Privacy Policy for OnMyGrad and AIinterviewCoach.io

At OnMyGrad and AIinterviewCoach.io, we are committed to protecting your privacy and ensuring compliance with applicable regulations, including the General Data Protection Regulation (GDPR). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you access our platforms at app.onmygrad.space and aiinterviewcoach.io.

Software as a Service (SaaS) refers to both OnMyGrad and AIinterviewCoach.io platforms, which provide cloud-based services that facilitate interactions between job candidates and employers through video interviews and application processes.

1. Information We Collect We may collect the following types of personal data:

• Identification Information: Name, email address, phone number
• User-Generated Content: Videos, resumes, and other documents you upload
• Technical Data: IP address, browser type, operating system
• Usage Data: Information about how you use our platforms and services When using our SaaS, you may upload and share your own documents (the “User Generated Content”). Your video and audio recordings may include Personal Data, Skills, and other information from your resume. While providing our SaaS, we collect and store the following information about your Video Interview:
• Email ID
• Phone Number
• Details within a Resume
• LinkedIn Profile
• IP Address

2. Purpose of Data Processing We process your personal data for several key purposes:

• Service Provision: Your data is essential for us to provide our services effectively. This includes managing your account, facilitating video interviews, and processing applications.
• User Interaction: We may use your information to communicate with you regarding updates, notifications, and customer support inquiries.
• Data Analysis: We analyze user behavior to improve our platforms and services. This includes assessing how users interact with our features to enhance user experience.
• Research and Development: Your anonymized data may be used for research purposes to develop new features or improve existing functionalities on our platforms.
• With your consent given according to Art. 9 II a GDPR to the respective employer, the Video Recording will be used in order to process data as follows:
• Video Analysis: We evaluate your Video Interview recordings using computer vision. The algorithm analyzes your facial expressions to look for positive or negative emotions. By using our SaaS, you expressly agree to the quantification and evaluation of your recorded facial expressions.
• Voice Analysis: Our SaaS records your voice and quantifies voice patterns (e.g., arousal and valence scores). The quantified voice patterns are evaluated regarding different effects (e.g., emotions) to provide feedback on the effects of your voice.
• Speech Analysis: The SaaS quantifies your voice-to-text (i.e., spoken words) and transcribes them. The spoken words are analyzed with existing NLP libraries (e.g., sentiment) to provide feedback on clarity of speech, word count, etc. By using our SaaS, you expressly consent to the processing and storage of this information. You can withdraw your consent at any time. You are not obliged to participate in Video Recruiting by law or by contract; you can proceed in the application process if you decide not to participate.

3. Legal Basis for Processing We process your personal data based on the following legal grounds:

• Consent: When you provide explicit consent for us to process your personal data.
• Contractual Necessity: To fulfill our contractual obligations to you.
• Legal Compliance: To comply with applicable laws and regulations.

4. Use of Platform 4.1 Grant of Rights OnMyGrad and AIinterviewCoach.io hereby grant you a limited, terminable, non-exclusive right to access and use the Platform for your personal, non-commercial purposes as follows:

• Seeking employment opportunities;
• Applying for jobs; and
• Any other purposes reasonably related to the purposes specified above. 4.2 Personal Use Your permission to access and use the Platform is personal to you and is non-transferable and non-assignable. 4.3 Participation in Activities As part of the application process for employment with an Employer, you may be required to participate in activities such as video and audio interviews, psychometric assessments, and gaming tests. You acknowledge and agree that your participation in such activities on the Platform may be recorded, and you hereby consent to such recording, including the use of your name, likeness, voice, and persona in connection with your use of the Platform. 4.4 Prohibited Uses You may not access or use the Platform:
• For any unlawful or fraudulent purpose;
• To disseminate or publish any content that is false, inaccurate, unlawful, harassing, defamatory, misleading, abusive, threatening, harmful, violent, obscene, vulgar, or otherwise objectionable;
• To copy, reproduce, duplicate, compile, sell, resell or otherwise exploit in any manner any content on the Platform;
• To modify, adapt, translate, reverse engineer, decompile, or disassemble any part of the Platform without our prior consent;
• To interfere with any other person’s access to or use of the Platform;
• To post any content or apply for any job on behalf of another party;
• To access information not intended for you or to access a server or account which you are not authorized to access;
• To interfere with or disrupt the operation of the Platform or violate any requirements or regulations of such networks;
• To create a database by systematically downloading and storing content available on the Platform;
• To sell or promote products or services; and
• In any manner that breaches this Agreement. 4.5 Right to Waive Conditions We reserve the right to waive any of the conditions in Clause 4.4 either generally or in specific instances. 4.6 Monitoring Accounts We may remove, edit, suspend, block, and/or monitor user accounts that we determine violate the terms of this Agreement or any applicable law.

