United Kingdom Privacy Policy.

Welcome to LIFELENZ, a versatile all-in-one people management platform that simplifies HR tasks and streamlines workflows(“Services”). People are at the core of our Services and we are committedto protecting the personal information of individuals that we work withglobally.

To make this Privacy Statement easier to understand, we have provided a summary to the of each section. We also encourage you to contact us (see “How to Contact Us”below) if you have any questions or concerns.

Last Updated: October 10th, 2024

SCOPE OF THIS PRIVACY STATEMENT

This Privacy Statement applies to individuals who interact with us or use LIFELENZ products and Services.

This Privacy Statement (“Statement”) sets out how LIFELENZ uses the information that we collect about you when you interact with us on our website (“Site”) or when using our Services. This Statement also explains the choices that you can make about the way that we use your information and applies to all individuals who interact with us globally as customers or their employees, our partners and vendors, visitors to our Site, or our own prospective employees or employees. This Site is owned and operated by Positive Circularity Inc.

Our Statement details the information we collect about you and how we use it, outlines the steps we take to protect the information you entrust to us, and describes your choices with respect to your information. By registering on this Site, submitting any information to LIFELENZ on our Site or by other wise accessing or using any of our systems or Services, you agree to the terms of this Statement and consent to the policies and practices described here.

YOUR RIGHTS AND PREFERENCES

LIFELENZ allows you to exercise your privacy rights and manage how we use your information.

Privacy and data protection laws in different geographic regions give individuals certain rights in relation to their personal information. We conduct our privacy practices according to this Privacy Statement and the relevant laws of the geographic regions in which we interact with you. LIFELENZ encourages you to become familiar with our privacy practices and to contact us to learn more about your privacy rights and how we collect and use your personal information. Unless we specifically disclose otherwise, you understand that we may use any of your collected personal information for any of the purposes described in this Statement (as permitted by applicable law).

INFORMATION WE COLLECT

We collect information that relates to you and your interactions with LIFELENZ.

When used in this Statement, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual (“data subject”), and includes “personal data” or “personal information” as defined in applicable data protection laws. Data that cannot be associated with you, such as aggregated, de-identified, or anonymized information (“Anonymous Information”), is not personal information. LIFELENZ commits to keep Anonymous Information in its de-identified state and will make no efforts to re-identify such data.

A. Information Directly from You.

LIFELENZ collects certain information from you in order to conduct business globally, including providing you with access to our Services, improving your experience, communicating with you in connection with or regarding our Services, and to enhance and improve our Site and operations based on insights we are able to obtain from your information, such as whether a given Site layout is convenient and accessible.

LIFELENZ also collects personal information directly from you during the recruitment process and in the context as an employer. If you choose not to provide certain personal information, we may not be able to provide you with requested Services, or information.

B. Information Collected in the Course of Using Our Services.

Your use of our Services may cause us to generate or collect certain information in order to facilitate providing those Services and enabling them to be useful, including:

• Scheduling and timekeeping information, Site work schedules and shifts, work offer and shift swap requests and responses, hours worked, estimated earnings and time records
• Work tasks, forms, notices, documents, locations, stations, and notifications, and messages
• Union membership
• Conversations between employees or between employer and employee
• Transactional, usage, and preference information, Site your subscription status, pages visited, types of Services accessed, data volumes transferred, shifts offered, response times, number of notifications, advertisements and coupons viewed, and settings chosen
• Other information about actions you perform through our Services and that you upload or provide during your use of our Services

C. Information from Third Parties.

We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application or site, such as an app store or a social networking site, we may collect information about you from that third-party site that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business and Services. We may also collect details of your interactions with other users of our Services.

D. Automatically Collected Information.

LIFELENZ may automatically collect some usage information when you interact with us. We use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, IP address, device type, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and Services information.

E. Derived Information.

LIFELENZ may use information we have about you to draw inferences and we may then use those inferences to gain a more complete understanding of your preferences. We use preference data in order to offer you potential choices, make recommendations, or to alert you to products or services that may be of interest to you.

F. Children’s Information.

LIFELENZ Services are not intended for children under 13 years of age. If you are aware that we have unintentionally collected information from someone who is underage, please notify us immediately by sending an email to privacy@LIFELENZ.com. By continuing to use our products and Services, you confirm that you are at least 18 years of age and are fully able and competent to enter into and accept the terms set forth in this Statement or that you have had a responsible parent or guardian do so on your behalf.

LIFELENZ does process children’s information in the employment context for the purpose of providing employee benefits.

