AHEAD PRIVACY POLICY

Effective date/Last updated: November 15, 2023

AHEAD, Inc. (“AHEAD”, “we”, “us”, or “our”) operates https://www.ahead.com. This Privacy Policy (“Policy”) informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of our website and our services (collectively, the “Site”). This Policy also addresses rights you may have under the California Consumer Privacy Act of 2018 (“CCPA”) and EU General Data Protection Regulation (“GDPR”).

By using the Site, you agree to the collection and use of information in accordance with this Policy.

We may modify this Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.

What Information do we collect and how?

While using our Site, we may ask you to provide us with certain personal information that can be used to contact or identify you. Personal information may include, but is not limited to your name, email address, or phone number (“Personal Information”).

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”).

This Log Data may include information such as your computer’s Internet Protocol address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Site.

A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

We use Cookies to:

• make our Site function properly;
• provide personalized experiences;
• tailor our interactions with you;
• help with our marketing efforts;
• provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and
• help us improve our services.

The Cookies on our Site may collect information such as:

• the IP addresses assigned to the computers and other devices you use;
• your internet service provider;
• the device ID number;
• approximate geographic location;
• the Site pages visited or clicked on;
• the date and time you visited the Site, and the amount of time spent on the Site;
• your operating system, browser type, search requests, and other similar information;
• the websites you access before and after visiting the Site, and

 

• data related to how and when you use the Site.

We may combine information from Cookies with Personal Information, including data obtained from other sources.

A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over how information gathered by third-party Cookies is used by third parties.

Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the

functioning of the Site.

Google Universal Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site. You may opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We may also implement additional add-on services to Google Analytics, such as Google Tag Manager.

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses  data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

Online Behavioral Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.

We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.

We collect the following types of personal information when you apply for a job with AHEAD or during the course of your employment at AHEAD:

• Your name, address, email address, telephone number, and other contact information;

 

• Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
• Information from interviews you may have, if any;
• Details of the type of employment you are looking for, current and/or desired salary and other terms relating to compensation and benefits packages, and job preferences;
• Details of how you heard about the position you are applying for;
• Any sensitive and/or demographic information obtained during the hiring process such as gender, information about your citizenship and/or nationality, medical or health information, and/or your racial or ethnic origin;
• Reference information and/or information received from background checks (as applicable), including information provided by third parties;
• Information relating to any previous applications you may have submitted to AHEAD and/or any previous employment history with AHEAD;
• Information about your educational and professional background from publicly available sources that we believe is relevant to your application or a potential future application (g., your LinkedIn profile);
• Banking information for direct deposit purposes, income history and income information, and benefits information as well as information regarding your beneficiaries; and
• Information collected from you automatically when you use our website, while using an AHEAD device, or while connected to AHEAD’s Internet through cookies, web beacons, pixel tags, and other online tracking mechanisms.

We may use personal data for the following purposes:

As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

Administration. We use Personal Information for administrative purposes, such as managing accounts, facilitating transactions, to inform our business strategies, and to understand the Site’s demographics and user preferences.

Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

Advertising and Communications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Site, to notify you of changes to our Terms or this Policy, and for other similar communications. You may opt-out of marketing emails by using the unsubscribe link in the email or contacting us at privacy@ahead.com with “Unsubscribe” in the subject line. To opt-out of other communications, please contact us as set forth below. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your account or transactions

To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

Third Parties With Whom We Share Personal Information

We may share all categories of Personal Information listed above with the following categories of third parties and/or service providers:

 

Employees and Affiliates. We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.

Service Providers. We may share Personal Information with service providers that provide services for us. For example, we may share Personal Information with vendors to help us host and manage the Site; provide targeted advertising and other marketing; improve the content and functionality of the Site; perform data analysis and statistical analysis; and troubleshoot problems with the Site.

Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, AHEAD or any other party.

Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to AHEAD.

Change in Ownership. In the event (a) AHEAD is subject to a change of control, (b) the Site changes ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including as part of any due diligence process.

Other. We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

De-Identified or Aggregated Information

AHEAD may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. AHEAD is the sole and exclusive owner of such de-identified and aggregated information, including if AHEAD de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.

California Residents

This section applies to our use and collection of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act (as amended by the California Privacy Rights Act (“CCPA”). In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence for California residents. In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the CCPA.

We make the following disclosures related to Personal Information we have collected in the past 12 months.

