California Privacy Notice

Effective Date: 14 November, 2024

Your privacy is important to us and maintaining your trust is our priority. Poplar Technologies Ltd. (“Breakroom,” "we," "our," or "us") operates the Breakroom website and services (the “Site”) and is committed to protecting your personal information through our compliance with this California Privacy Notice (“Privacy Notice”).

This Privacy Notice supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (”consumers” or “you”) and use our Site. We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Capitalized terms used but not otherwise defined herein or in the CCPA shall have the meanings given to such terms in the Privacy Policy. You can download a PDF version of this Privacy Notice here.

1. Types of Users

The personal information we collect depends on how you use or interact with our Site. Table 1 below indicates the general types of consumer users of our Site (“Users”).

Table 1 - Types of Users

NOTE: Breakroom has not collected any of the following categories of personal information from consumers within the last twelve (12) months:

• Biometric information (such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data).
• Non-public education information, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
• Other sensitive personal information, as defined in the CCPA, that is not otherwise identified above (for example, in the preceding twelve (12) months, we have not collected precise geolocation, genetic data, or personal information concerning a consumer’s health, sex life, or sexual orientation).

b. Non-Personal Information Collected

Breakroom collects, uses and discloses de-identified and/or aggregated consumer information, which is not considered personal information. Deidentified or aggregated data may be derived from your personal information, but is not considered personal information under CCPA, since it does not directly or indirectly reveal your identity. For example, we may aggregate your Internet or other similar network activity to calculate the percentage of Users accessing a specific Site feature. To the extent that Breakroom collects consumer information that is in de-identified form, we will maintain and use the information in de-identified form and not attempt to re-identify the information.

c. Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you take the quiz or survey, fill in forms, create an account, submit your resume/CV, or correspond with us by post, phone, e-mail or otherwise.
• Indirectly from you. For example, through automated technologies or your interactions with us, including from observing your actions when you use our Site.
• From Your Company. If your company is a paying Employer, we may receive personal information about you from your company for purposes of setting you up with a User account on our Site.
• Third Parties. We may receive personal information about you from various third parties, such as data analytics providers, advertising networks, or other third parties that you direct to disclose information to us. For non-users that operate in or work at a business (“Prospective Business Customers”), we also receive Business Information and Contact Data from third-party sources.

3. Our Business or Commercial Purposes for Collecting, Selling, or Sharing Personal Information

a. Purposes for Collecting or Using Your Personal Information

We describe in detail in our Privacy Policy the context in which your personal information may be collected, along with how and why we use your personal information. Pursuant to the CCPA, we may use the personal information we collect from Users for one or more of the following business or commercial purposes:

• To allow you to take the Breakroom quiz, provide you with a Breakroom rating for your job, and contribute to an aggregated Breakroom rating.
• To fulfill or meet the reason for which the personal information is provided. For example, if you provide your personal information to create an account, we will use that information to create your account.
• To create, maintain, manage, customize, and/or secure your account with us.
• To communicate with you about your account or our Site, and to manage our relationship with you.
• To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitor and improve our responses.
• To send you email job alerts, if you registered to receive job alerts.
• To send you newsletters and marketing communications (where you have asked us to or where permitted, and you have not otherwise opted out).
• To maintain certain pieces of your information on a suppression list, if you’ve indicated to us that you don’t want to be communicated in a particular way.
• To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email (with your consent, where required by law).
• To enable our Site to function properly (ensure proper display of content), create and remember your account login details, and for interface personalization, such as language, or any user-interface customization.
• To provide, support, personalize, and develop our Site and services.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing or collections, or manage payment disputes or issues with the Site or services.
• To help maintain the safety, security, and integrity of our Site, databases and other technology assets, and business.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• For testing, research, analysis, and product development, including to collect statistics and develop and improve our Site or services.
• For debugging to identify and repair errors that impair existing intended functionality of our Site or services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• In connection with or during negotiations of any proposed or actual financing, merger, purchase, sale, sale or transfer of some or all of our assets or stock, joint venture, or any other type of financing, acquisition or business combination of our company, or all or any portion of our assets, or transfer of all or a portion of our business to another company, including without limitation in the event of a divestiture, restructuring, reorganization, dissolution or other event, whether as an ongoing concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.

