Talentako Privacy Policy
Data privacy is important to the Talentako group of companies, which includes Talentako, Inc., Talentako K.K. (Japan) and their affiliates ("Talentako").

This Privacy Policy ("Privacy Policy") explains how information is collected, used, disclosed and stored by Talentako and applies to information collected when you use or access our desktop or mobile websites (such as www.talentako.com), products, services or applications (collectively, the "Talentako Services"), or when you attend a Talentako event or otherwise interact with us.

This Privacy Policy applies and has effect with respect to users located in Japan. If you are an user who is not located in Japan and having access to the Talentako Services through our desktop or mobile websites, you are accepting this Privacy Policy and you are deemed to consent to the terms of this Privacy Policy as to the collection, use, disclosure and storage of your personal information as described below in detail.

We respect the privacy rights of users and recognize the importance of protecting information collected about you. If you use the Talentako Services as part of an entity or organization that has an agreement with Talentako (like your employer or a university), the terms of that organization's contract for the Talentako Services may restrict our collection or use of your information more than what is described in this Privacy Policy.

Please read the following carefully to understand how we will collect, use and maintain your personal information. It also describes your choices regarding use, access and correction of your personal information.

Article 1. Changes to This Policy

1.1. We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Last Updated" date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by using email or other means of a notice
on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy whenever you access the Talentako Services to stay informed about our information practices and the ways you can help protect your privacy.

1.2. If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to deactivate with us and stop using the Talentako Services. Your use of any of the Talentako Services after the posting of such changes shall constitute your consent to such changes.

Article 2. Information Collected

2.1. We may collect certain user information (including personal information and/or
sensitive personal information) in the following ways:

(a) Information You Provide To Us. We collect information you provide directly to us including when you visit one of our websites, register for and/or use one of the Talentako Services.

(i) For example, we collect information when you register with Talentako for an account, create or modify your profile and online account, access and use the Talentako Services (including but not limited to when you upload, download or share files or other information), participate in any interactive features of the Talentako Services, participate in a survey, contest, promotion, sweepstakes, activity or event, make a purchase, apply for a job, request customer support, or communicate with us via third-party social media sites.

(ii) The types of information we may collect directly from you include your name, username, email address, your picture, postal address, phone number, information about your data storage preferences, employer's name, job title, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide. Please be aware that the information you choose to provide in your Talentako profile may reveal or identify information that is not expressly stated (for example, if you choose to provide your picture, your picture may reveal your gender. We also store the files or other information that you upload or provide to the Talentako Services ("Content") in order to be able to provide you with the features and functionality of the Talentako Service.

(iii) The information of third parties such as name, email address, etc. as may be
provided to enable the functionality and features of the Talentako Services.

(b) Information We Collect Automatically When You Use the Talentako Services. When you access or use the Talentako Services, we may automatically collect information about you, including:

(i) Usage Information: We monitor user activity in connection with the Talentako Services and may collect information about the applications and features you use, the websites you visit, the sizes and names of the files or folders you upload, download, share or access while using the Talentako Services, the Content you access and any actions taken in connection with the access and use of your Content in the Talentako Services.

(ii) Log Information: We log information about you when you access and use the Talentako Services including your Internet Protocol ("IP") address, access times, browser type and language, Internet Service Provider ("ISP"), the Web pages that you visit, the Content you use and the URL of the Web page you visited before navigating to the Talentako Services.

(iii) Device Information: If you access the Talentako Services from a mobile device, we may collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type).

We also collect the above listed personal information:

• Registered email;
• User full name;
• User biography;
• User nickname; and,
• Username.

Additionally, we collect the above listed information in relation with your
Talentako's user account:

• Account creation date and time;
• Confirmation sent date and time;
• Confirmed account date and time;
• Current session sign in date and time;
• Last session sign in date and time;
• Current session sign in Internet Protocol ("IP") address IP; and,
• Last session sign in IP.

If you experience an error or crash in any of the Talentako Services, we may collect data (using first or third party products) and logs from your device including information such as your device's IP address, device name, operating system version, application configuration(s), the time and date, and other statistics.

(iv) Information Collected by Cookies and Other Tracking Technologies: We (including service providers who are working on our behalf) use various
technologies to collect information, which may include saving cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Talentako Services and your experience, customize your experience and preferences, allow you to access and use the Talentako Services without re-entering your member ID and/or password, understand which areas and features of the Talentako Services are most popular and count visits. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images (also called "gifs") that may be used in the Talentako Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies and how to disable them, please see "Your Choices" below.

(v) Third party cookies: If you sign-up for, access, or log into the Talentako Services using third-party services, those third-party services may use cookies that are subject to those third-party services' own rules and policies. Talentako does not control the use of cookies by such third-party services. For more information around how you may be able to control the use of those cookies and other tracking technologies please see the
Opting Out of Cookies and Advertising section below.

(vi) Third Party clear gifs: Our third party partners employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage content on our website. We do not tie the information gathered to our Customers' or Users' personal information.

(vii) Advertising Cookies: We may partner with third parties to manage our advertising on other websites. Our third parties may use tracking technologies such as cookies to gather information about your activities on this website and other websites you visit in order to provide you advertising based upon your browsing activities and interests.

Article 3. Opting Out of Cookies and Advertising

3.1. You may opt out of behaviorally targeted ads anytime by deleting your browser's cookies. In addition, you may opt-out of interest-based advertising from some third- party partners by visiting http://preferences-mgr.truste.com/, http://www.youronlinechoices.eu, or the third-party provider's websites.

