Privacy Policy

At WorkUp, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, 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 Privacy Policy. Some of our practices require your affirmative consent in addition to notice. Where this is the case, we will request your consent through in-product prompts or other clear mechanisms. You may withdraw consent at any time as described in the State Law Privacy Rights section.

WorkUp's Services are intended for users aged 13 and up. By using WorkUp you represent and warrant that you are at least 13 years of age. If you're under the age of 18, you may only use the Services and disclose information to us with your parent's or guardian's consent.

Remember that your use of WorkUp's Services is at all times subject to our Terms of Use, which incorporate this Privacy Policy. 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 Privacy Policy by clicking here.

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 WorkUp website, and will notify or obtain consent to the extend required by law. 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.

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 Purpose for Processing Personal Data
• How We Disclose Your Personal Data
• Personal Data of Children and Teens
• Tracking Tools and Opt-Out
• Automated Decision-Making and AI Inferences
• Data Security
• Data Retention
• Your Choices
• State Law Privacy Rights
• Changes to this Privacy Policy
• Contact Information

What this Privacy Policy Covers

This Privacy Policy covers our practices and the practices of service providers we engage to process Personal Data on our behalf. We require our service providers to handle Personal Data in accordance with contractual restrictions and applicable law. This Privacy Policy does not cover the practices of third parties to whom you navigate or whose services you access independently (for example, social networks, healthcare institutions you apply to, or third-party websites linked from our Services). This Privacy Policy does not apply to personal data we process on behalf of third parties. Those parties are governed by their own privacy policies, which we encourage you to review.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect:

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, SMS or text message, or otherwise contact us.
• When you use the Services and such information is collected automatically.
• Through Cookies (defined in the "Tracking Tools and Opt-Out" section below).
• If you use a location-enabled browser, we may receive information about your location.

Partners

• Employers
• When you apply for employment with a partner and you have opted in to receiving communications related to career opportunities
• When you are participating in educational programming with a partner and you have opted in to receiving communications related to career opportunities

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.
• Social Networks
• If you sign in to the Services using a third-party social network (such as LinkedIn) or connect your social network account to your WorkUp account, we may receive specific data from that social network, including but not limited to name, email, work history, education history, and professional skills. We refresh this data when you re-authenticate. You may disconnect your social network account at any time through your account settings. Disconnection stops future imports but does not automatically delete data previously imported; to request deletion of imported data, see the State Law Privacy Rights section.

Our Purposes for Processing Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.
• 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.
• Conducting fraud protection, security and debugging.
• Connecting Talent and Healthcare Institutions on the Services.
• 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 WorkUp 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, WorkUp or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

Use of AI. We use Personal Data and Usage Data to operate, evaluate, and improve our AI-powered features, and to train, develop, fine-tune, and evaluate our AI models. All Personal Data used for AI training is deidentified and anonymized in advance. You may opt out of having your anonymized deidentified Personal Data used for AI model training through your account settings or by contacting support@workup.health, without affecting your ability to use the Services. For more detail on the AI features that rely on your data, see the AI Model Training provisions in our Terms of Use.

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.

How We Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section.

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.
• Support and customer service vendors.

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:

• Healthcare Institutions that use WorkUp as a workforce development resource.
• Healthcare Institutions and other entities that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access, or Authenticate

• Third parties you access through the services.
• Social media services.

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

If we are involved in a bankruptcy or sale of some or all of our assets, your Personal Data may be transferred to the successor entity. We will provide you with notice before your Personal Data is transferred if and as required by law, and you will retain the right to delete your account before the transfer is consummated, subject to applicable law. AI models trained in whole or in part on user data may be transferred as part of the business; we will require the successor to honor the privacy commitments in this Policy with respect to data embedded in those models.

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, train models, and promote our business, provided that we will not share such data in a manner that could identify you.

