Privacy Policy | Appli Network

1. Introduction and Scope

This Privacy Policy (“Policy”) describes how Appli Solutions (“Company,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects the personal information of individuals (“you,” “your,” or “users”) who access or use our professional networking platform, website, mobile applications, and all related services (collectively, the “Platform”). This Policy applies to all users located in the United States and Canada.

By creating an account, accessing, or using the Platform in any capacity, you acknowledge that you have read, understood, and agree to the collection, use, disclosure, and processing of your personal information as described in this Policy. If you do not agree with any provision of this Policy, you must immediately discontinue use of the Platform and delete your account.

This Policy is incorporated by reference into our Terms of Service. In the event of a conflict between this Policy and the Terms of Service regarding data privacy matters, this Policy shall control.

1.1 Applicable Laws and Regulations

This Policy has been drafted to comply with, and your rights are protected under, the following laws and regulations, to the extent applicable to you based on your jurisdiction of residence:

United States Federal Laws: The Federal Trade Commission Act (FTC Act), Section 5; the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM Act); the Children’s Online Privacy Protection Act (COPPA); Title VII of the Civil Rights Act of 1964; the Americans with Disabilities Act (ADA); the Age Discrimination in Employment Act (ADEA); the Fair Credit Reporting Act (FCRA); and the Genetic Information Nondiscrimination Act (GINA).

United States State Laws: The California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA); the California Delete Act (SB 362); the Illinois Biometric Information Privacy Act (BIPA); the Illinois Artificial Intelligence Video Interview Act (AIVIA); the Illinois Human Rights Act (as amended by HB 3773); the Colorado Privacy Act (CPA); the Colorado AI Act (SB 24-205); the Connecticut Data Privacy Act (CTDPA); the Virginia Consumer Data Protection Act (VCDPA); the Texas Data Privacy and Security Act (TDPSA); the Oregon Consumer Privacy Act (OCPA); the Maryland Online Data Privacy Act (MODPA); the Delaware Personal Data Privacy Act; the Montana Consumer Data Privacy Act; the New Hampshire Privacy Act; the New Jersey Data Privacy Act; the Minnesota Consumer Data Privacy Act; the Indiana Consumer Data Protection Act (INCDPA); the Kentucky Consumer Data Protection Act (KCDPA); the Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA); the Iowa Consumer Data Protection Act (ICDPA); the Tennessee Information Protection Act (TIPA); the Utah Consumer Privacy Act (UCPA); the Arkansas Data Privacy Act; New York City Local Law 144 (Automated Employment Decision Tools); and all other applicable state privacy, biometric, and consumer protection statutes.

Canadian Federal Laws: The Personal Information Protection and Electronic Documents Act (PIPEDA); Canada’s Anti-Spam Legislation (CASL); and the Canadian Human Rights Act.

Canadian Provincial Laws: Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25); Alberta’s Personal Information Protection Act (PIPA); British Columbia’s Personal Information Protection Act (PIPA); and all other applicable provincial and territorial privacy legislation.

1.2 Definitions

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identifiable individual. This includes, without limitation, names, email addresses, physical addresses, dates of birth, ages, profile content, resumes, video recordings, biometric identifiers, geolocation data, IP addresses, device identifiers, and professional information.

“Biometric Information” means any information based on an individual’s biometric identifiers, including but not limited to facial geometry, voiceprints, and any mathematical representations derived therefrom, used to identify an individual. This definition is intended to be interpreted consistently with the Illinois Biometric Information Privacy Act (740 ILCS 14/10) and all other applicable biometric privacy statutes.

“Sensitive Personal Information” means Personal Information that reveals racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, genetic or biometric data processed for the purpose of uniquely identifying an individual, Personal Information of a known child, and precise geolocation data.

“Processing” means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.

“Work Trial” means the assessment process conducted through the Platform whereby a user interacts with other individuals, completes sample projects, records videos, and engages in activities designed to evaluate the user’s professional capabilities in connection with a specific job application.

