MPLOYNOW – PRIVACY POLICY

MployNow is operated by Shirah Technologies Inc. (“Shirah”, “we”, “our”, and “us”), a company incorporated in Canada. Shirah recognizes the importance of protecting the privacy and the rights of individuals in relation to their personal information. The purpose of this privacy policy (“Privacy Policy”) is to inform you about our privacy practices on MployNow, including how we collect, use and disclose your Personal Information.

This Privacy Policy applies to the MployNow website at https://mploynow.shirah.co/ and the MployNow platform, including all accounts, tools and features offered through it (collectively, the “Platform”). It applies to all of our operations in Canada or operations in connection with Canada.

MployNow is a hiring platform. Employers post roles and we search, screen and vet candidates for them. On some of our services Shirah becomes the legal employer of the person hired, in that person's own country, and handles their payroll and statutory obligations. On others the employer hires the person directly. Which service applies changes what we do with information, and that is set out below.

This Privacy Policy governs the Platform only. Shirah operates other products, each with its own privacy policy, and its corporate website at https://shirah.co/ has its own. Nothing in this Privacy Policy applies to those.

MployNow has two kinds of user, and one of them has a second relationship with us.

Employers and clients. Businesses hiring through the Platform.

Candidates. Individuals looking for work through the Platform.

Where a candidate is hired on one of our managed embedded services, Shirah becomes that person's employer of record in their country. From that point we hold their information both as the operator of the Platform and as their employer, and the employment relationship brings its own legal obligations to collect and retain payroll, tax and statutory records. Those obligations are set by the law of the country of employment and they continue after employment ends.

Where a candidate is hired on a direct hire service, the employer employs them and we do not. Our role ends with the introduction and whatever support the employer has engaged us for.

We never charge a candidate a fee to find work through MployNow. Nobody on this Platform should ever ask a candidate for money in exchange for a job or a placement. If that happens, tell us.

This Privacy Policy is current as of the “last modified” date which appears at the top of this page. We may make changes to this Privacy Policy from time to time, which will become immediately effective when published in a revised Privacy Policy posted on the Platform unless otherwise noted. You are responsible for checking if any amendments have been made. Your continued use of the Platform will constitute your consent to collection, use, and disclosure of your personal information as described in the amended Privacy Policy.

Please review this Privacy Policy carefully. By submitting your personal information (“Personal Information”) to us, by registering for or using the Platform, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your Personal Information as set out in this Privacy Policy, as revised from time to time.

Personal Information means information about an identifiable individual as described under Canadian privacy laws, which may include, but is not limited to, your name, e-mail address and telephone number. Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work e-mail address.

Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected. We rely on your express consent when you apply for a role, when we present you to an employer, and when we collect the more sensitive information needed to employ or relocate you.

If you wish to withdraw your consent, please contact us using the information in the ‘Contact Information’ section below. In some cases, withdrawal will mean we can no longer put you forward for roles or continue to provide the Platform to you. Where we are your employer of record, some information must be retained regardless of consent because employment and tax law requires it.

What we collect depends on who you are and how far a hire has progressed.

From candidates, at application:

• Identity and contact information: name, email address, telephone number, city and country of residence.
• Account information: username, password and account preferences.
• Work information: your CV or resume, work history, skills, qualifications, certifications, education, languages and salary expectations.
• Right to work information: your current work authorization or immigration status in the country where the role sits.
• Anything you choose to add, including a portfolio, an introduction video or a cover note.

From candidates, once a hire is progressing:

• Interview and assessment records, screening notes, and any test or task results.
• References, and the outcome of credential and employment verification checks, where you have agreed to them.
• Where a background or criminal record check is required for the role, the result of that check, and only where you have given specific consent for it and where the role and the law permit it.

From candidates we employ as employer of record:

• Date of birth, national identification or tax number, and home address.
• Bank account details for payroll.
• Payroll, tax, deduction and statutory contribution records.
• Emergency contact, and dependant or beneficiary information where a benefit requires it.
• Time, attendance, leave and performance records.

From candidates being relocated:

• Passport and travel document details, immigration and travel history, previous applications and refusals, and the documents an immigration authority requires for the permit being applied for.
• Family member information where the application includes them, provided by you and with their permission or your authority as their parent or guardian.

From employers:

• Business identity and contact information, including business number and registered address.
• Role, wage, location, working arrangement and recruitment information.
• Billing and payment information, and where relevant the details needed to run a recurring authorized payment.
• The names and contact details of the people at the business who use the Platform.