5. Availability of Services 5.1 Reasonable Efforts We will apply reasonable efforts to ensure that the Platform is available at all times. However, we cannot guarantee that the Platform or any part or feature thereof will always be available or error-free. 5.2 Maintenance Restrictions Access to the Platform may be restricted from time to time to allow for repair, maintenance, or updates. We will attempt to restore access as soon as reasonably possible.

6. Intellectual Property Subject to Clause 7 (User Content), all Intellectual Property Rights in the Platform are owned by OnMyGrad and AIinterviewCoach.io. You may not reproduce, modify, distribute or otherwise use for commercial purposes any such content without our written consent unless permitted by law.

7. Data Retention Period We retain your personal data for a period of two years from the date of collection. After this period, we will securely delete or anonymize your data unless further retention is required by law.

8. Data Transfer to Third Parties We reserve the right to transfer your personal data to our partners as necessary to provide our services. This includes transferring data to employers companies, academic institutions, research institutes or companies involved in your application process. We ensure that any third parties receiving your data comply with applicable data protection laws.

9. User Rights Under GDPR As a user of our platforms under GDPR:

• Right to be Informed: You have the right to be informed about how your personal data is processed.
• Right of Access: You can request access to your personal data in JSON format along with supplementary information in your privacy settings.
• Right to Rectification: You have the right to correct inaccurate or incomplete personal data via your profile page.
• Right to Erasure: You have the right to request deletion of your personal data where there is no compelling reason for its continued processing.
• Right to Restrict Processing: You can request that we limit processing of your personal data.
• Right to Data Portability: You have the right to obtain a copy of your personal data in a structured format from your privacy settings.
• Right to Object: You can object to processing based on legitimate interests by changing email settings or contacting us directly. To exercise these rights or if you have questions regarding them, please contact us using the contact details provided above.

10. How We Use Your Data We prioritize transparency in how we handle your personal data:

• Service Provision
• Communication
• Data Analysis
• Research & Development

11. Binding Agreement 11.1 Overview OnMyGrad and AIinterviewCoach.io provide platforms that facilitate interactions between potential employers and job candidates through their SaaS offerings. The terms of this Agreement are between you and OnMyGrad and AIinterviewCoach.io; your access and use of our platforms constitutes your consent to this Agreement and its terms. 11.2 Updates to Agreement We may update this Agreement from time to time; notice will be provided via email or announcements on our platforms.

12. Security Measures We implement appropriate technical measures to protect your personal data against unauthorized access.

13. Changes to This Privacy Policy We may update this Privacy Policy from time to time; changes will be posted on this page with an updated effective date.

By using our platforms (the SaaS), you consent to the terms outlined in this Privacy Policy. If you do not agree with these terms, please do not use our services. Feel free to contact us through info@onmygrad.com with any questions about these terms or any requests.

Last Update: 24 November 2024

# Personal Data (Privacy) Policy Statement (“Privacy Policy”) OnMyGrad Limited and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”; if the context requires or permits, “Company” may refer to any one of OnMyGrad Limited and/or its subsidiary(ies) and/or affiliate(s)) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via OnMyGrad.com, its sub-domains, any other websites, media platforms or applications including mobile applications operated/developed by the Company (hereinafter collectively referred to as the "Channels" ) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (“User(s)”) except to the authorized persons listed under paragraph 3 below.

This Privacy Statement is applicable to both registered and unregistered Users, and the terms herein may be updated, revised, varied and/or amended from time to time as OnMyGrad Limited may deem necessary and/or appropriate.

If Users have questions or concerns regarding this Privacy Policy, they should first contact the Human Resources Department of the Company, whose contact details are set out under Paragraph 13 entitled “Enquiries” below.