“Hiring Manager” means a third-party employer, recruiter, or authorized representative who accesses user-submitted Work Trial data and other application materials through the Platform for the purpose of evaluating candidates for employment opportunities.

2. Information We Collect

We collect the following categories of Personal Information from and about you:

2.1 Information You Provide Directly

Account Registration Information: Full legal name, email address, password, date of birth, age, physical address, city, state or province, postal code, country of residence, and phone number.
Profile Information: Professional title, employment history, education history, skills, professional certifications, biography, profile photographs, and any other information you choose to include in your public profile.
Resume and Application Materials: Resumes, curriculum vitae, cover letters, portfolio samples, work history, references, and any supplementary documents you upload to the Platform.
Video Recordings: Interview videos that include your face, voice, spoken responses, and visual likeness, recorded through the Platform’s video recording functionality. These recordings constitute both audio-visual personal data and, to the extent that facial geometry or voiceprint data is extracted or could be extracted therefrom, Biometric Information.
Work Trial Data: All communications, messages, chat transcripts, sample project outputs (including but not limited to written reports, presentations, analyses, and creative work), video recordings, screen activity, and any other data generated during the course of a Work Trial conducted on the Platform.
Communications: Messages sent and received through the Platform’s messaging system, including direct messages between users and communications with our support team.
User-Generated Content: Posts, comments, endorsements, recommendations, and any other content you create or share on the Platform.

2.2 Information Collected Automatically

Device and Browser Information: IP address, browser type and version, operating system, device type, unique device identifiers, screen resolution, and language preferences.
Usage Data: Pages viewed, features accessed, links clicked, search queries, session duration, timestamps, referring URLs, and navigation patterns within the Platform.
Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixel tags, and similar tracking technologies as described in Section 12 of this Policy.
Geolocation Data: Approximate geographic location inferred from your IP address or, with your explicit consent, precise geolocation data from your device.

2.3 Information from Third Parties

Social Media Platforms: If you link a third-party social media account, we may receive profile information from that platform in accordance with your privacy settings on that platform.
Hiring Managers and Employers: Feedback, evaluations, and hiring decisions related to Work Trials.
Service Providers: Analytics providers, identity verification services, and fraud prevention services may provide us with information about you.

3. How We Use Your Information

We use the Personal Information we collect for the following purposes, each of which constitutes a lawful and legitimate basis for processing:

3.1 Platform Operations and Service Delivery

To create, maintain, and administer your user account and profile.
To display your profile information to other users of the Platform, subject to your privacy settings.
To facilitate connections, messaging, and professional networking between users.
To enable you to participate in Work Trials, including transmitting your Work Trial data (chat transcripts, project outputs, video recordings, and related materials) to the Hiring Manager(s) associated with the specific job position for which you applied.
To provide, maintain, improve, and develop the Platform and its features.

3.2 Communications

To send you transactional communications, including account confirmations, security alerts, technical notices, support messages, and administrative updates related to your use of the Platform.
To send you marketing and promotional communications about our products, services, events, and opportunities that may be of interest to you, subject to your opt-in consent where required by law (including CASL and CAN-SPAM Act compliance) and your right to opt out at any time.
To respond to your inquiries, feedback, and support requests.

3.3 Safety, Security, and Legal Compliance

To detect, prevent, investigate, and address fraud, unauthorized access, illegal activity, and violations of our Terms of Service.
To comply with applicable laws, regulations, legal processes, and enforceable governmental requests.
To protect the rights, property, and safety of the Company, our users, and the public.
To enforce our Terms of Service and other agreements.

3.4 Analytics and Improvement

To conduct research, analysis, and reporting to understand user behavior, improve the Platform, and develop new features.
To aggregate and de-identify data for statistical analysis and benchmarking purposes.