We may collect or use your sensitive personal information only as necessary to perform the services or provide the goods reasonably expected by an average consumer, or as otherwise permitted by the CCPA. Specifically, we collect or use your sensitive personal information for the following purposes:

• For all Users with an Account, where we collect an account log-in, this information is used to permit you to access your Breakroom User Account, authenticate you as a User, and for other security-related purposes.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

b. Purposes for Selling or Sharing Your Personal Information

We may sell or share your personal information for the following business or commercial purposes:

• To deliver targeted offers and advertisements about Breakroom’s Site and services through third-party sites, including retargeting, third-party segment creation, and frequency capping.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, measuring ad performance, conducting ad fraud detection, recording on ad viewability, and auditing compliance.

We do not sell or share any sensitive personal information, and do not have actual knowledge that we sell or share personal information of consumers under 16 years of age.

4. How We Disclose Your Personal Information

a. Disclosures of Personal Information at Your Direction

We disclose your personal information when you intentionally interact with third parties and when you direct us or intentionally use Breakroom to disclose your personal information in connection with the services that we provide to you. For example:

• If you are a Job Seeker and apply to a job posting on our Site, we will disclose your personal information to that prospective employer and/or its agent of the job to which you applied.
• We will also disclose your personal information for any purpose authorized by you when you provide us with the information or otherwise choose to participate in new features and functions available through the Site.

Pursuant to the CCPA, in the preceding twelve (12) months, we may have disclosed the following categories of personal information at your direction, depending on the information that you include in your Breakroom job seeker profile, resume/CV, and/or job application materials:

• Category A: Identifiers
• Category B: California Customer Records personal information categories
• Category C: Protected classification characteristics under California or federal law
• Category F: Geolocation data
• Category H: Professional or employment-related information

b. Disclosures of Personal Information for a Business Purpose

We describe in detail in our Privacy Policy the context in which your personal information may be disclosed to a third party. Table 3 below identifies the categories of personal information disclosed to third parties, service providers, or others for a business purpose in the preceding twelve (12) months.

In addition, Breakroom may disclose any or all of the personal information identified in the categories above to the following categories of third parties for a business purpose, depending on how you interact with our Services and/or where Breakroom has an obligation to make such disclosure:

• Social networks, where you interact with such parties directly.
• Third party partners that are integrated into our Services, where you interact with such partners directly or indirectly.
• Government entities, where required by law or in order to comply with our legal or regulatory obligations.
• Other third parties, where required by law or in order to protect our rights, or the rights of our customers or others.
• Third parties, in connection with a merger, sale, or asset transfer.
• Third parties, where you have expressly consented to the disclosure of your personal information.

Additional information concerning the above disclosures, and the context in which your personal information may be disclosed to these categories of third parties, can be found in Section 7 of our Privacy Policy.

Breakroom does not use or disclose sensitive personal information, except as necessary to perform the services or as otherwise permitted by the CCPA (as detailed further in this Privacy Notice).

c. Sale or Sharing of Personal Information

Your privacy is our priority, and we do not monetize your personal information by selling it to third parties.

After you visit our Site, you may receive targeted advertisements about Breakroom when you visit other websites (i.e., social media sites, search engines or other websites that are unrelated to Breakroom) (collectively, “Other Websites”). This happens because we use third-party vendors to provide you with information about Breakroom based upon your interactions with our Site. We also place third-party cookies, scripts and other tracking technologies on our Site to track your interactions with Breakroom ads placed on Other Websites.

These third-party vendors may additionally collect certain personal information about you through cookies and other tracking technologies (see our Cookie policy for more information). These third-party vendors may work with additional downstream providers in their relationship network that assist the third-party vendor in providing the advertising services to us. When personal information is disclosed by Breakroom in the manner described above, it may constitute a “sale” or “sharing” of personal information under the CCPA.

Pursuant to the CCPA, we may sell or share, and in the preceding twelve (12) months we have sold or shared, the following categories of personal information for the purpose of showing you ads about Breakroom:

• Category A: Identifiers
• Category B: California Customer Records personal information categories
• Category E: Internet or other similar network activity
• Category F: Geolocation data

In this limited context, we may sell or share each of the categories of personal information listed above with the following categories of third parties:

• Third-party advertising partners or advertising networks

The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless they provide you explicit notice and an opportunity to opt-out of further sales.