1. Purpose of Collection of Personal Data In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so. The Company’s purposes for collection of information and data on the Channels include but not limited to the following:

• for the daily operation of the services provided to Users;
• to identify Users who have posted views or comments or such other information (collectively “ Information”) on the Channels;
• to identify Users who have viewed the Information posted on the Channels;
• to provide the Users career coaching service or other related services offered by the Company;
• to handle and follow up service calls, enquiries, requests and complaints;
• to provide Users with event information, marketing and promotional materials for their enjoyment of benefits as members of the Channels (for further details, please refer to paragraph 4 headed “ Subscription of Newsletter/Promotional Materials/Marketing Materials” below);
• to identify Users who have enjoyed their benefits as members of the Channels by receiving and using marketing and promotional materials;
• to allow members of the Channels to enjoy their benefits as members by enrolling for special events hosted by the Company;
• to contact Users regarding administrative notices and communications relevant to the Users’ membership account maintained with the Company (if any) and/or the services offered by the Company;
• to design and provide products and services to Users in relation to the above purposes;
• to compile and analyze aggregate statistics about the Users’ use of the Channels and service usage by the Users for the Company’s internal use; and
• to facilitate the Company to use the Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events and/or promotions of the Company and/or its clients.

The Company strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove. If the Company requires the use of Users’ personal data for a purpose other than those set out hereinabove, the Company may request the Users’ prescribed consent to the same. Collection of Personal Data The Company may collect personal information and/or data about a User such as his/her name, log-in ID and password, address, email address, phone number, sex, education history, work history, and other personal information that is/are not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from a User in connection with contests, surveys, or special offers. Only duly authorized staff of the Company will be permitted to access the Users’ personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Paragraph 3 entitled “Disclosure or Transfer of Data”. Disclosure or Transfer of Data The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following. Generally speaking, the Company will only disclose and/or transfer Users’ personal information and/or data to the Company’s personnel and staff for the purpose of providing services to Users. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances: where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorized by the Company to use such information and/or data. where the information and/or data is disclosed and/or transferred to any agents or associates of the Company who have been duly authorized by the Company to use such information and/or data; where the Company needs to protect and defend its rights and property; where the Company considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Channels; and where the Company deems necessary in order to maintain and improve the services on the Channels.

Personal data collected via the Channels may be transferred, stored and processed in any country in which the Company operate. By using the Channels, Users are deemed to have agreed to, consented to and authorized the Company to disclose and/or transfer their personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the Users’ country.' Subscription of Newsletter/Promotional Materials/Marketing Materials The Company may from time to time send to members and Users of the Channels, by way of emails and/or short message service (SMS) notifications, newsletters, marketing and promotional materials and information regarding the Company or its third-party advertisers’ products, services and the like based on the personal information and data that the Users have provided to the Company. The Company may use Users’ data in direct marketing and the Company requires the Users’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that: the name, log-in ID and password, contact details, age, sex, date of birth, country of residence, nationality, education level and work experience of Users held by the Company from time to time may be used by the Company and/or its authorised personnel or staff in direct marketing; the following classes of services, products and subjects may be marketed: career related information and services; job related products and services; special events hosted by the Company for members and Users, including but not limited to courses, workshops, and competitions; reward, loyalty or privileges programmes and related products and services; special offers including coupons, discounts nad discounts products and services offered by the Company and its advertisers (the names of such entities can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); donations and contributions for charitable and/or non-profit making purposes;

The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or: third party service providers providing the products, services and subjects listed in paragraph (b) above; and charitable or non-profit marking organizations; in addition to marketing the above services, products and subject itself, the Company also intends to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products and subjects, and the Company requires the Users’ written consent (which includes an indication of no objection) for that purpose; the Company may receive money or other property in return for providing the data to the other persons in paragraph (d) above and, when requesting the Users’ written consent as described in paragraph (d) above, the Company will inform the Users if the Company receives any money or other property in return for providing the data to the other persons. Suitable measures are implemented to make available to such members the options to “opt-out” of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the membership registration or user account maintenance webpage, or clicking on the automatic link appearing in each newsletter/message, or contact the Customer Human Resource Department of the Company, whose contact details are set out under Paragraph 13 entitled “Enquiries” below.

