We are strongly committed to protecting the privacy of your personal information. The policies below are applicable to the website to which this Privacy Policy is linked (“Site”), however accessed and/or used, which Site is operated by, made available by, or produced and maintained by the owner of the Site (referred to herein as “we”, “us”, or “our”) for and on behalf of us and our licensees. We have established this privacy policy (“Privacy Policy”) to let you know the kinds of personal information we may gather during your visit to the Site, why we gather your personal information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information.

Please be advised that the practices described in this Privacy Policy apply only to information gathered online at our Site. It does not apply to information that you may submit to us offline, or to websites, content or applications maintained by other third parties to which we may link or that may link to us.

By visiting our Site, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our Site following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively, we will provide you with notice of the modifications or amendments.

What Information About Me Is Collected and Stored?

We collect two basic types of information from you in conjunction with your use of the Site, Personal Information and Non-Personal Information. “Personal Information” is information that you may supply to us and can individually identify you, including your name, e-mail address, telephone number, postal address, credit card, billing and contact information, i.e., when you register for an account on the Site, upload content or participate in a community. “Non-Personal Information” is any information that does not personally identify you but may include tracking and usage information about your location, demographics, use of the Site and the Internet.

Personal Information

As a general matter, you can browse the Site without submitting your Personal Information to us. However, there are a number of circumstances in which you may supply us with your Personal Information. The following lists the most common ways in which we may collect your Personal Information:

• Registration for an account on the Site
• Creating your profile
• Uploading your resume, cover letters or other materials
• Applying for a posted job
• Participating in interactive services, including any materials submitted in connection with a training module
• Signing up to receive e-mail newsletters from us
• Requesting customer service or other assistance
• Participating in surveys, panels, or market research
• Participating in special events and promotions
• Entry in contests or sweepstakes
• Submission of user generated content on any part of the Site that permits it
• Any other place on the Site where you knowingly volunteer Personal Information

When you apply for a job through the Site or upload your resume to our resume database, employers will have access to that content. We have no control over the retention or use of your resume or profile by employers or third parties.

Collection of Personal Information From Social Media Sites

When you interact with any Site page or account on a social media platform, such as Facebook, Twitter, Google+, Tumblr, YouTube, or Pinterest, or use a social media feature such as Facebook’s “Like” button, we may collect the Personal or Non-Personal Information including your IP address, account ID or “handle.” However, we will comply with the privacy policies of the corresponding social media platform and will only collect and store such Personal Information that we are permitted to collect by these social media platforms.

Non-Personal Information

In addition, when you interact with the Site, our servers may keep an activity log of Non-Personal Information. Generally, we collect and store the following categories of Non-Personal Information:

• Demographic data such as age, gender and five digit zip code as part of collecting personal information
• Device information about your computer, mobile device, or other device that you use to access the Site. This information may include IP address, geolocation information, unique device identifiers, browser type, browser language and other transactional information
• Usage information about your use of the Site. This information includes a reading history of the pages you view. We use this information to provide you with a more customized experience on the Site
• Additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times and referring website addresses
• Your search terms and search results
• Other information regarding our users' use of the Site

Collection of Your Source IP Address/Location Information

We collect and store your device's source IP address which may disclose the location of your device at the time you access the Site. Advertisements and certain content may be directed to you as a result of this data.

In addition, in some cases the Site can deliver content based on your current location if you choose to enable that feature. If you enable that feature, your current location will be stored locally on your device which will be used by the Site to serve you certain content tied to your location. If you elect to have your location-based searches saved to your history, we will store such information on our servers.

Collection of Personal and Non-Personal Information From Other Sources

We also may collect and store information about you that we receive from other sources to, among other things, enable us to update and correct the information contained in our database and to better customize your experience on the Site.

Use of Cookies, Flash Cookies and Web Beacons

Like many websites, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We use cookies to track use of our Site and online services. We may also use cookies to monitor traffic, improve the Site and make it easier for and/or relevant to your use. You may occasionally get cookies from companies advertising on our behalf. We do not control those cookies and they are not subject to this cookie policy.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau atwww.allaboutcookies.org.

We may also use web beacons or flash cookies. A web beacon or flash cookie (also known as “action tags”, “tracer tags”, or “single-pixel gifs”) is an invisible graphic on a web page that is programmed only to collect Non-Personal Information about your use of a given website. We do not collect Personal Information, such as names, e-mail addresses and phone numbers through such web beacons without your express permission.