3.5 Hiring and Employment Facilitation

Your Work Trial data, interview videos, resumes, and related application materials will be shared with the Hiring Manager(s) of the specific job position for which you have applied. This data may influence hiring decisions. We expressly disclaim any guarantee that your participation in a Work Trial or any use of the Platform will result in a positive hiring outcome or employment offer. Hiring decisions are made solely by the applicable Hiring Manager(s) and their organizations, and we bear no responsibility for such decisions.

4. Disclosure of Your Information

We may disclose your Personal Information to the following categories of recipients and for the following purposes:

4.1 Public Profile Information

By default, certain information you provide—including your name, professional title, employment history, education history, skills, profile photograph, and any other information you add to your public profile—will be visible to all users of the Platform and may be indexed by external search engines. You may adjust the visibility of certain profile fields through your account privacy settings. It is your responsibility to review and manage these settings. Any information you choose to make public is disclosed at your own risk.

4.2 Hiring Managers and Employers

When you apply to a job position and participate in a Work Trial, the following data will be shared with the Hiring Manager(s) designated for that position: your resume and application materials; your Work Trial chat transcripts, sample project outputs, video recordings, and all other data generated during the Work Trial; and your profile information. You provide your express consent to this disclosure each time you initiate a Work Trial application.

4.3 Service Providers and Processors

We engage third-party service providers who perform services on our behalf, including but not limited to cloud hosting, data storage, email delivery, analytics, payment processing, customer support, and security monitoring. These service providers are contractually obligated to process your Personal Information only as directed by us and in accordance with this Policy, and are prohibited from using your Personal Information for their own purposes. We require all service providers to maintain appropriate technical and organizational security measures.

4.4 Email Address Sharing

We may share your email address with third-party partners, including but not limited to Hiring Managers, recruiters, affiliated platforms, and marketing partners, for the purposes of facilitating professional opportunities, delivering relevant communications, and supporting the operation of the Platform. You provide your express, informed consent to this sharing when you create your account, and you may withdraw this consent at any time as described in Section 8 of this Policy. Upon withdrawal of consent, we will cease sharing your email address with new third parties within thirty (30) calendar days, though we cannot retroactively retrieve email addresses already disclosed to third parties prior to your withdrawal.

4.5 Legal and Regulatory Disclosures

We may disclose your Personal Information to government authorities, law enforcement agencies, courts, regulatory bodies, or other third parties where we believe in good faith that disclosure is required by applicable law, regulation, legal process, or enforceable governmental request; necessary to protect the rights, property, or safety of the Company, our users, or the public; necessary to detect, prevent, or address fraud, security, or technical issues; or made in connection with any merger, acquisition, reorganization, bankruptcy, asset sale, or similar transaction.

4.6 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, dissolution, asset sale, or similar transaction involving the Company, your Personal Information may be transferred as part of the transaction. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy, and we will use reasonable efforts to ensure the successor entity honors this Policy.

4.7 De-Identified and Aggregated Data

We may disclose de-identified or aggregated data that cannot reasonably be used to identify you to any third party for any purpose. We maintain technical safeguards and business processes to prevent re-identification.

4.8 With Your Consent

We may disclose your Personal Information to other third parties when we have obtained your specific, informed consent. Where required by applicable law, such consent will be obtained in writing (including electronic consent).

5. Biometric Information Notice and Consent

This Section constitutes a written notice and disclosure as required by the Illinois Biometric Information Privacy Act (740 ILCS 14/15) and all other applicable biometric privacy laws.

5.1 Collection of Biometric Information

When you upload or record interview videos through the Platform, the video recordings capture your facial geometry, visual likeness, and voice. To the extent that facial geometry scans, voiceprints, or other biometric identifiers or biometric information (as those terms are defined under BIPA) are collected, captured, or otherwise obtained from such recordings, we provide the following disclosures:

Purpose: Biometric Information is collected solely for the purpose of facilitating the job application and Work Trial evaluation process, including the transmission of your video recordings to applicable Hiring Managers. We do not use Biometric Information for facial recognition, surveillance, tracking, or any purpose unrelated to the specific employment opportunity for which you have applied.
Retention: We will retain your Biometric Information for no longer than three (3) years from the date of your last interaction with the Platform, or until the purpose for which the Biometric Information was collected has been satisfied, whichever occurs first. Upon expiration of the retention period, we will permanently destroy your Biometric Information using commercially reasonable methods within thirty (30) days.
Written Policy: We maintain a publicly available written policy establishing a retention schedule and guidelines for the permanent destruction of Biometric Information in compliance with BIPA Section 15(a).
No Sale or Profit: We will never sell, lease, trade, or otherwise profit from your Biometric Information. This prohibition is absolute and without exception.
No Disclosure Without Consent: We will not disclose, redistribute, or otherwise disseminate your Biometric Information to any third party unless: (a) you have provided your informed, written consent to the specific disclosure; (b) the disclosure is required by law, regulation, or valid legal process; or (c) the disclosure is necessary to complete a financial transaction that you have authorized.

5.2 Consent

By recording or uploading a video through the Platform, you acknowledge that you have read this Biometric Information Notice, you understand the purposes and duration for which your Biometric Information will be collected, stored, and used, and you provide your informed, written consent (via electronic acceptance) to the collection, storage, use, and limited disclosure of your Biometric Information as described herein. You have the right to withhold or withdraw this consent at any time; however, withholding or withdrawing consent may prevent you from using the video recording and Work Trial features of the Platform. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal.

5.3 Security of Biometric Information

We store and transmit Biometric Information using a standard of security that is equal to or more protective than the manner in which we store and transmit other confidential and sensitive personal information. Security measures include, at minimum, encryption in transit (TLS 1.2 or higher) and at rest (AES-256 or equivalent), access controls restricted to authorized personnel, multi-factor authentication, regular security audits, and intrusion detection systems.

6. Video Interview and Automated Decision-Making Notice

This Section provides the notices required under the Illinois Artificial Intelligence Video Interview Act (820 ILCS 42), the Colorado AI Act (SB 24-205), the California Civil Rights Council’s Automated Decision Systems regulations, New York City Local Law 144, and all other applicable laws governing automated decision-making in employment contexts.

6.1 Video Interview Disclosure

The Platform allows you to record and submit video interviews as part of a job application. We disclose the following:

Your video interviews will be reviewed by the Hiring Manager(s) for the specific position to which you have applied.
If any artificial intelligence, machine learning, or other automated analysis tools are used to evaluate your video interviews (including but not limited to analysis of speech patterns, facial expressions, word choice, sentiment, or other characteristics), we will provide you with a separate, specific notice describing the AI technology used, the characteristics it evaluates, and how those evaluations are used in the hiring process.
You will be asked to provide your informed consent before any AI analysis is conducted on your video interviews.
You have the right to request that any AI-generated evaluation be supplemented or replaced by human review.
You may request that your video interview recordings be deleted at any time, subject to any legal retention obligations, by contacting us at the address provided in Section 16.

6.2 Non-Discrimination

We are committed to ensuring that the Platform and all features, including Work Trials and video interviews, are operated in compliance with all applicable federal, state, provincial, and local anti-discrimination laws, including but not limited to Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Illinois Human Rights Act, the Canadian Human Rights Act, and all applicable state and provincial human rights legislation. We do not use or permit the use of any tool, algorithm, or process on the Platform that intentionally or knowingly discriminates against any individual on the basis of race, color, religion, sex (including gender identity and sexual orientation), national origin, age, disability, genetic information, veteran status, or any other characteristic protected by applicable law.

6.3 Reasonable Accommodations

If you require a reasonable accommodation due to a disability or medical condition in order to complete a video interview, Work Trial, or any other feature of the Platform, please contact us at the address provided in Section 16, and we will work with you and the applicable Hiring Manager to provide an accessible alternative assessment method.