Breakroom does not sell or share any sensitive personal information, and does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.

5. Your Consumer Rights

The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise them. These rights are not absolute and certain exceptions apply under the CCPA.

If you are a California resident, and the CCPA does not recognize an exception that applies to you, your personal information, or our processing of such information, you will have the rights identified in Table 4 below.

Table 4 - Consumer Rights

6. How to Exercise Your Consumer Rights

We have designed a number of tools to help give you more control over your personal information. To exercise a CCPA consumer right as described above, you can use one of the self-serve tools described below, or otherwise submit a verifiable consumer request to us by emailing hello@breakroom.cc. Additional details are provided below.

a. Correcting Inaccurate Information

If you would like to correct any inaccurate personal information that we hold about you, you may send an email to hello@breakroom.cc. To submit a verifiable consumer request via email, you must email us from the email address that is associated with your User Account, and identify what personal information we maintain that is inaccurate and which you are unable to correct.

b. Accessing Your Personal Information

You may send an email to hello@breakroom.cc if you would like to access a copy of your personal information or obtain a copy of your personal information in a portable manner. To submit a verifiable consumer request via email, you must email us from the email address that is associated with your User Account. If you are requesting access to categories and/or specific pieces of your personal information, you will be asked to provide identifying information that enables us to verify your identity with information in our system. Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems.

c. Deleting Your Personal Information

For Job Seeker Accounts: If you are a Job Seeker and would like to delete your Job Seeker account (including the personal information associated with your account), you may log in to your account on the Site, visit the “Your account settings” page, and click “Delete account”. We consider requests made through your account on the Site sufficiently verified when the deletion request relates to that specific account.

For Employer Accounts: If you are an Employer and would like to delete your Employer account (including the personal information associated with your account), you may send an email to hello@breakroom.cc directly from the email address associated with the account.

Send Us an Email with Your Request: All Users may send an email to hello@breakroom.cc with their deletion request. To submit a verifiable consumer request via email, you must email us from the email address that is associated with your User Account or use of the Site. We may ask you to provide identifying information that enables us to verify your identity with information in our system. Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems.

d. Opting Out of the Sale or Sharing of Your Personal Information

For more information, or to submit an opt-out request, you (or your authorized representative) may visit our Your Privacy Choices page or email your request to hello@breakroom.cc. You do not need to create an account with us to exercise your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request.

You may also use an opt-out preference signal, such as the Global Privacy Control (GPC), to opt-out of the sale and sharing of your personal information in accordance with the CCPA. If you use the GPC, your request to opt-out of the sale and sharing will be linked to your browser identifier only. It will not be linked to your email address (where applicable). If you would like us to make the connection between your browser and your email address, and you have not yet opted out of the sale or sharing of your personal information, please visit the Your Privacy Choices page, noted above.

e. Making a Verifiable Consumer Request

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account on the Site sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Using an Authorized Agent: If you use an authorized agent to submit a consumer request, the authorized agent must provide documentation or other proof indicating that they are authorized to act on your behalf. For requests to correct, access or delete personal information, we may require you to verify your identity directly with us (for example, by emailing us directly from the email address associated with your User account), and directly confirm with us that you provided the authorized agent permission to submit the request. If you are an authorized agent, you may make a request by emailing hello@breakroom.cc and providing documentation or other proof indicating that you are authorized by the consumer to act on their behalf. The authorized agent must provide documentation necessary (as determined in our discretion) to verify the agent has authority to act on the consumer's behalf in relation to CCPA requests.

Limitations on CCPA Requests: You may only make a verifiable consumer request to know or for access twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Metrics: Metrics related to CCPA requests received during the previous calendar year will be available here.

f. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing (email suffices). The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data access requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the verifiable consumer request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

g. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Retention of Personal Information

Different retention periods apply for different types and categories of personal information. Table 5 below identifies the criteria used to determine the length of time Breakroom intends to retain each category of personal information. Once you request that we delete your personal information, we will do so except where we are otherwise permitted or required to retain that information in accordance with applicable laws and regulations.