We may work with third-party advertising companies who also may utilize flash or enhanced cookies or web beacons to better provide advertisements about goods and services that may be of interest to you. These partners do not use this technology to collect Personal Information about you or have access to or use your name, address, e-mail address, telephone number or other information from us. They may, however, anonymously track your Internet usage across other websites in their networks beyond this Site. To learn more about the use of this information or to choose not to have this information used by our third-party advertising partners by opting out please visit the Network Advertising Initiative by clickinghttp://www.networkadvertising.org/managing/opt_out.asp.

Is Personal Information Collected From Children?

Individuals under the age of eighteen (18) are not allowed to visit or use this Site. We respect the privacy of children and we are committed to complying with the Children's Online Privacy Protection Act (COPPA). This Site does not knowingly collect, use, or disclose personal information (as defined under the Act) from anyone under the age of eighteen (18).

How Do We Use Your Information?

We use the information we learn from you to help us personalize and continually improve your experience on the Site. We may use your Personal and Non-Personal Information in the following ways:

General Uses

• Optimize and improve the Site, operations and the services we provide
• Perform statistical, demographic and marketing analyses of users of the Site
• Provide you with the services you request
• Post your user generated content to our Site as you request
• Communicate with you about your account, respond to your inquiries or send you information about features on our Site
• Communicate with you about changes to our policies
• Personalize content and experiences on our Site, including providing job opportunities or training modules based on job search preferences and history
• Connect you to potential employers
• Send you newsletters, offers and promotions for our services, third party products and services, or special events by e-mail or other medium
• Provide you with advertising, including advertising based on your activity on our Site or activity on third party sites and applications
• Administer contests, sweepstakes, promotions, and surveys
• Detect, investigate and prevent activities that may violate our policies or be illegal
• Protect users from, or prevent, fraudulent activity

Combination of Your Personal Information

We use and/or combine information that we collect off-line or from third party sources to enhance and check the accuracy of your customer records.

Use of Your Location Information

• We use your location information to:
• Provide you with the services you request
• Personalize content and experiences on our Site
• Personalize your newsletters, offers and promotions for our products and services, third party products and services, or special events
• Personalize the advertising you receive, including advertising based on your activity on our Site or activity on third party sites and applications
• Optimize or improve our services and operations
• Detect, investigate, and prevent activities that may violate our policies or be illegal
• Perform statistical, demographic, and marketing analyses of users of the Site

Who Do We Provide Your Information To?

We may disclose information about your Personal Information collected online to any of our Affiliates, successors or assigns. An “Affiliate” means an entity that controls, is controlled by, or is under common control with a party, where “control” means the direct or indirect ownership of more than fifty percent (50%) of the voting securities of such entity or party. Although, as disclosed below, we may provide your information to our partners, in no event will we sell or rent your Personal Information as part of a customer list or similar transaction, except in connection with the sale of our business.

Third-Party Agents

We may have third party agents, subsidiaries, Affiliates and partners that perform functions on our behalf, such as hosting, billing, marketing, analytics, customer service, fraud protection, etc. These entities have access to the Personal Information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Site.

Business Partners and Third Parties

We may share your Personal Information with our business partners or co-marketers from time to time. We may also share your Personal Information with third parties that provide services that we think you may be interested in. Although our treatment of your Personal Information is governed by this Privacy Policy, the business partner or third party's treatment of your Personal Information will be governed by the business partner or third party's privacy policy. You may withdraw your consent to our sharing of your Personal Information with business partners and third parties at any time by following the opt-out process described below.

Situations

We may also use or disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Site; (b) protect and defend our rights or property, the Site or our users, and (c) act under emergency circumstances to protect the personal safety of us, our Affiliates, agents, or the users of the Site or the public.

Use of Non-Personal Information

We may disclose or share Non-Personal Information (or other information, other than Personal Information) in any other manner that we deem appropriate or necessary. Among other things, we will disclose Non-Personal Information to third parties to help us determine how people use parts of the Site and who our users are so we can improve our Site. We will also disclose Non-Personal Information to our partners and other third parties about how our users collectively use the Site.

What Steps Are Taken To Keep Personal Information Secure?

We are concerned about ensuring the security of your Personal Information. Personal Information collected by our Site is stored in a reasonably secure operating environment that is not available to the public. Please understand, however, that while we use commercially reasonable efforts to safeguard your Personal Information once we receive it, no security is foolproof. The safeguards we use reflect, in a commercially reasonable manner, the nature of the information you have supplied to us and the nature and scope of our business.

