PRIVACY POLICY

Last Updated: June 26, 2024 (“Effective Date”)

Protecting individual privacy is important to All4Staff, Inc. d/b/a WorkBright (“WorkBright”, or “us” or “we”). This Privacy Policy is intended to describe how we collect, use and disclose information from you, including through websites operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), through our social media pages (“Social Media Pages”), as well as through email messages that we send to you that link to this Privacy Policy (collectively the Websites, Apps and our Social Media Pages are referred to as the “Services”). Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. BY USING THE SERVICES YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

1. Changes to Our Privacy Policy.

We reserve the right to make changes to this Privacy Policy at any time and will post the updated Privacy Policy on the Services. You are responsible for periodically reviewing the Services and this Privacy Policy to check for any updates or changes. Your use of the Services following the posting of any revised Privacy Policy shall be deemed acceptance of the revised policy, so we strongly recommend that you check back periodically to review this Privacy Policy.

2. The Information We Collect.

A. Personally Identifiable Information.

“Personally Identifiable Information” is information, that either alone or in combination with other information, identifies you. When we combine other information (i.e., information that does not, on its own, identify you), with Personally Identifiable Information, we treat the combined information as Personally Identifiable Information.

B. How We Collect and Use Personally Identifiable Information.

We and our service providers collect the Personally Identifiable Information set forth below in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the Personally Identifiable Information we request, we may not be able to provide you with the requested Services. The Personally Identifiable Information we and our service providers collect includes but is not limited to:

Information Required to Complete Your Personnel File.

In various areas of the Services, we provide you the opportunity to submit information which your current or prospective employer has deemed necessary in order for you to complete the required forms for your personnel file, either as an employee or contractor for such organization. Submission of your information in this regard may include but is not limited to the following categories of Personally Identifiable Information: (i) first and last name; (ii) email address; (iii) mailing address; (iv) social security number; (v) driver’s license number; (vi) financial account numbers; and (vii) national origin. We may send you reminder emails and text messages from time to time in the event you have not provided all information necessary in order to complete your personnel file. In addition, we may use your email and text messages to inform you of new products, technical information and services, and upcoming events that may be of interest. If you no longer wish to receive these emails and text messages, you may opt-out by clicking on and completing the opt-out link provided at the bottom of the applicable email or by replying STOP to the text message phone number. Please note that if you opt-out of receiving marketing-related emails or text messages from us, we may still send you important administrative messages, from which you cannot opt-out.

Personally Identifiable Information Collected through Various Forms.

We and our service providers may collect Personally Identifiable Information in a variety of ways, including but not limited to: (i) through use of the Services; (ii) offline, such as when you contact customer service or (iii) from other sources, such as public databases or other third parties.

Personally Identifiable Information You Disclose Relating to Others.

If you disclose any Personally Identifiable Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

C. Information We Automatically Collect Through Our Services.

We and our service providers collect the following types of information automatically when you use the Services:

Log Information.

When you use our Services, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Services), number of clicks, and how you interact with links on the Services, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of the Services to further our legitimate interests in securing the Services by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Services to improve the Services’ function and content.

Cookies and Similar Technology

When you use or access the Services, we use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Services. We process the information, including Personally Identifiable Information, collected through such technologies to further our legitimate interests in operating the Services, enhance your experience through personalization, and help us better understand the features of the Services that you and other users are most interested in.

Some of our service providers and third parties from which we receive content, for example ApplicantPro for online applications, use cookies or other methods to gather information regarding your use of our Services. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Services with any of your Personally Identifiable Information that they may have. The use of such information by a third party depends on the privacy policy of that third party. If you would like more information, please see Section 10 for our contact information.

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Services may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

We may also collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services, such as location stamping a signature. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location but if you do, we and/or our partners may not be able to provide you with the applicable personalized services and content.

Our Services do not currently have the capability of responding to “Do Not Track” signals received from various browsers.

Other Information.

In addition to the other information outlined in this Section 2.C, we may also collect information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as but not limited to: (i) browser and device information; (ii) App usage data; (iii) demographic information and other information provided by you that does not reveal your specific identity; and (iv) information that has been aggregated in a manner that it no longer reveals your specific identity.

