Team Theory | The Private Equity Talent Intelligence Engine

ppol, Inc. d/b/a Team Theory ("Team Theory," "we," "us," or "our") respects your privacy and is committed to protecting the personal information that we collect, use, and disclose. This Privacy Policy describes how we collect, use, share, and protect personal information in connection with the Team Theory website located at https://teamtheory.ai (the "Site") and our AI-powered talent intelligence platform (the "Service").

This Privacy Policy applies to personal information we collect from: (a) visitors to our Site; (b) individuals who create accounts or register for the Service; and (c) individuals whose personal information is processed through the Service by our customers. If you are a customer of Team Theory, your use of the Service is also governed by the Team Theory Terms of Service and any applicable Order Form.

Quick Reference - Your Privacy Rights

We are committed to transparency and compliance with global privacy laws including GDPR and CCPA. You have the right to:

• Access your personal data

• Request data deletion

• Correct inaccurate data

• Data portability

• Withdraw consent

• Object to processing

1. INFORMATION WE COLLECT

1.1 Information You Provide to Us

We collect personal information that you voluntarily provide to us, including:

Account Information: When you register for the Service, we collect your name, email address, organization name, job title, phone number, and other information you provide during the registration process.

Payment Information: If you purchase a subscription to the Service, we collect billing information such as billing address and payment method details. Payment processing is handled by our third-party payment processor, and we do not store full payment card numbers on our systems.

Communications: When you contact us via email, through the Service, or otherwise, we collect the content of your communications and any information you choose to provide.

Feedback: If you provide us with feedback, suggestions, or other recommendations regarding the Service, we collect that information.

1.2 Information Collected Automatically

When you access the Site or the Service, we may automatically collect certain information, including:

Device and Browser Information: Your device type, operating system, browser type and version, and screen resolution.

Log Data: Your IP address, access times, pages viewed, referring URL, and other standard web log information.

Usage Data: Information about how you interact with the Service, including usage statistics, feature usage, session duration, and other analytics data. Usage Data is aggregated and de-identified such that it does not identify you or any individual user.

Cookie and Tracking Data: Information collected through cookies and similar tracking technologies. For more information, see our Cookie Policy.

1.3 Customer Data

Our customers and their authorized users may upload, submit, or otherwise make available personal information through the Service as part of their use of the platform ("Customer Data"). Customer Data may include personal information about candidates, employees, and other individuals, such as names, resumes, interview transcripts, performance reviews, compensation information, and other professional and employment-related data. Our processing of Customer Data on behalf of our customers is governed by our Terms of Service and any applicable Data Processing Agreement, not this Privacy Policy. See Section 7 below for additional information.

2. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

Providing the Service: To create and manage your account, provide access to the Service, process transactions, and deliver the features and functionality of the Service.

Communications: To send you service-related communications, including account confirmations, technical notices, updates, security alerts, and administrative messages. We may also send you promotional communications about our products, services, and events, from which you may opt out at any time.

Improvement and Development: To analyze usage patterns, monitor and improve the performance of the Service, develop new features and functionality, and conduct research and analytics. For the avoidance of doubt, we do not use Customer Data to train or fine-tune artificial intelligence models.

Security and Fraud Prevention: To detect, prevent, and respond to security incidents, fraud, and other harmful or unauthorized activity.

Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.

Legitimate Business Purposes: To enforce our Terms of Service, protect our rights and property, and for other legitimate business purposes.

3. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your personal information with the following categories of recipients:

Third-Party AI Providers: We share Customer Data with Third-Party AI Providers (such as providers of large language models) solely as necessary to provide the Service. Our contracts with Third-Party AI Providers prohibit them from using Customer Data for model training purposes.

Service Providers: We share personal information with third-party service providers who assist us in operating the Service, including cloud hosting providers (Amazon Web Services), payment processors, analytics providers, and customer support tools. These service providers are contractually obligated to protect your information and may only use it for the purposes for which we have engaged them.

Professional Advisors: We may share personal information with our attorneys, accountants, auditors, and other professional advisors in connection with the provision of their services.

Legal Compliance and Protection: We may disclose personal information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

Business Transfers: In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity, subject to applicable law.

With Your Consent: We may share your personal information with other parties when you have given us your consent to do so.

4. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

Account Information: We retain account information for the duration of your relationship with us and for a reasonable period thereafter for legitimate business purposes, compliance, and legal obligations.

Customer Data: We retain Customer Data for the duration of the applicable Order Term plus the thirty (30) day post-termination retrieval period described in the Terms of Service, after which Customer Data is deleted.

Usage Data: Because Usage Data is aggregated and de-identified, it may be retained indefinitely for analytics and improvement purposes.

Communications: We retain communications for a reasonable period for customer support, compliance, and dispute resolution purposes.

5. YOUR RIGHTS AND CHOICES

5.1 Account Information

You may update your account information at any time by logging into the Service or by contacting us at privacy@teamtheory.ai. You may delete your account by contacting us, subject to our data retention obligations under any applicable Order Form.

5.2 Marketing Communications

You may opt out of receiving promotional communications from us by following the unsubscribe instructions included in each such communication or by contacting us at privacy@teamtheory.ai. Please note that you may continue to receive service-related communications even after opting out of marketing communications.