7. Sale of Personal Information and Targeted Advertising

7.1 Sale of Personal Information

Under the CCPA/CPRA and other applicable state privacy laws, the term “sale” is broadly defined to include the disclosure of Personal Information to a third party for monetary or other valuable consideration. To the extent that any disclosure described in this Policy constitutes a “sale” as defined under applicable law, we provide you with the right to opt out of such sales as described in Section 8.

7.2 Targeted Advertising

We may use your Personal Information for targeted or cross-context behavioral advertising purposes. Under applicable state privacy laws, you have the right to opt out of the processing of your Personal Information for targeted advertising. You may exercise this right as described in Section 8.

7.3 Do Not Sell or Share My Personal Information

We honor “Do Not Sell or Share My Personal Information” requests. You may submit such a request through the methods described in Section 8. We also recognize and honor Global Privacy Control (GPC) signals and other universal opt-out mechanisms (UOOMs) as valid opt-out requests, as required by applicable state law, including but not limited to the CCPA/CPRA, CTDPA, OCPA, and all other statutes mandating recognition of such signals.

8. Your Privacy Rights

Depending on your jurisdiction of residence, you may have the following rights with respect to your Personal Information. We will honor all applicable rights regardless of whether you reside in a jurisdiction that has enacted comprehensive privacy legislation:

Right to Know and Access: You have the right to request confirmation of whether we are processing your Personal Information and to access the specific categories and pieces of Personal Information we have collected about you.
Right to Correction: You have the right to request that we correct inaccurate Personal Information we maintain about you.
Right to Deletion: You have the right to request that we delete Personal Information we have collected from you, subject to certain exceptions permitted by law (such as legal retention obligations, ongoing legal disputes, security purposes, and the completion of transactions you have initiated).
Right to Data Portability: You have the right to receive a copy of your Personal Information in a structured, commonly used, and machine-readable format, and to transmit that information to another controller.
Right to Opt Out of Sale and Sharing: You have the right to opt out of the sale of your Personal Information and the sharing of your Personal Information for cross-context behavioral advertising or targeted advertising purposes.
Right to Opt Out of Profiling: You have the right to opt out of processing of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Restrict or Limit Processing: You have the right to restrict or limit our use of your Sensitive Personal Information to only those uses necessary to perform the services you have requested.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights under applicable law. We will not deny you services, charge you different prices, provide you a different level of service, or suggest that you will receive a different price or level of service for exercising your rights.
Right to Withdraw Consent: Where we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal.
Right to Appeal: If we deny your privacy request, you have the right to appeal our decision by contacting us at the address provided in Section 16. If your appeal is denied, you may contact your state Attorney General, the Office of the Privacy Commissioner of Canada, or the applicable provincial privacy commissioner to file a complaint.

8.1 How to Exercise Your Rights

You may exercise any of your privacy rights by: (a) emailing us at info@applisolutions.com; (b) submitting a request through the “Privacy Rights” page on our Platform; or (c) mailing a written request to 72 Burling Pl, Newmarket, ON L3Y 5W4, Canada. We will respond to all verified requests within the timeframes required by applicable law (generally, forty-five (45) calendar days from receipt, with a possible extension of an additional forty-five (45) days upon notice to you if reasonably necessary).

8.2 Verification

To protect your privacy and security, we will verify your identity before fulfilling any privacy request. Verification may require you to provide your name, email address, and other information sufficient to match you to our records. We will not fulfill a request if we are unable to verify your identity. Authorized agents may submit requests on your behalf with proper written authorization and verification of both the agent’s and the consumer’s identity.

9. Data Retention

We retain your Personal Information only for as long as is reasonably necessary to fulfill the purposes for which it was collected, as described in this Policy, and to comply with our legal, regulatory, and contractual obligations. Specific retention periods are as follows:

Account and Profile Information: Retained for the duration of your account and for a period of three (3) years following account deletion, to comply with legal obligations and to resolve disputes.
Resumes and Application Materials: Retained for two (2) years following your last application activity, unless you request earlier deletion.
Interview Video Recordings and Biometric Information: Retained for no longer than three (3) years from your last interaction with the Platform, or until the purpose for collection has been satisfied, whichever is earlier, in compliance with BIPA and other biometric privacy laws.
Work Trial Data: Retained for two (2) years following completion of the Work Trial, or as required by the applicable Hiring Manager’s record retention obligations, whichever is longer.
Communications and Messages: Retained for the duration of your account and for one (1) year following account deletion.
Usage Data and Logs: Retained for up to two (2) years for analytics and security purposes.
Consent Records: Retained for a minimum of three (3) years following the expiration or withdrawal of consent, as required by CASL and other applicable laws.

