Platform Privacy Policy

Effective date: October 1, 2025

At Findem, Inc. (“Findem,” “we,” “us,” “our,” or the “Company”), your privacy is important to us. Please read this Privacy Policy to learn how we treat your personal data.

Findem is a talent acquisition and recruitment platform designed to help organizations identify both internal and external candidates for employment, ensuring they find the best fit for each position. To do so, Findem works with organizations to discover candidates from within their existing network (“ATS Candidate Data”) or source business contact and other information related to individuals’ professional or employment background (“Copilot Candidate Data”) to match qualified candidates with open positions quickly and compliantly. 

By using or accessing our candidate sourcing platform and associated app that cites to this Privacy Policy (the “Platform”), you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Platform Privacy Policy. 

In the ordinary course of making these Services available, we process ATS Candidate Data about individuals at the direction of our customers. In those cases, we are a service provider and our processing of that data is governed by the agreement in place between us and the applicable customer. The customer’s privacy policy or other agreement between the customer and you or your organization, and not this Privacy Policy, applies to such processing. Where that is the case, please contact the relevant customer, and not Findem, in the first instance to address your rights with respect to such data.

And remember that your use of Findem’s Services is at all times subject to our Terms and Conditions which incorporates our Privacy Policies, or the agreement in place between us and the applicable customer. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Platform Privacy Policy by clicking here.

For a complete description and additional details related to our privacy practices, please read on below.

Privacy Policy Table of Contents

• What this Privacy Policy Covers
• Personal Data
  
  • Categories of Personal Data We Collect
  • Categories of Sources of Personal Data
  • Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
• How We Disclose Your Personal Data
• Tracking Tools, Advertising and Opt-Out
• Data Security
• Data Retention
• Personal Data of Children
• US State Privacy Rights
• Exercising Your Rights under US State Privacy Laws
• Other State Law Privacy Rights
• European Union and United Kingdom Data Subject Rights
• Modification to our Privacy Policy
• Contact Information

What this Privacy Policy Covers

As stated above and described herein, this Privacy Policy applies only to the information collected from users of the Platform (“Platform Users”) or Copilot Candidate Data. This Privacy Policy does not apply to personal data collected when using or accessing our public-facing corporate website, findem.ai (the “Website”) and other related activities or interactions as set forth in our Website Privacy Policy, available here. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. Unless specified, the term Personal Data as used herein refers to the Personal Data of both Platform Users and Copilot Candidate Data. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months regarding Platform Users:

*Findem makes probabilistic inferences of Candidate Demographic Data to generate aggregate-level statistics that customers can use in assessing their own recruiting practices, including to identify areas of over- or under-representation in their pipelines. Findem does not make Candidate-level gender or ethnicity inferences available to customers or otherwise sell such data.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

• When you provide such information directly to us:
  
  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
• When you use the Services and such information is collected automatically:
  
  • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
  • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Public Records

• From the government or other sources.

Third Parties

• Vendors
  
  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  • We may use vendors, including data brokers, to obtain information to generate leads and create user profiles.
• Advertising Partners
  
  • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
• Social Networks
  
  • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
• Other
  
  • We also license data from third parties that is collected from publicly-available sources around the internet and, in some cases, collect such data ourselves.

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you with the products, services or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Marketing the Services

• Marketing and selling the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Findem or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Findem or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants, Vanta and TAC Security, for compliance and auditing purposes.
• Support and customer service vendors.
• Payment processors.
  
  • Our payment processing partner, Stripe, Inc, which collects your voluntarily-provided payment card information necessary to process your payment.
  • Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners. These parties partner with us in offering various services. They include:

• Organizations seeking to match qualified candidates with open positions quickly and compliantly.
• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate

• Third parties you access through the services.
• Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking here:

‍

To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Session Replay Technology

We may use session replay technology in order to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology. If you would like to change your settings with respect to session replay technology, use the privacy or security settings in your web browser (often found under “Privacy,” “Security,” or “Cookies”).

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain Platform User profile information and credentials for as long as you have an account with us. 
• We retain Platform User payment data for as long as we need to process your purchase or subscription. 
• We retain Platform User device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
• We retain Copilot Candidate Personal Data for a reasonable period consistent with our legitimate interest in making such data available to organizations seeking to identify external candidates for employment.

Personal Data of Children

We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@findem.ai.

U.S. State Privacy Rights

If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the ‘Exercising Your Rights under U.S. State Privacy Laws’ section below for instructions regarding how to exercise these rights. Please note that your rights may be subject to certain conditions or exceptions in accordance applicable U.S. State Privacy Laws. 

With the exception of the California Consumer Privacy Act, many U.S. State Privacy Laws do not apply to individuals where they are acting in a commercial or employment context. As a result, these laws may have limited applicability to Findem’s processing and use of Copilot Candidate Data related to residents of such states where these laws are in effect. Nevertheless, Findem is committed to ensuring users’ privacy choices are honored and, as such, allows residents of any state—regardless of how such states’ laws are scoped—to exercise their privacy rights as detailed in this Platform Privacy Policy (subject to applicable exceptions). 

If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@findem.ai.

Access

You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to which we has disclosed your Personal Data.