3. How We Use Your Personally Identifiable Information.

A. Use of Personally Identifiable Information.

We and our service providers may use Personally Identifiable Information for our legitimate business interests, including the following: (i) to respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service; (ii) to send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communication that we believe may be of interest; (iii) to personalize your experience on the Services by presenting products and offers tailored to you; and (iv) for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, or improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

B. To Whom We Disclose Personally Identifiable Information.

We will not disclose Personally Identifiable Information about you except as set forth in this Privacy Policy or with your consent. This section describes to whom we disclose Personally Identifiable Information, and for what purposes:

Employers. To your current or prospective employers who have engaged us to provide the Services to you for purposes of creating or maintaining your personnel record(s) electronically.

Our Service Providers. We employ service providers to perform tasks on our behalf and to assist us in providing the Services, such as website hosting, data analysis, payment processing, order fulfillment, customer service, information technology and related infrastructure provision, email delivery, and other services. A list of all current third party vendors can be found at the conclusion of this policy.

Companies Involved in Merger and Acquisition Transactions. In some cases, we may choose to buy or sell assets. In these types of transactions, user data (including Personally Identifiable Information) is typically one of the business assets transferred. Moreover, if WorkBright, or substantially all of its assets, were acquired, user data would be one of the assets that is reviewed and transferred or acquired by a third party.

Law Enforcement, Government Agencies, and Courts. We may disclose Personally Identifiable Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of a customer or any other person. We may also disclose Personally Identifiable Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.

4. Your Data Subject Rights.

If you provide us with Personally Identifiable Information, you have the following rights with respect to that Personally Identifiable Information:

to access, edit, delete, or export (i.e. data portability, if legally required), or object to or restrict certain categories of Personally Identifiable Information that you have supplied to us by contacting us in accordance with the information provided in Section 10 below. We will promptly review all such requests in accordance with applicable laws.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personally Identifiable Information about you. We encourage you to first reach out to us in accordance with the contact information set forth in Section 10 so we have an opportunity to address your concerns directly before you do so.

5. How We Protect Your Information.

The security of your Personally Identifiable Information is important to us and we take reasonable precautions to protect it, which may, in certain circumstances, include the use of Secure Sockets Layer (SSL) encryption technology supported by most Internet browsers. Additionally, most Internet browsers also offer their own security features that enable end users to control how their transmissions are protected. Please remember, however, that any Personally Identifiable Information you send to us via the Internet is subject to the risk of unlawful interception by third parties, and that no method of safeguarding information is 100% secure. If you become aware of any breach of security, please notify us immediately.

6. Children’s Use of The Website.

The Services are not intended for children under 13 years of age. We do not knowingly collect Personally Identifiable Information from children under age 13. If you are under 13 years old, do not use or provide any information on or through the Service. If we learn we have collected or received Personally Identifiable Information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe we might have any personally identifiable information from or about a child under the age of 13, please email us at support@workbright.com.

7. Links to Affiliate, Partner, and other Third Party Websites.

To the extent the Services contain links to any networked web pages and/or other websites operated by our partners, affiliates, or other third parties, the privacy policy featured on such partner, affiliate, or third party site shall control. We are not responsible for the privacy practices of the partner, affiliate, or other third party websites you choose to visit.

8. Retention.

We will retain Personally Identifiable Information about you for the period necessary to fulfill the purposes for which Personally Identifiable Information about you has been collected as outlined in this Privacy Policy unless a longer retention period is required by law. In most cases, your prospective employer sets the period that your Personally Identifiable Information is stored within our System.

9. Location of Our Servers; Governing Law and Venue for Disputes.

If you are using the Services from outside the United States, please be aware that the Services and the servers that host it are located in the United States and any information or data you provide, including Personally Identifiable Information, will be transferred to the United States. By using the Services or providing your Personally Identifiable Information, you agree and consent to (a) the application of the laws of the State of Colorado, United States, with respect to any dispute arising out of or related to this Privacy Policy, and (b) the exclusive jurisdiction of the courts of the State of Colorado, United States to resolve any such dispute and you hereby waive any objection thereto based on inconvenient forum.

10. Contact Information.

We welcome your comments about this statement of privacy. If you believe that we have not adhered to this statement, please contact us at support@workbright.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.

11. Third Party Subprocessors as of April 2023

We employ service providers to perform tasks on our behalf and to assist us in providing the Services, such as website hosting, data analysis, payment processing, order fulfillment, customer service, information technology and related infrastructure provision, email delivery, and other services. The below is an example of some of the service providers we engage, but is not meant to be an exhaustive list and may be updated by us from time to time. As of the Effective Date, these third parties include those listed here.