G. Personal Information Collection and Disclosure Chart.

The following applies to the personal information of data subjects that interact with LIFELENZ and our Services:

HOW WE USE YOUR INFORMATION

We use your personal information to develop and provide our Services, to personalize, improve and promote our interactions with you, to operate our business and to communicate with you.

A. Delivering Services, including:

• Sending you an invitation to use our Services (for example, when your employer or potential employer invites you to use our Services, we may send you an invitation)
• To provide you with customer or technical support (e.g., by contacting you via email address)
• To facilitate social interactions between you and other users of our Services (such as employers)
• To notify you of future changes and improvements to our Services
• To provide you with access to the functionality and features of our Services (e.g., in order for you to create or update your CV, to request shifts, to find employers or employees)
• To manage our relationship with you and to manage the payment and recovery of amounts payable to us by you

B. Business and Internal Operations Purposes, Including:

• To analyze data to ensure appropriate service levels are being achieved
• To enable us to operate, maintain and improve the functionality and features of our Services
• If you have opted-in to receive advertising or coupons through the LIFELENZ app, to enable third parties to provide you with advertising or coupons in relation to offers for goods or services
• To provide you with other direct marketing communications regarding offers of goods or services which may be relevant to you
• To enable us to conduct our business generally, such as notifying our insurers, quality assurance, internal teaching and data processing and handling and in connection with any potential sale of our business and for other purposes which are reasonably necessary in connection with our normal functions and activities
• For our internal management purposes as a business and as an employer

C. Our Employment/Contract Application Process, Including:

• To assess and determine your eligibility or suitability for a job or contract with us
• To, with your permission, contact professional or other reference(s) you have provided in connection with a job application to discuss your experience/employment

HOW WE SHARE YOUR INFORMATION

We will only share your personal information as we have described in this Privacy Statement.

A. Affiliated Companies.

We may share your information with our affiliated companies to fulfil the purposes described in this Statement, including for data processing, marketing, and administrative purposes.

B. Vendors and Other Third Parties.

We may authorize vendors and other third-party companies to provide certain services. We provide these companies with only the information they need to perform their services and work closely with them to ensure that your privacy is respected and protected. These companies are prohibited by contract from using this information for their own marketing purposes or from sharing this information with anyone other than us. The services provided include:

1. Information Technology Providers

• Hosting and operation of the Site and other platforms
• Processing transactions and payments
• Digital marketing and advertising

2. Marketing, Advertising and Customer Service

• Marketing or promotional assistance
• Advertising, such as:
  • Sending you advertisements and promotions through the LIFELENZ app if you have opted-in to receiving these
  • Participating in or administering our promotions or surveys
  • Teaming to provide products, services, or promotions
  • Providing customer service
  • Third parties who may wish to contact you regarding offers of goods or services which you may be interested in, unless you have opted-out of receiving such marketing communications

C. In Connection With Your Job Application or in Connection with a Job or Contract With Us

• Disclosure to any professional or personal references you provide in connection with your job or contract application to the extent necessary for us to consider your application
• Disclosure to vendors that assist with employment processes such as payroll providers, benefits providers and IT service providers

D. Social Sharing, Including:

• Logging into, linking with or connecting your LIFELENZ account with your social media account
• Using your social media account to authorize or verify your LIFELENZ account
• Connecting your LIFELENZ account to your social media account where you have authorized us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy

E. Following the Law and Protecting LIFELENZ

We may share your information with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your information if we believe it is appropriate to protect the rights, property or safety of LIFELENZ, our Services, our people, or to protect or assist others as required by law or contract.

F. Credit Reporting.

We may share information about your creditworthiness with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

G. Sale of Our Business.

If we sell, merge, or transfer any part of our business, information about you may be shared, sold or transferred as part of that transaction. We may also share your information with current or future corporate parents, to our subsidiaries, between our brands, or with our affiliates.

H. De-identified or Aggregated Data.

We may de-identify or aggregate your information, alone or in combination with information from other individuals. Such de-identified or aggregated information will not contain personal information and may be shared freely by LIFELENZ.

I. With your Consent.

Other than as set out above, we may also share your personal information and your other information for additional purposes with your consent or at your direction.

Cookies and Similar Tracking Technologies

We and our service providers use cookies and other related technologies to receive and store certain types of information whenever you interact with us or use our Services through your computer or mobile device.

A. Cookies.

We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies ("Cookies”) to collect information about you. We use this information to improve your experiences when you interact with us. You have control over some of the data we collect from Cookies and how we use it. You may learn more about Cookies and how to manage them at https://www.allaboutcookies.org/

Please note that even if you elect not to enable Cookies or interest-based advertising and marketing, you may still receive advertisements, they just won't be tailored to your interests. Also, if you elect to receive Cookies and later delete them, use a different browser, update your systems, or use a different device, you may need to renew your choices.

