consider them for, other opportunities or positions that may be of interest to them;
• to understand and respond to inquiries and feedback;
• to better tailor and personalize the promotions and benefits that we can offer to our customers;
• to ensure our systems and premises are secure;
• to develop relationships with business partners;
• to ensure debts are paid;
• to operate suppressors to exclude you from direct marketing if you unsubscribe;
• to share data in connection with acquisitions and transfers of our business;
• to manage our supply chain;
• to prevent, detect, or investigate unauthorized use of our Services and ensure we comply with the law and our policies; and
• to manage any dispute and accidents and take legal or other professional advice.

HOW WE SHARE PERSONAL INFORMATION

We may share personal information with potential employers as well as our third party service
providers, suppliers, vendors, professional advisors and business partners, which may include IT
service providers, financial institutions and payment providers, customer relationship
management vendors, other cloud-based solutions providers, lawyers, accountants, auditors and
other professional advisors. We contract with such vendors and advisers to ensure that they only process your personal information under our instructions and ensure the security and
confidentiality of your personal information. We share personal Information with these third
parties to help us:

• with the uses described in the How We Use Information section above;
• in the operation, management, improvement, research and analysis of our Services;
• with our marketing and promotional projects, via e-mail, SMS/text message, or otherwise, such as sending you information about products and services you may like and other promotions (provided you have not unsubscribed from receiving such marketing and promotional information from us); and
• comply with your directions, permission, or any consent you have provided us.

• responding to a subpoena, court order, or other legal processes;
• defending, protecting, or enforcing our rights; assisting in the event of an emergency; and
• complying with applicable law.

If you are a job applicant, we may share your personal information with potential employers,
employment/recruitment agencies, or background screening providers as part of the recruitment
process.

In accordance with applicable law, we may also transfer or assign personal information to third
parties as a result of, or in connection with, a sale, merger, consolidation, change in control,
transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a
legal claim, we may disclose personal information about you that is relevant to the claim to third
parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with third parties as reasonably necessary to meet our
business needs.

HOW WE PROTECT PERSONAL INFORMATION

We are dedicated to ensuring the security of your personal information. We use physical,
electronic, and administrative security measures appropriate to the risks and sensitivity of the
personal information we collect. We aim to provide secure transmission of your personal
information from your devices to our servers. We have processes to store personal information
that we have collected in secure operating environments. Our security procedures mean that we
may occasionally request proof of identity before we disclose your personal information to you.
We try our best to safeguard personal information once we receive it, but please understand that
no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your personal information,
please contact us immediately.

DATA TRANSFERS

We are a global business. As such, information we collect may be transferred to, stored, and
processed in any country or territory where one or more of our business partners or service
providers are based or have facilities which may be a different to your home country. In these
circumstances, the governments, courts, law enforcement, or regulatory agencies of that country
may be able to obtain access to your personal information through the laws that country. While
other countries or territories may not have the same standards of data protection as those in your
home country, we will continue to protect personal information that we transfer in line with this
Privacy Notice by requiring that our business partners or service providers adhere to this Privacy
Notice and the applicable privacy regulations in your home country.

CHILDREN’S PRIVACY

Our Services are not for children or those under the age of 16. We do not knowingly collect
personal information from children or other persons who are under 16 years of age. Individuals
who are children or those under the age of 16 should not attempt to provide us with any personal
information. If you think we have received personal information from children or those under the
age of 16, please contact us immediately.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law permits you to request information regarding the
disclosure of your personal information to third parties for the third parties’ direct marketing
purposes. In addition, California residents under 18 years old, in certain circumstances, may
request and obtain removal of personal information or content that you have posted on our
Services. Please be mindful that this would not ensure complete removal of the content posted by
you on our Services. To make any request pursuant to California privacy law, please contact us.

YOUR CHOICES

We offer you certain choices in connection with our Services.

Access to your personal information

You may request access to the personal information that we collect, use, and disclose about you. To submit a request, please contact us using the information below.

Deleting your personal information

You may request that we delete your personal information. To submit a request, please contact us using the information below.

Updating your personal information

The accuracy of the personal information we have about you is very important. To submit a request to update or correct your information or designate an authorized agent to make such a request, please contact us using the information below.

Email Communications / Direct Marketing

You may have the opportunity to receive certain communications from us related to our
Services. If you provide us with your email address in order to receive communications, you can
opt-out of marketing emails at any time by following the instructions at the bottom of our emails
and adjusting your email preferences. Please note that certain emails may be necessary for the
operation of our Services. You will continue to receive these necessary emails, if lawful and
appropriate, even if you unsubscribe from our optional marketing communications.

Cookies / Beacons

If you wish to minimize information collected by cookies or beacons, you can adjust the settings
of your device or browser. You can also set your device or browser to automatically reject any
cookies. You may also be able to install plug-ins and add-ins that serve similar functions.
However, please be aware that some Services may not work properly if you reject cookies. In
addition, the offers we provide when you visit us may not be as relevant to you or tailored to
your interests. For more information about how our Services use cookies, please see our Cookie
Notice.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you
wish to minimize the amount of targeted advertising you receive, you can opt-out of certain
network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page or
through the Digital Advertising Alliance Opt-Out Tool. Please note that even if you choose to
remove your personal information (opt-out) you will still see advertisements while you’re
browsing online. However, the advertisements you see may be less relevant to you. For more
information or to opt-out of certain online behavioral advertising, please visit http://www.aboutads.info.