From everyone:

• Technical information: IP address, browser type, operating system and device information, collected to ensure the security, performance and functionality of the Platform.
• Usage information: pages visited, length of visits, page interaction such as scrolling and clicks, and how you navigate the Platform.

Some of what we hold is sensitive. Payroll and bank details, immigration status, a background check result, and health information where a benefit or an accommodation requires it, all carry real consequences if they are mishandled.

We collect it only where the service you are using requires it, and only at the point it is required. We do not sell it. We do not use it for advertising, and we do not disclose it for advertising purposes. We do not share a background check result, a payroll record or a bank detail with an employer.

We use different methods to collect information, including through:

• Information you provide directly, when you register, apply, upload a CV, complete onboarding, message us, or contact us.
• Information an employer provides about a role, and about a candidate they have already found.
• Information from referees, verification providers and background check providers, where you have consented.
• Information collected automatically through cookies and similar technologies. See ‘Automatic data collection technologies’ below.

We use information that we collect about you or that you provide to us in the following ways:

• Matching and screening: to understand a role, find candidates who fit it, rank and shortlist them, and present them to the employer.
• Hiring: to arrange interviews, run assessments, carry out verification, and support the employer's decision.
• Employment: where we are the employer of record, to run payroll, make statutory deductions and contributions, administer leave and benefits, and meet our obligations as an employer.
• Relocation: where the service includes it, to run the required advertising, prepare and support the immigration application, and keep the record an inspection may require.
• Billing: to invoice employers and collect payment.
• Notifications: to tell you about applications, interviews, offers, start dates and payroll.
• Platform optimization: to analyze usage data and improve the Platform.
• Customer support: to respond to inquiries and provide assistance.
• Marketing outreach: to send updates and relevant roles or services based on your preferences, with the option to opt out at any time. We do not use payroll, immigration or background check information for this.
• Regulatory compliance: to meet legal, employment, tax and audit requirements, including keeping the recruitment records that an employment agency licence or an immigration programme requires.
• Security monitoring: to conduct audits and risk assessments that protect your data from unauthorized access or breaches.

MployNow uses automated matching and ranking to help find and order candidates for a role. That tool is called MIRA.

MIRA compares what a role needs against what a candidate has told us, and produces a match score and a ranking. It is a way of ordering a shortlist, not a decision.

No hiring decision is made about you by automated means. Every candidate presented to an employer has been reviewed by a person on our recruitment team, and the employer makes the final hiring decision. A low match score does not by itself remove a candidate from consideration.

If you would like to know why you were or were not shortlisted for a role, ask us using the contact information below and we will explain what we can.

We do not use your Personal Information, your CV or your application content to train publicly available artificial intelligence models. Where an automated feature relies on a third party service provider, that provider is bound by contract to process the information only to deliver the feature and not to use it for its own purposes, including model training.

We share information in the following ways, and no others.

• With the employer, where you are a candidate for their role. We share your profile, CV, and the assessment and interview material relevant to the role. We do not share your date of birth, bank details, national identification number, home address, immigration documents or background check result unless the employer must have it by law for that role and you have consented.
• With the candidate, where you are an employer, so they know who they would be working for and on what terms.
• With referees and verification or background check providers, where you have consented to a check.
• With payroll, benefit, tax and statutory authorities in the country of employment, where we are your employer of record, because employment law requires it.
• With immigration authorities and, where one is engaged, a licensed immigration professional, where the service includes relocation.
• With third party service providers who perform services on our behalf, such as data storage (Google Cloud), email delivery and marketing (Mailchimp), payroll providers and payment processing. They are required to keep your Personal Information secure and to handle it only for the limited purposes for which we disclose it to them, and are not authorized to disclose it to unauthorized parties or to use it for their own direct marketing purposes.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure and obtain your consent.

We do not sell your Personal Information, and we do not disclose it to other organizations for their own direct marketing purposes.

We may send you direct marketing communications and information about roles and services that we consider may be of interest to you, in accordance with applicable marketing laws, including Canada’s Anti-Spam Legislation (CASL). At any time you may opt out by contacting us or by using the unsubscribe mechanism provided in our marketing communications. Opting out of marketing does not stop the operational messages you need about an application, a hire or your pay.