B. Do Not Track.

Like most other companies, LIFELENZ is not currently configured to respond to browser "Do Not Track" signals because, at this time, no formal "Do Not Track" standard has been adopted.

C. Social Media Features.

LIFELENZ or our authorized third parties may use social media features to gather certain information about you. These features may collect your IP address, log which pages you are visiting, and may set a Cookie to enable features to function properly. Your interactions with these social media features are governed by the privacy policies and practices of the providing company and not by LIFELENZ.

SECURITY OF YOUR INFORMATION

We provide reasonable and appropriate security measures in connection with securing your personal information.

Keeping your personal information safe is important to us. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. At LIFELENZ, we:

• Work to review and update our security practices and implement accepted methods to protect your personal information.
• Store personal information on our secure servers behind firewalls and securely transmit such.
• Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry's Data Security Standards (PCIDSS). Payment transactions are encrypted using SSL or other encryption technology, or will use our third party payment processors, who will use appropriate security procedures.
• Comply with applicable laws and security standards.
• Train applicable employees and contractors on data privacy and require them to safeguard your data.

Your communications containing personal information may be unlawfully intercepted or accessed by third parties and our Site may be subject to network attacks or malfunctions. We cannot and do not guarantee the security of any information transmitted over the Internet. Once we receive your personal information, we take steps that we believe are reasonable to limit access to your personal information to only those employees and service providers whom we determine need access to the personal information to provide the requested Services, offers or opportunities that may be of interest to you or that you have ordered, or that we may otherwise disclose. However, even after we receive your personal information, we cannot and do not guarantee that your personal information will not be accessed, disclosed, altered, or destroyed as a result of a breach of our security efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your personal information or any other information is completely secure and safe from any risk.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain of our Services (such as our Sites or your customer account), you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas, like message boards or social media.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee its security during transmission to us. Any transmission of your information to us is at your own risk. LIFELENZ is not responsible for circumvention by a third party of any privacy settings or security measures.

YOUR DATA ACCESS RIGHTS

You may have the right to exercise certain data protection rights regarding your personal information.

LIFELENZ will not discriminate against you for exercising your privacy rights.

A. Responses from LIFELENZ.

We respond to all requests from individuals regarding the exercise of their data protection rights in accordance with applicable data protection laws. While your data protection rights may vary depending on your location, they generally include:

• Accessing, correcting, updating, or requesting deletion of your information,
• Objecting to or asking us to restrict the processing of your information,
• Requesting the portability of your information and providing the same in a timely manner and at no charge;
• Electing whether or not to receive marketing communications from us, and
• Withdrawing your consent at any time for us to collect, process, store, or share your information (noting that such withdrawal will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect otherwise lawful processing or storage).

Please see Section 10 for additional regional and country considerations.

B. Data Controller.

LIFELENZ is considered to be a “controller” of your information under certain data privacy regulations. It is possible that other entities may also act as controllers of your information and you should contact them if you have any questions about how they use your information.

ADDITIONAL REGIONAL/ COUNTRY PRIVACY CONSIDERATIONS

We operate in many different countries and regions. Our Statement sets out the privacy principles and procedures we adhere to globally, but specific laws may apply to you based on the country or region in which you are located.

LIFELENZ has adopted a global approach on privacy with the intent of providing individuals with strong privacy protections regardless of where they reside. We recognize and implement high standards for privacy rights compliance on a global scale. Listed below, you can find additional privacy provisions that may be relevant to your specific country or region.

If you have any questions or concerns regarding the privacy provisions relevant to you, or you wish to exercise any of these rights, please contact our Privacy Officer by using the contact information provided in Section 12 “How to Contact Us.”

A. Australia:

Controlling law: Australia Privacy Act of 1988

Australia Privacy Rights: If you are located in Australia, you have the following rights with respect to your personal information:

• right to know why personal information is being collected, how it will be used and who it will be disclosed to,
• right to not identify oneself, or use a pseudonym in certain circumstances,
• right to access personal information,
• right to stop receiving direct marketing,
• right to correct personal information, and
• right to make a complaint against a subject entity that mishandled your personal information.

B. Canada:

Controlling law: Personal Information Protection and Electronic Documents Act (PIPEDA)

Canada Privacy Rights: You can exercise your rights of access and rectification by contacting us. Depending on your province, you may have additional rights, including the right to control the dissemination of your personal information, the right to data portability, the right to be informed of and submit observations regarding automated decision-making, and the right to request information about data processing.

