Privacy Policy

Privacy Policy Foreword We, Jobortunity.ai UG (limited liability) (hereinafter: "the company," "we," or "us"), take the protection of your personal data seriously and would like to inform you about data protection in our company. Within the scope of our data protection responsibilities, the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR") has imposed additional obligations on us to ensure the protection of personal data of the data subject (we also refer to you as the data subject as "customer," "user," "you," or "data subject"). Insofar as we decide, either alone or jointly with others, on the purposes and means of data processing, this includes, in particular, the obligation to inform you transparently about the nature, scope, purpose, duration, and legal basis of the processing (cf. Articles 13 and 14 GDPR). With this declaration (hereinafter: "Privacy Policy"), we inform you about how we process your personal data. Our data protection information has a modular structure. It consists of a general section for all processing of personal data and processing situations that apply each time a website is accessed (Section A. General) and a specific section, the content of which refers only to the processing situation specified there with the name of the respective offer or product, in particular the visit to websites as described in more detail here (Section B. Visiting websites). Part B is relevant if you use our German website, including our social media presence. § 1 General (1) Definitions Based on

Art. 4 GDPR, this privacy policy is based on the following definitions: - "Personal data" (Article 4(1) GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, an online identifier, location data, or by reference to the physical, physiological, genetic, mental, economic, cultural, or social identity characteristics of that person. Identifiability may also be given by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings may also contain personal data). - "Processing" (Art. 4 No. 2 GDPR) is any operation involving personal data, whether with or without the aid of automated (i.e., technology-based) procedures. This includes, in particular, the collection (i.e., procurement), recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning, combining, restricting, erasing or destroying personal data, as well as changing the purpose or objective for which the data was originally processed. - "Controller" (Art. 4 No. 7 GDPR) is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. - "Third party" (Art. 4 No. 10 GDPR) is any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or processor, are authorized to process personal data; this also includes other legal entities belonging to the group. - "Processor" (Art. 4 No. 8 GDPR) is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with its instructions (e.g. IT service providers). In terms of data protection law, a processor is not a third party. - "Consent" (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. (2) Name and address of the controller The entity responsible for processing your personal data within the meaning of

Art. 4 No. 7 GDPR is us: Jobortunity.ai UG (limited liability) Seeweg 26, 83236 Übersee info@jobortunity.ai For further information about our company, please refer to the legal notice on our website. (3) Legal basis for data processing By law, any processing of personal data is prohibited in principle and is only permitted if the data processing falls under one of the following justifications: - Art. 6 (1) (a) GDPR ("Consent"): If the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unequivocal affirmative action that he or she consents to the processing of personal data relating to him or her for one or more specific purposes; - Art. 6 (1) (b) GDPR: If processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; - Art. 6 (1) (c) GDPR: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., a statutory retention obligation); - Art. 6 (1) (d) GDPR: If processing is necessary to protect the vital interests of the data subject or another natural person; - Art. 6 (1) (e) GDPR: If processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or - Art. 6 (1) (f) GDPR ("legitimate interests"): If processing is necessary for the purposes of the legitimate (in particular legal or economic) interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject (in particular where the data subject is a child). We indicate the applicable legal basis for each of the processing operations we carry out below. Processing may also be based on several legal bases. (4) Data deletion and storage period For the processing operations we carry out, we specify below how long the data is stored by us and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will only be stored on our servers in Germany, subject to any transfer in accordance with the provisions in A.(6) and A.(7).However, storage may continue beyond the specified period in the event of an (imminent) legal dispute with you or other legal proceedings, or if storage is required by legal regulations to which we are subject as the controller (e.g., Section 257 of the German Commercial Code (HGB), Section 147 of the German Fiscal Code (AO)). When the storage period prescribed by law expires, the personal data will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for this. (5) Data security We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties (e.g., TLS encryption for our website), taking into account the state of the art, implementation costs, and the nature, scope, context, and purpose of the processing, as well as the existing risks of a data breach (including its likelihood and impact) for the data subject. Our security measures are continuously improved in line with technological developments. We will be happy to provide you with further information on request. (6) Cooperation with processors If we use external service providers (e.g., for IT, logistics, telecommunications, sales, and marketing) to conduct our business, they will only act on our instructions and will be contractually obliged to comply with data protection regulations in accordance with