Your Obligations to Keep Your Access Rights Secure

You promise to: (a) provide true, accurate, current and complete information about yourself and your business as prompted by a registration form (such information being the “Registration Data”) and (b) maintain and promptly update the Registration Data to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of the Site (or any portion thereof). You are entirely responsible for the security and confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur under your account. You agree to immediately notify us of any unauthorized use of your account or any other breach of security of which you become aware. You are responsible for taking precautions and providing security measures best suited for your situation and the intended use of the registration and Site.

What Happens When I Link To or From Another Website?

The Site may contain links to other websites not operated by us. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through other websites. We are not responsible for the actions and privacy policies of third parties and other websites.

What About Contests and Sweepstakes?

When we run a contest or sweepstakes relating to our Site, it will be accompanied by a set of rules. The rules for each contest/sweepstakes will specify how the information gathered from you for entry will be used and disclosed, if it is different than as described in this Privacy Policy. In conjunction with your entry in such contest or sweepstakes, Personal Information will be collected only if you voluntarily submit it.

Public Areas, Chat Rooms, Reviews, and Community Areas

Please remember that any information you share in public areas, such as message boards or feedback sections, becomes public and anyone may take and use that information. Please be careful about what you disclose and do not post any Personal Information that you expect to keep private. Please consult the applicable guidelines, if any, for use of our chat rooms and other community areas for more information.

Access To and Correcting Information

You may review and change your Personal Information by logging into the Site and accessing your profile. You may also remove your resume or delete your account at any time. If you delete your account, we will, for a period of time as determined by us, retain an archival copy of your Personal Information for its records and for audit purposes but the copy will not be accessible online.

Governing Law

The Site is published in the United States of America. We attempt to protect the Personal Information of all users of our Site and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to the services provided by us. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your Personal Information through the Site.

Assignment

We may change our ownership or corporate organization while providing the Site and services. We may also sell certain assets associated with the Site. As a result, please be aware that in such event we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Notice to Users Outside the United States of America

If you are located outside the United States of America, you should be aware that your Personal Information will be transferred to the United States of America, the laws of which may be deemed by your country to have inadequate data protection. If you are located in a country outside the United States of America and you voluntarily submit Personal Information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States of America.

Changes to This Policy

As our Site continues to develop, we may add new services and features to our Site. In the event that these additions affect our Privacy Policy, this document will be updated appropriately. We will post those changes prominently so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We do, however, recommend that you read this Privacy Policy each time you use our Site in case you missed our notice of changes to the Privacy Policy. We will not, however, materially change our policies and practices to make them less protective of Personal Information we have previously collected from you without your express consent.

How Do I Opt-Out or Correct Information About Me

You may always opt-out of receiving future e-mail messages from us. We provide you with the opportunity to opt-out of receiving communications from us at the point where we request information about you. To do so, you can send us a message atcustomersupport@yourjobpath.com.

Your California Privacy Rights

California Civil Code Section 1798.83 permits customers of us who are California residents to request certain information regarding its disclosure of their Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail tocustomersupport@yourjobpath.com.

Do Not Track Practices

As of the date of this Privacy Policy listed above, we cannot honor web browser “do-not-track” signals because we may use third party vendors who do not honor such signals. While we collect Personal Information from you as described earlier in this Privacy Policy, we do not collect or use or allow third parties to collect or use Personal Information from you on the Site in order to monitor your online activities across third party websites or online services and over time (also known as behavioral advertising or interest-based advertising). For more information about behavioral advertising or interest-based advertising and for further information on how to opt out from such advertising (and what “opting-out” does and doesn’t do), clickhttp://www.networkadvertising.org/choices/#completed

[ We are a participant in the US-EU Safe Harbor program developed by the US Department of Commerce and the European Union (EU). We have certified that we adhere to the Safe Harbor Privacy Principles agreed upon by the US and EU. For more information about the Safe Harbor and to view our certification, visit the US Department of Commerce’s Safe Harbor website atwww.export.gov/safeharbor/. ]

PRIVACY STATEMENT – NEVADA RESIDENTS ONLY

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

If you are a Nevada resident, you may submit a request to opt out of any potential future sales under Nevada law by emailing customersupport@yourjobpath.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

PRIVACY STATEMENT-CALIFORNIA RESIDENTS ONLY

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of JobPath Partners LLC and its subsidiaries and affiliate partner sites (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (www.hornellp.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:             Identifiers.
Category B:             California Customer Records personal information categories.
Category C:             Protected classification characteristics under California or federal law.
Category I:              Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• Sales, identifying the personal information categories that each category of recipient purchased; and
• Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 855-765-8080.
• Visiting yourjobpath.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.