Access to or request for correction of data Any User is entitled to request access to or make amendments to his/her own personal information and data kept with the Company by contacting the Human Resources Department of the Company, whose contact details are set out under Paragraph 13 entitled “Enquiries” below. In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to a User’s requests within 40 days of his/her request and will endeavor to do so wherever possible. Cookies and Log Files The Company does not collect any personally identifiable information from any Users whilst they visit and browse the Channels, save and except where such information of the Users is expressly requested. When Users access the Channels, the Company records their visits only and do not collect their personal information or data. The Channels’ server software will also record the domain name server address and track the pages the Users visit and store such information in “cookies”, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring. The Company and third-party vendors engaged by the Company use the Company’s cookies and third-party cookies, such as the Google Analytics cookies, together to inform, optimize, and serve marketing materials based on the Users’ past visits to the Channels. The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns and administer the Channels. Such automatically collected information and data will not be disclosed save and except in accordance with the Paragraph 3 entitled “Disclosure or Transfer of Data”. Google Analytics Google Analytics Advertising Features (“Features”) are implemented on the Channels. The Features which the Company has implemented are based on Google Analytics Demographics and Interest Reporting. Google Analytics is a web analysis service provided by Google which utilizes the data collected to track and examine the use of the Channels, to prepare reports on the Users’ activities and share them with other Google services. Google may use the data collected to contextualize and personalize the marketing materials of its own advertising network. Links to Other Websites / Media Platforms / Applications The Channels may provide links to other websites / media platforms / applications which are not owned or controlled by the Company. Personal information and data from Users may be collected on these other websites / media platforms / applications when Users visit such websites / media platforms / applications and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Channels which grants Users access to another website / media platforms / applications, the protection of Users’ personal information and data which are deemed to be private and confidential may be exposed in these other websites / media platforms / applications. Non-registered Users who gain access to the Channels via their accounts in online social networking tools (including but not limited to Facebook) are deemed to have consented to the terms of this Privacy Policy, and such Users’ personal data which they have provided to those networking tools may be obtained by the Company and be used by the Company and its authorized persons in and outside of the User’s country for the purpose of providing services and marketing materials to the Users. These Users are deemed to have consented to the Company and its authorized personnel’s access and use of their personal data so obtained, subject to the other provisions of the Privacy Policy. This Privacy Policy is only applicable to the Channels. Users are reminded that this Privacy Policy grants no protection to Users’ personal information and data that may be exposed on websites / media platforms / applications other than the Channels, and the Company is not responsible for the privacy practices of such other websites / media platforms / applications. Users are strongly recommended to refer to the privacy policy of such other websites / media platforms / applications. The Company assumes no responsibility or liability for Users’ use of such other websites / media platforms / applications. Security The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data will be protected against unauthorized access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data. All personal information and data provided by Users are only accessible by the authorized personnel of the Company or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected, unless Users request the Company to cease to hold the same or terminate his/her membership account with the Company. Such request may render the Company unable to further provide its services, information and/or promotional materials for your benefit in the future. Registered Users should safeguard his/her unique Username and Password by keeping it secret and confidential and never share these details with anyone. The Company uses third party payment gateway service providers to facilitate electronic transactions on the Channels. Regarding sensitive information provided by Users, such as credit card number for completing any electronic transactions, the web browser and third party payment gateway communicate such information using secure socket layer technology (SSL). The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to protect Users’ personal information and data against unauthorized access, the Company cannot guarantee its absolute security. Access to or request for correction of data The Company would like to help Users keep his/her personal information accurate and up-to-date. To view or edit personal information that has been stored at the Channels, please email to info@onmygrad.com Any User may make a data access request or a data correction request at any time by contacting the Customer Relationship Executive of the Company, whose contact details are set out under Paragraph 13. entitled “Enquiries ” below. In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to Users’ request within 40 days of his/her request and will endeavour to do so wherever possible. Please note that if Users do make a data access request and if the Company deems the same as appropriate, only a copy of your personal data would be provided. Retention of Personal Data Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company until the User requests the Company in writing to erase his/her own personal information and/or data from the Company's database or to terminate his/her membership of the Channels. Changes in this Privacy Policy The Company reserves the right to update, revise, modify or amend this Privacy Policy in the following manner at any time as the Company deems necessary and Users are strongly recommended to review this Privacy Policy frequently. If the Company decides to update, revise, modify or amend this Privacy Policy, the Company will post those changes to this webpage and/or other places the Company deems appropriate so that Users would be aware of what information the Company collects, how the Company uses it, and under what circumstances, if any, the Company discloses it. If the Company makes material changes to this Privacy Policy, the Company will notify Users on this webpage, by email, or by means of a notice on the home page of the Company. Enquiries For any query, please contact our Human Resource Department with contact details as follows: OnMyGrad Limited Email: info@onmygrad.com Tel: +852 55751000