 

 

 

Category of Personal Information	Collected (Y/N)	Category of Source from which Personal Information is Collected	Purpose of Collection	Third Parties to whom Personal Information is Disclosed for a Business Purpose	Third Parties to whom Personal Information is Sold or Shared	Retention Period
Identifiers	Yes	You and our business partners and service providers; cookies and other tracking technologies	To show you appropriate products and events	Business partners and service providers	We do not sell this category of personal information. However, we share this category of Personal Information with third parties for purposes of cross-context behavioral advertising	2 years
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Yes	You and our business partners and service providers	To engage and solicit business	Business partners and service providers	Business partners and service providers	7 years from last interaction.
Protected classification characteristics under California or federal law	No	N/A	N/A	N/A	N/A	N/A
Commercial information	Yes	You and our business partners and service providers	To better serve your needs	Business partners and service providers	We do not sell or share this category of Personal Information	7 years from last interaction.
Biometric information	No	N/A	N/A	N/A	N/A	N/A
Internet or other similar network activity	Yes	Cookies and other tracking technologies	To improve your viewing experience.	Business partners and service providers	We do not sell this category of personal information. However, we share this category of Personal Information with third parties for purposes of cross-context behavioral advertising	2 years
Geolocation data	No	N/A	N/A	N/A	N/A	N/A
Sensory data	No	N/A	N/A	N/A	N/A	N/A
Professional or employment-related information for applicants	Yes	You and our business partners and service providers	For hiring and human resource purposes	Service providers	We do not sell or share this category of Personal Information	3 years from the last interaction
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	No	N/A	N/A	N/A	N/A	N/A
Inferences drawn from other personal information	No	N/A	N/A	N/A	N/A	N/A
Sensitive Personal Information	No	N/A	N/A	N/A	N/A	N/A

 

If you are a California resident, you have the following rights:

 

Privacy Right	Description
Notice	The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access	The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability	The right to receive the Personal Information you have previously provided to us.
Erasure	The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
Correction	You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
Automated Decision Making	You have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. Ahead does not currently engage in any automated decision making practices.
To Opt Out of Sales or Sharing of Personal Information	You have the right to opt out of the “sharing” or “selling” of your Personal Information as those terms are defined by the CCPA. Please note that although we do not sell your Personal Information to our business partners, you often enter into a separate agreement and/or agree to terms by using their products and you may agree to share information with the business partner as well when you sign up for an event. To the extent that is true, their privacy policy shall apply.
Limit Use of Sensitive Personal Information	You have the right to limit the use of your sensitive Personal Information to only that which is necessary for providing products or services to you.

To exercise your California rights described in this section, you may submit your request to us by contacting us at privacy@ahead.com or submitting a request on the web form located here.

Verifiable Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you that complies with applicable law.

 

Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA.

Who May Exercise Your Rights? You may make a request to exercise your rights on behalf of yourself. In addition, you also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with AHEAD, and (c) directly confirm with AHEAD that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.

Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.

California’s “Do-Not-Track” Requirement. We currently do not respond to “Do Not Track” requests. Location of AHEAD

We are located entirely within the United States. We and our service providers may store information about individuals in the United States, or we may transfer it to, and store it within, other countries. Consumers from jurisdictions outside the United States visit us or use our services at their own choice and risk. If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction, and that we may store your personal information in the United States or elsewhere. Please note that the level of legal protection provided in the United States from which you may access our services may not be as robust as those protections provided under the privacy standards or the privacy laws of other countries, possibly including your home jurisdiction.

EU Residents

If you are located in the EU, you have certain rights under the GDPR with respect to your Personal Information, including the right to request access to, correct, and delete your Personal Information. You may also have the right to receive a copy of your Personal Information in a commonly used and machine-readable format, object to the processing of your Personal Information, and ask that we restrict the processing of your Personal Information in certain instances. Please note that Ahead does not market to EU residents except as permitted by an existing business relationship.

We primarily process Personal Information on behalf of and in accordance with the instructions of our customers, who may collect such information from you in the course of providing their services. Upon written request, with proper verification of identity at our sole discretion, we can promptly destroy, correct, amend and/or return to such verified consumer any and all Personal Information in our or our sub-processor’s control or possession, subject to our right to retain such information as deemed necessary to comply with legal obligations. We will use

commercially reasonable efforts to respond to such requests within thirty (30) days of receipt of such request and proper identity verification. All requests in this regard should be submitted via email to privacy@ahead.com or on the web form located here. Please note that not all requests can be honored.