Art. 28 GDPR. (7) Requirements for the transfer of personal data to third countries Within the scope of our business relationships, your personal data may be transferred or disclosed to third-party companies. These may also be located outside the European Economic Area (EEA), i.e., in third countries. Such processing is carried out exclusively for the purpose of fulfilling contractual and business obligations and maintaining your business relationship with us. We will inform you of the respective details of the transfer in the relevant sections below. The European Commission certifies that some third countries have data protection standards comparable to those of the EEA through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data- protection/adequacy-decisions_en). In other third countries to which personal data may be transferred, however, there may not be a consistently high level of data protection due to a lack of legal provisions. Where this is the case, we ensure that data protection is adequately guaranteed. This can be achieved through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data, certificates, or recognized codes of conduct. (8) No automated decision-making (including profiling) We do not intend to use personal data collected from you for automated decision-making (including profiling). (9) Legal obligation to transfer certain data We may be subject to a specific legal or regulatory obligation to provide lawfully processed personal data to third parties, in particular public authorities (Art. 6 (1) (c) GDPR). (10) Your rights You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided in A.(2) above. As a data subject, you have the right: - request information about your data processed by us in accordance with

Art. 15 GDPR. In particular, you can request information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data, if it was not collected by us, and the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details; - to request the immediate correction of inaccurate data or the completion of your data stored by us in accordance with

Art. 16 GDPR; - to request the erasure of your data stored by us in accordance with

Art. 17 GDPR, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims; - to request the restriction of the processing of your data in accordance with

Art. 18 GDPR, unless the accuracy of the data is disputed by you or the processing is unlawful; - to receive your data that you have provided to us in a structured, commonly used, and machine-readable format or to request its transfer to another controller ("data portability") in accordance with Art. 20 GDPR; - to object to the processing in accordance with Art. 21 GDPR, provided that the processing is based on

Art. 6 (1) (e) or (f) GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either stop or adjust the data processing or point out to you our compelling legitimate reasons for continuing the processing; - in accordance with

Art. 7 (3) GDPR, your consent once given (even before the GDPR came into force, i.e. before May 25, 2018) - i.e. your voluntary, informed and unambiguous declaration of intent, made clear by a statement or other unequivocal confirmatory action, that you consent to the processing of the personal data concerned for one or more specific purposes - at any time, if you have given such consent. This means that we may no longer continue the data processing based on this consent in the future and - complain to a data protection supervisory authority about the processing of your personal data in our company in accordance with

Art. 77 GDPR. (11) Changes to the privacy policy As part of the ongoing development of data protection law and technological or organizational changes, our data protection information is regularly reviewed for the need for adjustments or additions.

§ 2 Visiting websites and using the contact form (1) Explanation of the function Information about our companies and the services we offer can be found in particular at jobortunity.ai and the associated subpages (hereinafter collectively referred to as "websites"). When you visit our websites, your personal data may be processed. (2) Processed personal data When you use the websites for informational purposes, we collect, store, and process the following categories of personal data: "Log data": When you visit our websites, a so-called log data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of: • IP address • Date and time of access • Access status/HTTP status code • Referrer URL • Browser type & version • Operating system • Device information (device, screen resolution) • Interactions • Session ID • Anonymized usage statistics "Contact form data": When you use contact forms, the data transmitted via these forms is processed (message text, email address, and time of transmission). In addition to the purely informational use of our website, we offer a subscription to our newsletter, which provides you with information about current developments in commercial law and events. If you subscribe to our newsletter, we collect, store, and process the following "newsletter data": - the page from which the page was requested (so-called referrer URL) - the date and time of the request - header of the web browser used - the IP address of the requesting computer, which is shortened so that it can no longer be traced back to a specific person - the email address - the date and time of registration and confirmation We transmit your email address and name to Mailchimp, Intuit Mailchimp 405 N Angier Ave. NE Atlanta, GA 30308, USA for the technical execution of email delivery. (3) Purpose and legal basis of data processing We process the personal data specified above in accordance with the provisions of the GDPR, other relevant data protection regulations, and only to the extent necessary. Insofar as the processing of personal data is based on

Art. 6 (1) (f) GDPR, the purposes mentioned also represent our legitimate interests. The processing of log data serves statistical purposes and the improvement of the quality of our website, in particular the stability and security of the connection (the legal basis is

Art. 6 (1) (f) GDPR). The processing of contact form data is carried out for the purpose of processing customer inquiries (the legal basis is

Art. 6 (1) (b) or (f) GDPR). The processing of newsletter data is carried out for the purpose of sending the newsletter. By subscribing to our newsletter, you consent to the processing of your personal data (legal basis is

Art. 6 (1) (a) GDPR). We use the double opt-in procedure for registration for our newsletter. This means that after you register, we will send an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. The purpose of this procedure is to verify your registration and, if necessary, to be able to clarify any possible misuse of your personal data. You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can revoke your consent by clicking on the link provided in every newsletter email, by sending an email to info@jobortunity.ai, or by sending a message to the contact details provided in the legal notice. (4) Duration of data processing Your data will only be processed for as long as is necessary to achieve the above- mentioned processing purposes; the legal bases specified in the context of the processing purposes apply accordingly. Third parties employed by us will store your data on their system for as long as is necessary in connection with the provision of services for us in accordance with the respective order. (5) Transfer of personal data to third parties; legal basis The following categories of recipients, which are usually processors, may have access to your personal data: - Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g., for data center services, payment processing, IT security). The legal basis for the transfer is then