# Privacy Policy of www.onmygrad.space, www.onmygrad.com, aiinterviewcoach.io and OnMyGrad Mobile Application Last updated: November 24, 2024 OnMyGrad recognizes that your privacy is very important and we take it seriously. This Privacy Policy (“Privacy Policy”) describes our policies and procedures on the collection, use, disclosure, and sharing of your personal information or personal data when you use the OnMyGrad Platform. This Privacy Policy applies to activities by OnMyGrad Limited and its affiliates and subsidiaries (collectively “OnMyGrad,” “we” or “us”). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service. This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible from www.onmygrad.com. Information Collection And Use We collect information directly from individuals, from third parties, and automatically through the OnMyGrad Platform. Account and Profile Information: When you create an account and profile on the OnMyGrad Platform, we collect your name, contact information, and other information you provide, such as topics that you know about or find interesting. Your name, photo, and any other information that you choose to add to your public-facing profile will be available for viewing to users of the OnMyGrad Platform. Once you create a profile, other users will be able to see in your profile certain information about your activity on the OnMyGrad Platform, such as the questions and answers you post, your followers and who you follow, topics of interest to you, the information you list as credentials, and your edits to Your Content. For more information about your choices for publicly displayed information, see the section below about Your Choices. Your Content: We collect and store the information and content that you post to the OnMyGrad Platform, including your questions, answers, photos, comments, learning materials and activities. Unless you have posted certain content anonymously, Your Content, date and time stamps, and all associated comments are publicly viewable on the OnMyGrad Platform, along with your name. This also may be indexed by search engines and be republished elsewhere on the Internet in accordance with our Terms of Service. For more information about what you can change, see the below section on Your Choices. Communications. When you communicate with us (via email, phone, through the OnMyGrad Platform, or otherwise), we may maintain a record of your communication. Automatically Collected Information About Your Activity. We use cookies, log files, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the OnMyGrad Platform. We also collect and may store information that your computer or mobile device provides to us in connection with your use of the OnMyGrad Platform such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the OnMyGrad Platform, even if you have not created an account. For more information, see the “Cookies and Tracking” section below. Engagement. We collect browsing information – such as IP address and location, date and time stamp, user agent, OnMyGrad cookie ID (if applicable), URL, unique advertising or content identifiers (if applicable) and time zone, and other information about user activities on the OnMyGrad Platform, as well as on third party sites and services that have embedded our widgets, plug-ins, buttons, or related services. We may also receive information about you from third parties, such as other users, partners (including ad partners), or our affiliated companies. How We Use Your Information We do not sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes. OnMyGrad uses the information we collect for the following purposes: Provide our Services. To provide you the services we offer on the OnMyGrad Platform, communicate with you about your use of the OnMyGrad Platform, respond to your inquiries, provide troubleshooting, and for other customer service purposes. Personalization. To tailor the content and information that we may send or display to you in the OnMyGrad Platform, to suggest circles, followers and content, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the OnMyGrad Platform. Advertising. To display interest-based advertising to you in the OnMyGrad Platform, to improve our advertising and measurement systems so we can show you relevant ads, and to measure the effectiveness and reach of ads and services. Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third party products and services. Analytics. To gather metrics to better understand how users access and use the OnMyGrad Platform; to evaluate and improve the OnMyGrad Platform, including the Ad Services and personalization, and to develop new products and services. Comply with Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes. Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

How We Share Your Information We share information as set forth below, and where individuals have otherwise consented: Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers, as well as those who assist us in providing the Ad Services. Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of OnMyGrad Limited, whose use and disclosure of your personal information is subject to this Privacy Policy. Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event. Legally Required. We may disclose your information if we are required to do so by law. Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of OnMyGrad, its users, or others. Your Content and Activity. Your Content, including your name, profile picture, profile information, and certain associated activity information is available to other users of the OnMyGrad Platform and may be viewed publicly. Public viewing includes availability to non-registered visitors and can occur when users share Your Content across other sites or services. In addition, Your Content may be indexed by search engines. See the section below about Your Choices for information about how you may change how certain information is shared or viewed by others. Metrics. We may share with users of our advertisers or publishers aggregate statistics, metrics and other reports about the performance of their ads or content in the OnMyGrad Platform such as the number of unique user views, demographics about the users who saw their ads or content, conversion rates, and date and time information. We do not share IP addresses or personal information. We may also allow our advertisers or publishers to collect information about the performance of their ads or content. Anonymized and Aggregated Data. We may share aggregated or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual. Cookies Tracking We and our third party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on the OnMyGrad Platform and across third party sites or online services. We may combine this information with other information we collect about users. Below, we provide a brief summary these activities. Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember users who are logged in, to understand how users navigate through and use the OnMyGrad Platform, and to display personalized content and targeted ads (including on third party sites and applications). Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar in function to cookies, which we use to track the online movements of users of the OnMyGrad Platform and the web pages and to personalize content. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications. Analytics Tools. We may use internal and third party analytics tools, including Google Analytics. The third party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