Upon expiration of the applicable retention period, your Personal Information will be permanently deleted or irreversibly de-identified using commercially reasonable methods. We conduct periodic reviews of our data retention practices to ensure compliance with applicable laws.

10. Data Security

We implement and maintain commercially reasonable administrative, technical, and physical security measures designed to protect your Personal Information from unauthorized access, disclosure, alteration, destruction, and misuse. These measures include but are not limited to:

Encryption of Personal Information in transit using TLS 1.2 or higher and at rest using AES-256 encryption or equivalent.
Access controls, including role-based access and the principle of least privilege, restricting access to Personal Information to authorized personnel who require access for legitimate business purposes.
Multi-factor authentication for all administrative and internal systems.
Regular security assessments, vulnerability scans, and penetration testing conducted by qualified independent third parties.
Intrusion detection and prevention systems, firewalls, and continuous monitoring of our systems and networks.
Employee training on data protection, privacy, and security best practices.
Incident response procedures designed to promptly detect, contain, investigate, and remediate security incidents.
Physical security measures at data centers, including access controls, surveillance, and environmental protections.

Notwithstanding the foregoing, no method of transmission over the Internet and no method of electronic storage is completely secure. While we strive to protect your Personal Information, we cannot guarantee its absolute security. In the event of a data breach involving your Personal Information, we will notify you and the appropriate regulatory authorities in accordance with all applicable breach notification laws, including but not limited to the PIPEDA breach notification requirements, CCPA/CPRA, and all applicable state breach notification statutes.

11. Cross-Border Data Transfers

Your Personal Information may be processed and stored in the United States, Canada, or other countries where our service providers maintain facilities. These countries may have data protection laws that differ from those in your jurisdiction of residence.

Where your Personal Information is transferred across national borders, we ensure that appropriate safeguards are in place, including contractual data protection clauses, privacy certifications, or other mechanisms recognized under applicable law. For transfers of Personal Information from Canada, we comply with PIPEDA’s requirements for cross-border data transfers, including ensuring that contractual or other means are in place to provide a comparable level of protection. We remain accountable for your Personal Information regardless of where it is processed.

For transfers from the European Economic Area, the United Kingdom, or Switzerland, we rely on applicable adequacy decisions and standard contractual clauses approved by the relevant authorities.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your use of the Platform. Cookies are small text files placed on your device that help us recognize your browser, remember your preferences, and improve your experience.

12.1 Types of Cookies We Use

Strictly Necessary Cookies: Required for the operation of the Platform, including session management and security. These cookies cannot be disabled.
Functional Cookies: Enable personalized features such as remembering your language preferences and settings.
Analytics Cookies: Help us understand how users interact with the Platform, including page views, session duration, and navigation patterns. We use third-party analytics providers, such as Google Analytics, to collect and analyze this data.
Advertising and Targeting Cookies: Used to deliver advertisements relevant to your interests and to measure the effectiveness of advertising campaigns. These cookies may track your activity across different websites.

12.2 Your Cookie Choices

You may manage your cookie preferences through the cookie consent banner displayed upon your first visit to the Platform, through your browser settings, or by adjusting your preferences in the “Cookie Settings” section of your account. Please note that disabling certain cookies may limit the functionality of the Platform. We honor GPC signals as a valid opt-out of cookies used for targeted advertising, as required by applicable law.