Art. 6 (1) (b) or (f) GDPR, unless they are processors; - Government agencies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the transfer is then

Art. 6 (1) (c) GDPR; - Persons employed to carry out our business operations (e.g., auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the transfer is then

Art. 6 (1) (b) or (f) GDPR. Furthermore, we only disclose your personal data to third parties if you have given your express consent in accordance with Art. 6 (1) (a) GDPR.

§ 3 Registration and use of platform functions requiring registration On our platform, we offer users the opportunity to register by providing personal data. The data is entered into an input mask, transmitted to us, and stored. The data is not passed on to third parties. The following data is collected during the registration process: - Last name and first name - Email - Hash of the assigned password The following data is transmitted to us and stored when using the Job Tracker and Dashboard: - Saved job links - Notes on applications - Application status information - Uploads (resume, cover letter, letters of recommendation, etc.) The following data is transmitted to us and stored when you use the AI features: - Uploads (resume, cover letter, letters of recommendation, etc.) for resume/cover letter optimization - Prompt content This data is transferred to OpenAI, Inc. based in the USA for the purpose of generating an AI response. Please refer to the privacy policy - available at https://openai.com/de- DE/policies/row-privacy-policy/ - for information on data processing there. Data is transferred to Cloudinary for the purpose of processing and providing images. When using the upload function, the data contained in uploaded files is stored; this may include, in particular: • Name • Address • Education and career data The data collected during registration and platform use is used for the purpose of contract fulfillment in accordance with Art. 6 (1) (b) GDPR.

§ 4 Hosting and backend services (1) Website hosting We use Vercel Inc. as our hosting and deployment platform for operating our website. The following personal data is processed in this context: • IP addresses • Server logs (access logs, timestamps, status messages) • Browser data (user agent, browser type, operating system) Processing takes place on servers in the EU and/or the US, depending on the region setting. Vercel uses content delivery networks (CDN) worldwide to deliver our website. Insofar as data is transferred to the US, Vercel Inc. is certified under the EU-US Data Privacy Framework (DPF) and has committed to complying with European data protection standards. The machine-readable (JSON) data set for Vercel Inc.'s DPF certification is available at https://dpfapi.azurewebsites.net/api/participants/6847. Processing is based on

Art. 6 (1) (f) GDPR (legitimate interest). Our legitimate interest lies in the technical provision of our website. Vercel's privacy policy is available at https://vercel.com/legal/dpa. Server logs are usually deleted automatically after 30 days. Session data is removed after the session ends. You can assert your rights as a data subject against Vercel Inc. Contact: privacy@vercel.com or via the EU data protection representative: c/o EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium. (2) Database hosting We use the database hosted by MongoDB Inc., 1633 Broadway, Fl 38, New York, NY 10019, USA, to operate our platform. MongoDB Inc. is certified under the EU-U.S. Data Privacy Framework (DPF) and has committed to complying with European data protection standards. The machine-readable (JSON) data set for MongoDB, Inc.'s DPF certification is available at https://dpfapi.azurewebsites.net/api/participants/5847. MongoDB Inc. uses Amazon Web Services EMEA SARL, 38 Av. John F. Kennedy, L-1855 Luxembourg, and Amazon Web Services, Inc., 410 Terry Ave North, Seattle, Washington 98109, USA, as subcontractors. Amazon Web Services, Inc. is certified under the EU-U.S. Data Privacy Framework (DPF) and has committed to complying with European data protection standards. The machine- readable (JSON) data set for the DPF certification of Amazon Web Services, Inc. is available at https://dpfapi.azurewebsites.net/api/participants/5776. The physical database infrastructure is located in the AWS data center in Frankfurt, but data may be transferred to data centers in the US. The following data is transferred to these companies: • Account data (name, email, login information) • Usage data in the job tracker (saved jobs, notes, status, documents) • Document metadata (references) Processing is based on