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your local privacy commissioner.

C. European Union (EU), United Kingdom (UK), Switzerland (CH) and European Economic Area (EEA):

Controlling laws: The General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), UK The Data Protection Act 2018 (UK GDPR), Swiss Federal Act on Data Protection.

Legal Bases for Processing EU, UK CH, EEA personal data: Applicable law and policies require LIFELENZ to have a “legal basis” for the processing of your personal data. The applicable legal basis often depends on the types of data and the specific context in which it is processed. Where the GDPR and similar laws apply, we typically rely on performance of a contract, our legitimate business interests, or your consent as our primary legal bases to process your personal data.

EU, UK, CH, EEA Privacy Rights: If you are located in these regions listed, you have the following rights with respect to your personal data. You may contact us if you wish to exercise any of these rights:

• The right to access your personal data;
• The right to update your personal data by emailing us or, where appropriate, amending the personal details contained in your registered account with us. If practically possible, we will make corrections (where appropriate) based on your updated information;
• The right to withdraw your consent with respect to data that is collected on the basis of your consent;
• The right to request erasure of your data or object to its processing;
• The right to data portability; and
• The right to lodge a complaint with us or with a supervisory authority.

D. United States (US):

Controlling Law: There are many US state-specific privacy laws with new ones coming into effect every year. As a company with operations based in California and because California’s privacy protections are viewed by many to be the most comprehensive in the US, we refer US-based individuals to the California Consumer Privacy Act of 2018 (“CCPA”), and as of January 1, 2023 the California Privacy Rights Act of 2020 (“CPRA”), for personal information protection.

Our Processing of US Personal Information: LIFELENZ collects and has collected in the last 12 months all of the information described in Section 3 of our Privacy Statement from and about US residents. You should refer to that section for more detail, but this information generally falls into the categories listed in the chart in Section 3 to the extent it is personally identifiable. The chart also indicates the data subjects whose personal information we collect, the purposes of processing, and the categories of third parties to whom we recently disclosed the data leading up to the effective date of this Statement.

LIFELENZ does not receive any monetary compensation for data it shares with vendors or service providers. LIFELENZ shares or “sold” (as that term is defined under applicable US privacy regulations) “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on a website), and “commercial information” (like the fact that a browser visited our webpage,) to third parties that assist us, such as marketing or analytics providers.

US Privacy Rights: Under applicable US law, you have the right to:

• Request access to your personal information as it is processed and stored by us;
• Correct or delete your personal information that we hold unless LIFELENZ is legally required to retain it;
• Restrict or object to our processing of your personal information;
• Lodge a complaint; and
• Opt out of “sale” of your personal information.

Marketing opt-out: Use the “Your Privacy Choices” link in the footer of LIFELENZ Sites, click on the “opt-out” option to opt out of sharing and sales of your personal information, which includes any sharing of your information for targeted advertising. As an alternative to using the link referenced above, you may call +1 8559555885 to submit your request.

Cookies and online tracker opt-out: If you would like to opt-out of CPRA “sales or sharing” that happen through Cookies and related technologies, follow the steps below on each LIFELENZ Site you use:

Click the cookie icon in the bottom left corner of the Site and select the “Reject All” option.

Please note, you must repeat this process for each device and browser that you use to access LIFELENZ Sites.

Contact: Please contact us for more information or to exercise a request regarding your US privacy rights. If you are concerned about LIFELENZ’s compliance with US laws relating to the privacy of your personal information, you may contact your Attorney General’s Office.

CHANGES TO OUR PRIVACY STATEMENT

We may make changes to our Privacy Statement or our supporting privacy procedures at any time.

From time to time, we may change or update this Privacy Statement. We reserve the right to make changes or updates at any time and without prior notice to you.

If we make material changes to the way we process your personal information, we will provide you notice by posting the most current version of this Statement on our Sites and we may also advise you of changes via our Services information, or by other communication channels, such as by email, newsletters or community post. Please review any changes carefully.

If you object to any changes and no longer wish to use our Services, you may close your accounts and cease use of our Services. All changes to our Statement are effective immediately upon posting and your continued interaction with us or your use of our Services after a posting of an updated Statement constitutes your consent to all changes.

HOW TO CONTACT US

If you have questions or comments about this Statement, you may contact us by email, direct mail or phone.

A. Email privacy@LIFELENZ.com is the fastest and most-preferred way to reach us with your data management or privacy-related questions and concerns.

B. Via Direct Mail:

LIFELENZ

Attn: Privacy Officer

Level 7, 200 Massachusetts Ave, NW Washington, DC 20001

C. Via Phone: +1 8559555885