OnMyGrad Ads and Personalization We may display personalized content (including from third party publishers) and personalized ads (including sponsored content), based on information that we have collected via the OnMyGrad Platform, and through our widgets, and buttons embedded on third party sites. We also may report aggregated or de-identified information about the number of users that saw a particular ad or content and related audience engagement information to users of our advertisement services and to publishers of content on the OnMyGrad Platform. Users of our advertisement services may also provide us with information as part of their ad campaigns, including customer list information (e.g., email addresses and demographic or interest data) with us in order to create customized audiences for their ad campaigns; we only use this information to facilitate the particular user’s campaign (including ad metrics and reporting to that user) or for fraud detection and security purposes; and we do not disclose this information to third parties (other than our service providers) unless required by law. We also do not disclose to the users of our advertisement services the names or identities of their customers that were successfully reached as part of such campaigns. We may also work with third parties such as network advertisers to serve ads on the OnMyGrad Platform and on third-party websites or other media (e.g., social networking platforms), such as Google AdSense (more info here)and Facebook Audience Network (more info here). These third parties may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. How We Protect Your Information The security of your information is important to us. OnMyGrad has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using the OnMyGrad Platform on a shared or unsecured device. Access and Amend Your Information You may update or correct your account information at any time by logging in to your account. You may also make a number of other adjustments to settings or the display of information about you as described in more detail in the following section about Your Choices. Your Choices You may, of course, decline to submit information through the OnMyGrad Platform, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, limit the information shared within the OnMyGrad Platform about you, and otherwise amend certain privacy settings. Here is some further information about some of your choices: Anonymous Posts.You may post certain content anonymously, including questions and answers. In such event, your name is not displayed along with the content, and OnMyGrad does not associate such content with your user ID and other profile data. Your Content.You may edit or delete the answers that you post at any time. Any questions you have posted may remain on the OnMyGrad Platform and be edited by other users. Any deleted content will be removed from third party sites from which it has been shared via OnMyGrad’s standard sharing features; however we have no control over deletions or changes to Your Content if it has been shared manually by others. When you make edits to Your Content, other users will be able to see the history of those edits in your profile activity and on content edit logs. Emails and Communications. When you join the OnMyGrad Platform by signing up for an account or creating a profile, as part of the service, you will receive the newsletters containing content that we believe may match your interests. You can manage your email and notice preferences in your account profile settings, under your Emails and Notifications settings. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you transactional e-mails about your account or any services you have requested or received from us. Third parties may comment on your postings within the OnMyGrad Platform. In your profile, under your Privacy Settings, you can adjust whether to allow people to comment on your answers and posts. You can also adjust permissions about who you allow to send you messages on the OnMyGrad Platform. Followers. You can block the ability of other OnMyGrad users to follow you by selecting the setting for this in the other user’s profile. You can change whether or not you follow other users. Topics. You can change topics that you follow or that your profile lists as areas that you know about. Deleted Account. If you choose Delete Your Account in your privacy settings, then all of Your Content will be removed from public visibility on the OnMyGrad Platform, and it may not be restored by us, even if you change your mind. Transferring Your Data OnMyGrad is headquartered in the HKSAR, PRC, and has operations, entities and service providers throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Children’s Privacy We do not knowingly collect or solicit personal information from anyone under the age of 15 or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information. Links to Other Websites The OnMyGrad Platform may contain links to third party sites or online services. We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy. Changes to Our Privacy Policy If we change our privacy policies and procedures, we will post those changes on this page. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice in the OnMyGrad Platform or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes. Contact Us If you have any questions about this Privacy Policy, please contact us: By email: info@onmygrad.com