Art. 6 (1) (f) GDPR (legitimate interest). Our legitimate interest lies in the technical provision of our website. (3) Image hosting and image processing with Cloudinary We use the services of Cloudinary Inc., Suite 220, 6201 America Center Dr, San Jose CA 95002, USA, to store, manage, and optimize user-uploaded documents and media content (e.g., resumes, cover letters, letters of recommendation, PDF files). Cloudinary is a US company. Cloudinary Inc. is certified under the EU-U.S. Data Privacy Framework (DPF) and is committed to complying with European data protection standards. The data you upload is processed and stored by Cloudinary on AWS (Amazon Web Services) servers, which may be located anywhere in the world, including the USA. When using the upload function, the following personal data is transmitted to Cloudinary and processed: • Personal data contained in files uploaded by the user, in particular: • First and last name • Address • Phone number and email address • Education and career data • Other personal data embedded by the user • Metadata of uploads (file name, file type, size, upload timestamp) • User's IP address Data is transferred to the USA. Cloudinary processes data for the following purposes: • Storing and managing uploaded documents • Optimizing and converting files (e.g., previews, thumbnails) The legal basis is

Art. 6 (1) (b) GDPR (fulfillment of the contract for use of the platform). Our legitimate interest (Art. 6 (1) (f) GDPR) lies in the efficient provision of a reliable cloud infrastructure.

§ 5 Use of cookies and plugins on our website (1) Cookies We use cookies on our websites. Cookies are small text files that are stored on your device by the browser you are using and that contain a characteristic string of characters through which certain information is transmitted to the entity that sets the cookies. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offering more user-friendly and effective overall, i.e., more pleasant for you. Cookies may contain data that enables the device used to be recognized. In some cases, however, cookies only contain information about certain settings that are not personally identifiable. Cookies cannot directly identify a user. A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored on your device beyond the individual session. In terms of their function, cookies are divided into: - Technical cookies: These are essential for navigating the website, using basic functions, and ensuring the security of the website; they do not collect information about you for marketing purposes, nor do they store which websites you have visited. - Performance cookies: These collect information about how you use our website, which pages you visit, and, for example, whether errors occur when using the website; they do not collect any information that could identify you— all information collected is anonymous and is only used to improve our website and find out what interests our users; - Advertising cookies, targeting cookies: These are used to offer website users tailored advertising on the website or offers from third parties on the website and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months; - Sharing cookies: These are used to improve the interactivity of our website with other services (e.g., social networks); sharing cookies are stored for a maximum of 13 months. Any use of cookies that is not technically necessary constitutes data processing, which is only permitted with your express and active consent in accordance with

Art. 6 (1) (a) GDPR. This applies in particular to the use of advertising, targeting, or sharing cookies. Furthermore, we only pass on your personal data processed by cookies to third parties if you have given your express consent in accordance with

Art. 6 (1) (a) GDPR. (2) Cookie settings For more information about which cookies we use and how you can manage your cookie settings and disable certain types of tracking, please refer to our cookie settings. (3) Social media plugins We use social media plugins from TikTok, LinkedIn, and Instagram on our websites. The operators of these platforms process personal data from visitors to our websites. These social media plugins collect the following data: • Your IP address • HTTP header of your browser Data collected by social media plugins is transferred to the USA. Further information on data processing and your rights as a data subject can be found in the privacy policies of the respective providers: The privacy policy of TikTok Technology Limited can be found at https://www.tiktok.com/legal/page/eea/privacy-policy/de. If you have any questions about data protection, you can contact TikTok Technology Limited, 10 Earlsfort Terrace, Dublin D02 T380, Ireland. Contact form for data protection inquiries: https://www.tiktok.com/legal/report/privacy. The privacy policy of LinkedIn Ireland Unlimited Company can be found at https://de.linkedin.com/legal/privacy/eu. If you have any questions about data protection, you can contact LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Contact form for data protection inquiries: https://www.linkedin.com/help/linkedin/ask/ppq. The privacy policy of Meta Platforms Ireland Limited (operator of Instagram) can be found at https://help.instagram.com/155833707900388. If you have any questions about data protection, you can contact Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. (4) Analytics Tools We use Vercel Analytics on our website to analyze visitor numbers and user behavior. The data available to Vercel as a host is processed for this purpose. In this regard, please refer to § 4(1) (Website Hosting).

§ 6 Technical and organizational measures For security reasons and to protect the transmission of personal data and other confidential content (e.g., inquiries via contact forms, login data, uploaded documents), our website uses SSL or TLS encryption (Secure Sockets Layer / Transport Layer Security). You can recognize an encrypted connection by the fact that the address line of your browser displays the prefix "https://" instead of "http://" and by the lock symbol in the address line of your browser. Data transmission between us and the service providers we use is also encrypted. Our TLS encryption is based on digital certificates issued by trusted certification authorities. These certificates confirm the identity of our website and enable encrypted communication. Your browser automatically checks the validity of the certificate each time you visit the site. If the certificate is invalid or has expired, you will receive a security warning from your browser. In such a case, you should not transmit any personal data and should inform us using the contact details in the legal notice.