5.3 Cookies

You can manage your cookie preferences through your browser settings. For more information, see our Cookie Policy.

5.4 European Union Residents (GDPR)

If you are a resident of the European Union, you may have additional rights under the General Data Protection Regulation ("GDPR"), including the right to:

(a) Access your personal data and receive a copy of it;

(b) Rectification of inaccurate or incomplete personal data;

(d) Restrict processing of your personal data;

(e) Data portability - receive your personal data in a structured format;

(f) Object to processing based on legitimate interests;

(g) Withdraw consent where processing is based on consent; and

(h) Lodge a complaint with a supervisory authority.

Legal Basis for Processing: We process personal data based on the following legal bases:

• Contract: To perform our contractual obligations to you

• Legitimate Interests: To operate our business, improve our services, and communicate with you

• Consent: Where you have given specific consent for processing

• Legal Obligation: To comply with applicable laws and regulations

5.5 California Residents (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) ("CCPA"), including the right to:

(a) Know what personal information we collect, use, disclose, and sell about you;

(b) Delete your personal information, subject to certain exceptions;

(d) Opt out of the sale or sharing of your personal information (we do not sell personal information); and

(e) Non-discrimination for exercising your privacy rights.

Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email address, IP address), commercial information (transaction and billing records), internet or other electronic network activity information (usage data, log data), and professional or employment-related information (job title, organization).

We do not sell personal information. We do not use or disclose sensitive personal information for purposes other than those permitted under the CCPA.

5.6 How to Exercise Your Rights

To exercise your privacy rights under GDPR, CCPA, or other applicable laws, please email us at privacy@teamtheory.ai with the following information:

Required Information for Data Subject Requests:

• Your full name and email address
• Type of request (access, deletion, correction, portability, etc.)
• Specific data categories you're inquiring about (if applicable)
• Proof of identity (government-issued ID)
• Any additional information that helps us locate your data

We will verify your identity before responding to your request and will respond within the timeframes required by applicable law (typically 30 days for GDPR requests and 45 days for CCPA requests). You may also designate an authorized agent to make requests on your behalf.

Data Deletion Process: When you request deletion of your personal data, we will:

1. Verify your identity to prevent unauthorized deletion requests

2. Review applicable exceptions (legal obligations, legitimate interests)

3. Delete your data from active systems within 30 days of verification

4. Confirm completion via email once deletion is complete

5. Maintain audit logs of the deletion process for compliance purposes

5.7 Individuals Whose Data Is Processed by Our Customers

If your personal information has been provided to Team Theory by one of our customers (for example, if your resume, interview transcript, or other professional data has been uploaded to the Service by your employer or a prospective employer), you should direct any privacy-related requests (including access, deletion, or correction requests) to the organization that provided your data to us. We process such data on behalf of our customers and in accordance with our Terms of Service. We will cooperate with our customers in responding to such requests in accordance with applicable law.

6. DATA SECURITY

We implement commercially reasonable technical, administrative, and organizational measures to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. For additional information about our security practices, see the Team Theory Security Addendum, which is incorporated into our Terms of Service.

7. CUSTOMER DATA PROCESSING

When we process Customer Data on behalf of our customers, we act as a service provider (as that term is used under the CCPA) or processor (as that term may be used under other applicable data protection laws). Our processing of Customer Data is governed by our Terms of Service and any applicable Data Processing Agreement, and not by this Privacy Policy. Our customers are responsible for: (a) Determining the lawful basis for processing personal information through the Service; (b) Providing any required notices to, and obtaining any required consents from, individuals whose personal information is processed through the Service; (c) Ensuring that they have the legal authority to upload and process such personal information through the Service; and (d) Responding to individuals' requests to exercise their privacy rights with respect to their personal information. If we receive a request directly from an individual whose personal information has been provided to us by a customer, we will refer that individual to the applicable customer, unless we are otherwise required to respond by applicable law.

8. INTERNATIONAL DATA TRANSFERS

The Service is hosted in the United States and personal information is processed in the United States. If you access the Service from outside the United States, please be aware that your personal information may be transferred to, stored in, and processed in the United States, where data protection laws may differ from those of your jurisdiction. By using the Service, you consent to the transfer of your personal information to the United States.

9. CHILDREN'S PRIVACY

The Service is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take reasonable steps to delete such information promptly. If you believe we have collected personal information from a child under 18, please contact us at privacy@teamtheory.ai.

10. THIRD-PARTY LINKS

The Site and Service may contain links to third-party websites, products, or services that are not owned or controlled by Team Theory. We are not responsible for the privacy practices or content of such third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or other factors. If we make material changes, we will provide notice by posting the updated Privacy Policy on the Site and, where appropriate, by sending you an email notification. Your continued use of the Site or Service after the effective date of any updated Privacy Policy constitutes your acceptance of the updated Privacy Policy.

12. CONTACT US

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

ppol, Inc. d/b/a Team Theory

1065 SW 8th St., Suite 5815

Miami, Florida 33130

United States

Email: privacy@teamtheory.ai

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Privacy Policy