Personal Data of Children and Teens

Personal Data of Children. WorkUp's Services are intended for users aged 13 and up. We do not knowingly collect, use, or share Personal Data from children under 13 years of age, and we do not permit children under 13 to register for the Services. If we learn that we have collected Personal Data from a child under 13, we will delete that information as soon as reasonably possible. If you are a parent or guardian and believe a child under 13 has provided us with Personal Data, please contact us at support@workup.health.

Users age 13 to 17. Teens may use the platform to apply for Observations in Ohio. If you are between the ages of 13 and 17, you represent that you have your parent or guardian's permission to use the Services and that your parent or guardian has reviewed our Terms of Use and this Privacy Policy.

Tracking Tools 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. For example, Google LLC ("Google") uses cookies in connection with its Google Analytics services. Google's ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google's use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
• Session-replay technologies. We use HotJar and PostHog to record user sessions for diagnostic and product improvement purposes. These recordings may capture mouse movements, clicks, keystrokes, and inputs on the Services. Session-replay technologies are a specific type of Performance/Analytical Cookies.

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 into your browser settings. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Automated Decision-Making and AI Inferences

We use automated systems, including AI models, to generate inferences about your skills, qualifications, and preferences, and to surface relevant opportunities, candidates, and content. We do not use automated systems alone to make decisions that have a legal or similarly significant effect on you without meaningful human review.

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 your profile information and credentials for as long as you have an account with us.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Your Choices

In this section, we describe the choices available to you.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt-out of text messages by texting "STOP" in response to a text that you receive or by other reasonable means.

Cookies. Please see the Tracking Tools and Opt-Out section above for information about your choices with respect to Cookies.

Depending on where you reside, applicable state privacy laws may also provide you with certain rights regarding the personal data we collect. Please see the next section, State Law Privacy Rights, for more information.

State Law Privacy Rights

New Jersey Resident Rights

This section describes how we collect, retain, use, disclose, sell, and process for targeted advertising purposes the personal information of New Jersey residents and the rights New Jersey resident users may have with respect to their personal information. Please note that we may not be able to process your access, correction, or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term "personal information" means information that is linked or reasonably linkable to an identified or identifiable person and excludes publicly available information. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

• Information/to know. You can request to know whether we process your personal information.
• Access. You can request a portable copy or representative summary of the personal information that we have collected about you.
• Correction. You can ask us to correct inaccurate personal information that we have collected about you.
• Deletion. You can ask us to delete the personal information that we have collected from or about you.
• Opt-out.
  • Opt-out of targeted advertising. We do not process your personal information for targeted advertising purposes.
  • Opt-out of sale of your Personal Information. We do not sell your personal information.
• Automated decision making. We do not use your personal information to engage in automated processing or profiling personal information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.
• Sensitive Personal Information. We do not process Sensitive Personal Information.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by applicable State Privacy Laws.
• Appeal. You can appeal our denial of any request validly submitted.

Exercising your right to know, access, correction, deletion, and appeal. You may submit requests via email to support@workup.health.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Global Privacy Control. The Global Privacy Control is an opt-out preference signal that allows you to automatically exercise your right to opt-out of the sale or sharing for targeted advertising purposes of your personal information. Because we do not sell or share your personal information for targeted or cross-contextual advertising purposes, broadcasting the Global Privacy Control does not change how we process your personal information. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Verification of identity; Authorized agents. We may need to verify your identity to process your know, access, correction, deletion, or appeal requests and reserve the right to confirm your residency. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

You may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

California Resident 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 support@workup.health.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at support@workup.health with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time and will post the revised Policy with an updated effective date. We will provide notice as required by law via email to your account email address and an in-product notice. Where required by law, we will obtain your affirmative consent before applying changes to your Personal Data. Prior versions of this Policy are available upon request at support@workup.health.

Contact Information

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

www.workup.health
support@workup.health
WorkUp Health, Inc., 228 Park Ave. S, PMB 57938, New York, NY, New York 10003