The security of your personal information is very important to us. We take reasonable steps to ensure it is protected from misuse and loss and from unauthorized access, modification, or disclosure, including access controls that limit an employer to the candidates and roles they are entitled to see, and that keep payroll and identity information out of employer view.

The safety and security of your information also depends on you. You are responsible for keeping your password confidential and for the activity on your account, and we ask you not to share your password with anyone.

Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. Accordingly, any personal information which you transmit to us online is transmitted at your own risk. Once we receive your transmission, we make our best efforts to ensure its security on our systems.

MployNow is cross border by design. A candidate in one country is hired by an employer in another, and the payroll runs in a third. Using the Platform means your information moves between countries.

We may transfer personal information that we collect or that you provide to contractors and service providers we use to support our business, who are contractually obligated to keep it confidential, use it only for the purposes for which we disclose it to them, and process it to the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of that country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. You are welcome to contact us for further information about our policies regarding service providers outside of Canada.

We only collect information by lawful means. When we do, we will collect, use or share your personal information with your consent for the purposes identified or as otherwise permitted or required by law. In some situations, the law allows us to collect, use or disclose personal information without your consent.

You can withdraw your consent at any time. Withdrawing it will normally mean we can no longer put you forward for roles or continue to provide the Platform to you. Where we are or have been your employer of record, employment, payroll and tax law require us to keep certain records for set periods, and we cannot delete those on request.

You may withdraw your consent to the collection, use or disclosure of your or your child’s personal information at any time by contacting our Privacy Officer (see ‘Contact Information’ below) and, subject to those legal constraints, we will comply with your request.

You may request access to any personal information we hold about you at any time by contacting us. Where we hold information you are entitled to access, we will try to provide you with suitable means of accessing it.

If you believe that Personal Information we hold about you is incorrect, incomplete, or inaccurate, you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note stating that you disagree with it, together with your requested amendment. If we correct your Personal Information, we will, so far as is reasonably practicable, inform every other person to whom we have disclosed that information of the correction.

We may request specific information from you to help us confirm your identity and your right to access. In certain situations we may not be able to fulfil your request, and we will explain the reasons when responding. For example, the information may contain another person's assessment or reference given in confidence, or it may be a record we are legally required to keep.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting, employment or reporting requirements.

In practice that means an unsuccessful application is kept for a period so that you can be considered for future roles, and you can ask us to remove it sooner. Recruitment records connected to a relocation or an immigration programme are kept for as long as an inspection may require. Employment and payroll records, where we are or have been your employer of record, are kept for the period the law of the country of employment requires.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you, and we reserve the right to use such anonymous and de-identified data for any legitimate business purpose.

Tracking Technologies and Advertising. You can set your browser settings to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Platform may not be accessible or may not function properly.

Promotional Offers. If you no longer wish to receive marketing email from us, you can opt out by clicking “Unsubscribe” at the bottom of the email or by contacting us.

We do not share your personal information with unaffiliated third parties for their promotional purposes, and we do not use payroll, immigration or background check information to target advertising.

The information we collect automatically is statistical information and may include personal information. It helps us to improve the Platform and deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or your smartphone. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Platform, including the parts that require you to be signed in.

Web Beacons. Pages of the Platform and our e-mails may contain small electronic files known as web beacons that permit Shirah, for example, to count users who have visited those pages or opened an email and for other related statistics.

Some content or applications on the Platform may be served by third parties. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Platform. We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

The Platform may include links to third-party websites, plug-ins, services or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. These third parties have their own privacy policies, we do not assume responsibility for their privacy practices, and we encourage you to review them before using them.

MployNow accounts are for individuals who are of the age of majority in their jurisdiction of residence, and the Platform is not directed to children. We do not knowingly allow a child to create an account or knowingly collect personal information directly from a child.

Where a relocation application includes a dependent child, the information about that child is provided to us by the parent or legal guardian, who is responsible for having the authority to provide it. We handle it under this Privacy Policy, and the parent or guardian may exercise the rights in this Privacy Policy on the child's behalf.

We welcome your questions, comments, complaints and requests regarding this Privacy Policy and our privacy practices. Shirah has designated a Privacy Officer who is accountable for our compliance with this policy and with applicable privacy laws. You may contact our Privacy Officer at:

Privacy Officer

Shirah Technologies Inc., operator of MployNow

support@mploynow.shirah.co

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. Please note that we may need to confirm your identity or request additional details in order to process your request.