13. Children’s Privacy

The Platform is not intended for use by individuals under the age of sixteen (16). We do not knowingly collect Personal Information from individuals under sixteen (16) years of age. If we become aware that we have inadvertently collected Personal Information from a child under the applicable minimum age, we will promptly delete such information from our records. If you believe that a child under sixteen (16) has provided us with Personal Information, please contact us immediately at the address provided in Section 16.

For users between the ages of sixteen (16) and eighteen (18), or the age of majority in their jurisdiction, parental or guardian consent may be required for certain features. We comply with COPPA, the CCPA’s enhanced protections for minors, the CTDPA’s age-appropriate design code requirements, and all other applicable laws governing the collection and processing of minors’ personal data.

We will never sell or share the Personal Information of users known to be under the age of eighteen (18) for targeted advertising purposes.

14. Commercial Electronic Messages and Anti-Spam Compliance

14.1 CAN-SPAM Act Compliance (United States)

All commercial electronic messages sent by us comply with the CAN-SPAM Act of 2003. Each commercial message will: (a) accurately identify us as the sender; (b) include a clear and conspicuous subject line that is not deceptive or misleading; (c) include our valid physical postal address; (d) include a clear and conspicuous mechanism for you to opt out of receiving future commercial messages from us; and (e) honor opt-out requests within ten (10) business days of receipt.

14.2 CASL Compliance (Canada)

All commercial electronic messages sent to recipients in Canada comply with Canada’s Anti-Spam Legislation (CASL). We will not send you commercial electronic messages unless: (a) we have obtained your express consent through a clear, affirmative opt-in mechanism that identifies us, describes the purpose of the messages, and includes our contact information; or (b) we have implied consent based on an existing business relationship or other ground recognized under CASL. Each commercial electronic message will: (i) clearly identify us as the sender; (ii) include our contact information (mailing address and either a phone number, email address, or web address); and (iii) include a clear and functional unsubscribe mechanism. We will honor unsubscribe requests within ten (10) business days. We maintain records of all consents for a minimum of three (3) years following the expiration or withdrawal of consent.

15. Jurisdiction-Specific Disclosures

15.1 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. In the preceding twelve (12) months, we have collected, disclosed for a business purpose, and may have sold the categories of Personal Information described in this Policy. You have the right to: know what Personal Information we collect and how it is used and shared; request deletion of your Personal Information; opt out of the sale and sharing of your Personal Information; limit the use of your Sensitive Personal Information; correct inaccurate Personal Information; and receive equal service and pricing regardless of whether you exercise your rights. California residents may designate an authorized agent to submit requests on their behalf by providing a signed, written authorization. We do not use or disclose Sensitive Personal Information for purposes other than those permitted under the CCPA/CPRA.

15.2 Illinois Residents (BIPA and AIVIA)

If you are an Illinois resident, you have additional rights under the Biometric Information Privacy Act (BIPA) and the Artificial Intelligence Video Interview Act (AIVIA). Your rights under BIPA are described in Section 5 of this Policy. Under AIVIA, if AI is used to analyze your video interview, we will: (a) notify you in writing prior to the interview that AI may be used; (b) provide you with information about how the AI works and what characteristics it evaluates; (c) obtain your consent before using AI to analyze the interview; and (d) upon your request, destroy your video recording within thirty (30) days of receipt of such request. Under Illinois HB 3773, effective January 1, 2026, we will notify you when AI is used in recruitment, hiring, promotion, or other employment decisions affecting you through the Platform, and we will not use AI in any manner that results in discrimination based on any protected class under the Illinois Human Rights Act.

15.3 Colorado Residents

If you are a Colorado resident, you have additional rights under the Colorado Privacy Act and, effective June 30, 2026, the Colorado AI Act (SB 24-205). Under the Colorado AI Act, to the extent we deploy high-risk AI systems that make or substantially influence consequential employment decisions, we will: use reasonable care to prevent algorithmic discrimination; maintain a risk management policy and program; conduct impact assessments; provide notice to affected individuals; and offer an opportunity to appeal adverse decisions. You may opt out of profiling and targeted advertising as described in Section 8.