Deletion

You may have the right to request that we delete the Personal Data that we have collected about you.

Correction

You may have the right to request that we correct any inaccurate Personal Data we have collected about you.

Portability

You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

"Selling" or "Sharing," Personal Data

Depending on your state of residence, you may have the right to opt out from the “sale,” “share,” or disclosure of your Personal Data for the purposes of targeted advertising. These or similar terms may be defined differently depending on the applicable U.S. State Privacy Law. 

You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

Over the past 12 months, we have sold or shared the categories of Personal Data we collect regarding Copilot Candidates (excluding Gender and Ethnicity Data, as detailed above) to Business Partners for the business and commercial purpose of helping organizations identify both internal and external candidates for employment. 

To our knowledge, we do not sell or share the Personal Data of minors under 18 years of age.

Processing of Sensitive Personal Data

*Findem makes probabilistic inferences of Candidate Demographic Data to generate aggregate-level statistics that customers can use in assessing their own recruiting practices, including to identify areas of over- or under-representation in their pipelines. Findem does not make Candidate-level gender or ethnicity inferences available to customers or otherwise sell such data. We do not collect Sensitive Personal Data including Personal Data from a known child under 13 years of age.

Automated Decision Making and Profiling

Depending on the state of your residence, you may have the right to opt-out the use of automated decision-making technology or from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable. However, we do not process your Personal Data in this manner.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy laws.  We will not deny you our services, charge you different prices or rates, or provide you a lower quality of service if you exercise your rights under applicable privacy laws.

Other State-Specific Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@findem.ai.

Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Exercising Your Rights Under U.S. State Privacy Laws

To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Opt-Out of Sale, Share, and/or Targeted Advertising

You have the right to opt-out of the sharing of your Personal Data. You can opt-out using the following methods:

• You can complete the online form found here: Do Not Sell or Share My Personal Information.
• You can email us at privacy@findem.ai
• You can use a Global Privacy Control or similar control that is legally recognized by a government agency or industry standard. Please note this does not include Do Not Track signals.

Request to Access, Delete, Correct

As applicable, you may submit a Valid Request for your right to access, delete, correct, or obtain a copy of your Personal Data described in this Privacy Policy by using the following methods:

• Email us at privacy@findem.ai 
• Call us at 650-399-3628
• Submit a form at this address: https://www.findem.ai/do-not-sell-or-share-my-personal-information

If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey Oregon, or Texas resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Appealing a Denial

If you are a Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods: 

• Email us at: privacy@findem.ai (title must include “[STATE OF RESIDENCE] Appeal”)
• Call us at: 650-399-3628

If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia.

Public disclosures: The Delete Act of 2023, SB 362

Compile the number of requests to delete, to know, to access, to opt-out of sale or sharing, or to limit the use of a consumer’s personal information that the data broker received, complied with in whole or in part, and denied during the previous calendar year.

• Total data subject requests received in 2024: 318,521
• Data subject requests complied with in 2024: 63,441
• Data subject requests unable to be processed due to insufficient data in 2024: 255,080
  

Compile the median and the mean number of days within which the data broker substantively responded to requests to delete, to know, to access, to opt-out of sale or sharing, or to limit the use of a consumer’s personal information that the data broker received during the previous calendar year.

• Median days to respond: 1
• Mean days to respond: 9
  

Specify the number of requests in which deletion was not required in whole, or in part, under each provision in California Civil Code section 1798.145 or 1798.146.

• N/A

European Union and United Kingdom Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.  

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Findem will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@findem.ai.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• ‍Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms and Conditions with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
  
  • Platform Users
    
    • User Data
    • Payment Data
• ‍Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
  
  • Platform Data
    
    • User Data
    • Device/IP Data
    • Web Analytics
    • Geolocation Data
    • Other Identifying Information that You Voluntarily Choose to Provide
  • Copilot Candidates
    
    • Profile or Contact Data
    • Demographic Data
    • Professional or Employment-related Data
    • Social Media Account Data
    • Inferences Drawn from Other Personal Data Collected
    • We may also de-identify or anonymize Personal Data to further our legitimate interests.
  • Examples of these legitimate interests include (as described in more detail above):
    
    • Providing, customizing and improving the Services.
    • Marketing the Services.
    • Corresponding with you.
    • Meeting legal requirements and enforcing legal terms.
    • Completing corporate transactions. ‍
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.‍
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@findem.ai. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. If you are a customer, you can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. If you are a customer, you can also correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.‍
• Right to File Complaint: You have the right to lodge a complaint about Findem’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Findem and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Findem in the U.S. and will be hosted on U.S. servers, and you authorize Findem to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

Modifications to our Privacy Policy

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Findem website, in the Platform, or by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• 650-399-3628
• https://www.findem.ai
• privacy@findem.ai
• 702 Marshall Street, Redwood City, CA 94063

If you are located in the EU or UK, you may use the following information to contact our Data Protection Officer and our EU or UK-Based Member Representative:

• European Union Representative: George Barry, 4 St Christopher's Rd, Montenotte, Cork, T23 E9TR, Ireland
• UK Representative: S. Alec Lawton, Graigwen, Plasycoed road, Pontypool Torfaen, NP4 6QH, UK