3.2. Please note that opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) after you opt-out.

(a) Do Not Track. Some browsers offer a "do not track" ("DNT") option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

(b) Information We Collect From Other Sources. We may also obtain information from third parties and combine that with information we collect through the Talentako Services. For example, we may have access to certain information from a third-party social media service if you create or log into your online account through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media service is in accordance with the Privacy Policy and authorization procedures determined by the social media service. We protect data obtained from third parties according to the practices described in this policy, plus any additional
restrictions imposed by the source of the data.

Article 4. Use of Information

4.1. We may use the information collected for the limited purpose of providing the Talentako Services and related functionality and services, as described in this Privacy Policy and as permitted by applicable laws. These limited purposes include circumstances where it is necessary to provide or fulfill Services requested by or for you or where you have given us your express consent.

4.2. The information may be used to perform a variety of purposes, including to:

(a) Provide, operate, maintain and improve the Talentako Services;
(b) Enable you to access and use the Talentako Services, including uploading, downloading, sharing Content and sending emails on your behalf;
(c) Send you technical notices, updates, security alerts and support and administrative messages;
(d) Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;
(e) Respond to your comments, questions, and requests and provide customer service and support;
(f) Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Talentako and our select partners;
(g) Process and deliver contest or sweepstakes entries and rewards;
(h) Monitor and analyze trends, usage, and activities in connection with the Talentako Services and for marketing or advertising purposes;
(i) Investigate and prevent fraudulent transactions, unauthorized access to the Talentako Services, and other illegal activities;
(j) Personalize and improve the Talentako Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Talentako Services;
(k) Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
(l) Enable you to communicate and share files with users you designate; and
(m) For other purposes about which we will provide you with prior notice as described in the "Changes to This Policy" section.

Article 5. Processing

By accessing or using the Talentako Services or otherwise providing information to us, you consent to the processing and transfer of information in and out of Japan. Your access to our Talentako Services through our desktop or mobile websites constitutes your agreement to
be bound by the provisions contained in this Privacy Policy no matter where you are.

Article 6. Sharing and Disclosure of Information.

6.1. We will not share personal information about you or any Content with any third parties except as described in this Privacy Policy or in connection with the Talentako Services. For example, we may share personal information about you including as follows:

6.2.Vendors, Consultants and Other Service Providers: We may share your information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as to process billing, provide customer support, etc. These service providers are authorized to use your personal information only as necessary to provide services to Talentako and/or Talentako Services. In some cases, we may share your information with third-party vendors to understand which areas and features of the Talentako Services are most popular and/or to improve the overall effectiveness of Talentako's Services and features.

6.3. Corporate Account: If you are an individual Talentako registered user and the domain of the primary email address associated with your Talentako account is owned by your employer and was assigned to you as an employee of that organization, and such organization wishes to establish a Talentako corporate account, then certain information concerning past use of your individual account may become accessible to that organization's administrator including your email address.

6.4.Compliance with Laws: We may disclose your information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and Terms of Service, (c) to protect the security or integrity of the Talentako Services, (d) to protect Talentako, our customers or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person or (f) to any other third party with your prior consent.

6.5.Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6.6.Aggregated or Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you.

Article 7. Security

7.1. While no service is completely secure, Talentako takes the necessary and proper measures to help protect information about you from leakage, loss, theft, misuse, unauthorized access, disclosure, alteration, destruction, and for other security control of the personal data.

7.2. Notwithstanding the foregoing, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

7.3. You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please
note that we will never ask you to disclose your password in an unsolicited phone call or email.

7.4. If you have any questions about the security of your personal information, you can contact us at contact@talentako.com.

Article 8. Your Choices

8.1. Account Information & Retention. You may update, correct or delete information about you at any time by logging into your online account and modifying your information or by emailing us at contact@talentako.com. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. If you wish to deactivate your account, please email us at contact@talentako.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements. We will retain personal data we process on behalf of our customers as directed by paying customers. Talentako will
retain this personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements. Upon request, Talentako will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information that we are aware of. To request this information, contact us at contact@talentako.com. We may ask you to provide us with your proof of identity before carrying out your request.

8.2.Promotional and Newsletter Communications. You may opt out of receiving promotional and newsletter emails from Talentako by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing contact@talentako.com with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Talentako Services or those about your online account or our ongoing business relations.

8.3. Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of the Talentako Services.

Article 9. Social Media Features and Widgets

The Talentako Services may include social media features. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on a Talentako Service. Your interactions with these features are governed by the privacy policy of the company providing it.

Article 10. Community Forums and Blogs.

10.1. Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

10.2. To request removal of your personal information from our blog or testimonials, contact us at contact@talentako.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Article 11. Testimonials

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent we may post your testimonial along with your name.

Article 12. Links to Third Party Websites

We may place links on the Talentako Services. When you click on a link to a third party website from our website, your activity and use on the linked website is governed by that website's policies, not by those of Talentako. We encourage you to visit their websites and review their privacy and user policies.

Article 13. Our Policy Toward Children

The Talentako Services is not directed to individuals under 18. We do not knowingly collect personal information from children under the age of 18. If you become aware that a child has provided us with personal information, please contact us at contact@talentako.com. If we
become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.

Article 14. Governing Law

14.1. This Privacy Policy shall be governed by and construed in accordance with the laws of Japan.

14.2. Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the Courts of Japan.

Article 15. Contacting Us

Any questions about this Privacy Policy should be addressed to contact@talentako.com.

Article 16. Complaints

If you have a concern about our handling of your personal information, please get in contact with us first using the details in the 'Contacting Us' section of this Privacy Policy.
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