15.4 Canadian Residents (PIPEDA, Law 25, CASL)

If you are a Canadian resident, your Personal Information is protected under PIPEDA and, where applicable, provincial privacy legislation including Quebec’s Law 25, Alberta’s PIPA, and British Columbia’s PIPA. Under PIPEDA’s ten Fair Information Principles, you have the right to: know why your Personal Information is being collected; expect that it will be used only for the purposes for which it was collected; have your Personal Information collected only by fair and lawful means; have your Personal Information protected by appropriate security safeguards; access and request correction of your Personal Information held by us; and challenge our compliance with PIPEDA by filing a complaint with the Office of the Privacy Commissioner of Canada. We have appointed a Privacy Officer who is accountable for our compliance with PIPEDA and who can be contacted at the address provided in Section 16. For Quebec residents, we comply with Law 25’s enhanced requirements regarding privacy impact assessments, consent, automated decision-making, and the right to data portability.

15.5 Other U.S. State Residents

Residents of Virginia, Connecticut, Oregon, Montana, Texas, Delaware, New Hampshire, New Jersey, Maryland, Minnesota, Indiana, Kentucky, Rhode Island, Iowa, Tennessee, Utah, Arkansas, and all other states with applicable comprehensive privacy laws have the rights described in Section 8 of this Policy, in addition to any state-specific rights provided under their respective statutes. We honor all such rights to the fullest extent required by law. If you are uncertain about your rights, please contact us at the address provided in Section 16.

16. Contact Information and Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your privacy rights, please contact us:

Privacy Officer: Kyan Chiang, Appli Solutions
Email: info@applisolutions.com
Mailing Address: 72 Burling Pl, Newmarket, ON L3Y 5W4, Canada
Online Form: Privacy Rights Request Form

For complaints regarding our compliance with PIPEDA, you may also contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3, or at 1-800-282-1376. For complaints regarding provincial privacy laws, you may contact the applicable provincial or territorial privacy commissioner.

17. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. When we make material changes to this Policy, we will: (a) update the “Last Updated” date at the top of this Policy; (b) post a prominent notice on the Platform; (c) send you an email notification at the email address associated with your account at least thirty (30) calendar days before the changes take effect (to the extent required by applicable law); and (d) where required by applicable law, obtain your consent to the changes before they take effect. Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the changes. If you do not agree with any changes, you must discontinue use of the Platform and delete your account.

18. Governing Law and Dispute Resolution

This Privacy Policy and any disputes arising out of or related to this Policy or our data practices shall be governed by and construed in accordance with the laws of the jurisdiction in which you reside, to the extent that such laws provide mandatory protections that cannot be waived by contract. Nothing in this Policy shall be construed to limit, restrict, or waive any rights you have under applicable privacy laws.

For users residing in Canada, you may file a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner. For users residing in the United States, you may file a complaint with your state Attorney General or the Federal Trade Commission. Where permitted by applicable law, disputes may also be resolved through binding arbitration, as described in our Terms of Service, except that you shall not be required to arbitrate any claim arising under a state or federal privacy statute that prohibits mandatory arbitration.

19. Accessibility

We are committed to ensuring that this Privacy Policy is accessible to individuals with disabilities. If you require this Policy in an alternative format (such as large print, braille, or audio), please contact us at the address provided in Section 16, and we will provide it to you within a reasonable timeframe at no additional cost.

20. Severability

If any provision of this Privacy Policy is found to be unlawful, void, or unenforceable by a court of competent jurisdiction, that provision shall be severed from this Policy and shall not affect the validity and enforceability of the remaining provisions, which shall continue in full force and effect.

21. Entire Agreement

This Privacy Policy, together with our Terms of Service and any supplemental privacy notices provided at the time of data collection, constitutes the entire agreement between you and the Company with respect to the collection, use, disclosure, and processing of your Personal Information through the Platform. This Policy supersedes all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding the subject matter hereof.