When AHEAD processes your Personal Information, it has a legal basis for doing so as required under GDPR. AHEAD will only process Personal Information if: (i) it has received your express opt-in consent for such processing, (ii) the processing is necessary for performance of a contract, (iii) the processing is necessary for a legal obligation to which AHEAD is subject, (iv) the processing is necessary to protect the vital interests of the data subject, (v) the processing is necessary for a task carried out in the public interest, or (vi) if AHEAD or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the data subject. Personal Information that we receive may be transferred to and/or processed by third parties that are located outside of the EU. AHEAD will only transfer EU data subject’s Personal Information to third-parties located outside

 

of the EU when it has ensured appropriate safeguards for such personal data, such as the standard contractual clauses with such third party. You have the right to submit a GDPR complaint to your local data protection authority. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index en.htm.

Children’s Privacy

Our website is not directed to or intended to be used by individuals under the age of 16. We do not knowingly request or collect personal information from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has submitted personal information to us in connection with our website, and without prior verifiable parental consent, please email us at privacy@ahead.com or submit a request on the web form located here so that we can take steps to delete the personal information that she or he provided as required in accordance with applicable law.

Social Media

We are active on social media, including Facebook, Twitter, Instagram and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Site. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to protect your Personal Information, we do not guarantee its absolute security and you provide Personal Information at your own risk.

Privacy Information for Job Applicants

We use the personal information we collect from you as a job applicant for the following purposes:

• Managing the application process. We use your personal information to process your job application, verify the information you have provided in your application, communicate with you regarding your application, answer your questions regarding the application process, and confirm your eligibility for a position. We may also save your information for future job openings within AHEAD.
• Managing the hiring process. We may use your personal information in the hiring process to conduct interviews. We may also use your personal information to perform background and reference checks (with your consent) if you are offered a position.
• Communicating with you. We may use your personal information to provide information to you and respond to your questions.
• Managing recruiting. We may use personal information to communicate with you regarding the recruiting process, learn where you heard about AHEAD, and evaluate and improve our recruiting process.
• Maintaining records. We may use personal information to comply with applicable legally required or industry-standard business and employment recordkeeping requirements and to respond to governmental requests for information.
• Maintaining health and safety. We use this information to protect your health and safety or the health and safety of others, including through the use of technology to allow contact tracing if you may have been

 

exposed to communicable diseases such as COVID-19. We may also use this information to respond to an employee-related emergency.

We may share personal information we collect with third parties when requested or consented to by you or for the purposes described in this Notice.

• Third-Party Service Providers. AHEAD may share personal information with third-party service providers or suppliers (“Service Providers“) that include, without limitation, data storage providers, website or mobile application hosting providers, and e-mail service providers as needed to provide the applicable services to us. AHEAD will take steps to help ensure appropriate protections are in place before we share or disclose personal information with any Service Provider.
• Legal Requirements. We will cooperate with law enforcement and other governmental agencies. We may disclose personal information for the following legal purposes:
• If we believe in good faith we are legally required to disclose that personal information
• If we are advised to disclose personal information by our legal counsel
• When necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, AHEAD or any other party
• To protect our rights or property, protect your health and safety, or the health and safety of others
• To detect and investigate fraud or illegal activity, or to respond to a government request
• To respond to an emergency
• Professional Advisors. We may share personal information with our professional advisors, such as our attorneys and accountants, in their capacity as advisors, including for advice on potential or actual litigation matters.
• Change in Ownership. In the event AHEAD is subject to a merger, acquisition, or sale of its assets, we may provide personal information in connection with the proposed transaction, including information to the subsequent owner(s). If we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change of control or reorganization, personal information and other information could be one of the assets transferred to or acquired by a third party, or reviewed as part of the due diligence process.

AHEAD will only keep applicant and employee personal information for so long as it has a reasonable business purpose for doing so or where we are required to keep it by applicable law. To determine the appropriate retention period for personal information, we consider our statutory obligations, the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means.

If there is no activity in relation to the personal information, AHEAD may remove it from its systems, subject to its data retention obligations, policies, and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities.

If you wish to exercise a right, please contact privacy@ahead.com or submit a request on the web form located here. We will respond to any requests in accordance with applicable law, and there may be circumstances where we are not able to comply with your request.

If you have any questions or concerns regarding this Notice, please send an e-mail to privacy@ahead.com.

Changes to the Privacy Policy

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@ahead.com