Additionally, many advertising network programs allow you to view and manage the interest
categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference
that you can set in certain browsers, which is intended to be a signal to websites and services that
you do not wish to be tracked across different websites or online services you visit.

Please note that we cannot control how third party websites or online services you visit
through our website respond to Do Not Track signals. Check the privacy policies of those
third parties for information on their privacy practices. Our Services do not currently
change the way they operate upon detection of a Do Not Track or similar signal.

THIRD PARTY WEBSITES AND APPS

Our website and Services may contain links to other websites or apps operated by third parties.
Please be advised that the practices described in this Privacy Notice do not apply to information
gathered through these third party websites and apps. We have no control over, and are not
responsible for, the actions and privacy policies of third parties and other websites and apps.

EUROPE / UNITED KINGDOM / CANADA

This section only applies if you are a resident of a member state of the European Union
(EU), the United Kingdom, the European Economic Area (EEA), or Canada.

If you have questions or concerns regarding the use of your personal information, please contact
us.

International Transfers

The personal information we collect from you may be transferred to and stored by our group
companies, or IT vendors and other service providers (as specified in How We Share Personal
Information above) who operate on our behalf. We also transfer information to a number of
providers of business applications – such as CRM and marketing applications – as well
marketing service providers. These providers are primarily located in the United States, but may
also be located in other jurisdictions.

In certain cases, there may not be an adequacy decision by the European Commission and/or
United Kingdom authorities in respect of those countries. Adequacy of data protection is instead
ensured by Standard Contractual Clauses approved by the European Commission in accordance
with Article 46(2)(c) of the General Data Protection Regulation, or any equivalent clauses
approved by the authorities in the United Kingdom including any additional safeguards as
required by EU / UK data protection laws that we have in place with that third party. A copy may
be requested by contacting our Data Protection Officer.

• We retain your personal information for as long as necessary for the purpose(s) for which it was
  initially collected. The criteria we use to determine the retention period is as follows:
• whether there are contractual or legal obligations that exist which require us to retain the information for a period of time;
• whether there is an ongoing legal claim that relates to any business (or otherwise) relationship you have with us, or that is otherwise related to your relationship with us; and
• whether any applicable law, statute, or regulation allows for a specific retention period.

Your Privacy Rights

You may have – in accordance with applicable data protection laws – the following rights when
it comes to our handling of your personal information. Please note that many of these rights are
not absolute, and we may have grounds for refusing to comply with your request to exercise
them (for example, where we are (a) required or permitted by law to process your personal data
in a way that is incompatible with your request, or (b) able to rely on exemptions under data
protection law which entitle us to process your personal data in a way that is incompatible with
your request). Where such circumstances apply, we will inform you of this at the time you make
a request to exercise your rights.

• Right of access – you may have the right to request a copy of the personal information
  we have about you and to request supporting information explaining how the personal
  information is used;
• Right of rectification – you may have the right to request that we rectify inaccurate
  personal information about you;
• Right of erasure – you may have the right to request that we erase personal information
  about you;
• Right to restrict processing – in some situations, you may have the right to request that
  we do not use the personal information you have provided (for example, if you believe it
  to be inaccurate);
• Right to data portability – you may have the right to receive your personal information
  in a structured, commonly used and machine-readable format and to transmit such
  information to another controller;
• Right to withdraw consent – where we process your personal information based on
  consent (including direct marketing consents), you have the right to withdraw consent at 
  any time. However, this will not affect the lawfulness of the processing based on consent
  before its withdrawal. Furthermore, even in case of a withdrawal we may continue to use
  your personal information as permitted or required by law; and
• Right to object – where we are processing your personal information based on a
  legitimate interest (or those of a third party) you may challenge this. However, we may
  be entitled to continue processing your personal information where we can demonstrate
  that we have compelling legitimate grounds to process your information (which override
  your rights and freedoms), or where continuing to process your personal information is
  relevant to the establishment, exercise or defence of legal claims. You also have the right
  to object where we are processing your personal information for direct marketing
  purposes.

If you would like to exercise any of these rights or in case you should have any concerns about
how we process your personal information, please contact us using the information below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal information, or access someone else's personal information on
their behalf (or to exercise any of the other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer
than a month if your request is complex or you have made a number of requests. In this case, we
will notify you and keep you updated. Should we be unable to comply with your request, we will
provide an explanation.

Data Protection Officer Contact Information

You may contact our Data Protection Officer with any issues or questions you have regarding our processing of personal information.
EMAIL – privacy@correlation-one.com
POSTAL ADDRESS – Correlation One, Inc, 1330 Avenue of Americas, Suite 12A, New York,
NY, 10019.

You have the right to make a complaint at any time to the Information Commissioner's
Office (ICO), the UK supervisory authority for data protection issues (Tel: 0303 123 1113
or at www.ico.org.uk). Alternatively, you can also make a complaint to the supervisory
authority in the Member State of the EU or EEA in which you are resident. We would
however appreciate the chance to deal with your concerns before you approach the ICO or
a supervisory authority, so please contact us in the first instance.

Data Security

We take the security of your personal information seriously. We implement industry-standard security measures to protect your data from unauthorized access, disclosure, alteration, and destruction.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be effective immediately upon posting the updated policy on our website.

CONTACT US

We welcome requests, questions, comments, and feedback on this Privacy Notice and our
management of personal information. If you have requests, questions, concerns, or feedback, you
can always contact us in the following ways. For your protection, we may need to verify your
identity before assisting with your request, such as verifying that the information used to contact
us matches the information that we have on file.