Our Privacy Commitments

This Privacy Policy is issued by RINGO (trading name "MODJO"), a société par actions simplifiée (simplified joint stock company) with a share capital of 38,666.31 euros, registered in the Nanterre Trade and Companies Register under number 879 606 283, with its registered office at 59, avenue Sainte Foy - 92200 Neuilly-sur-Seine.

We have placed at the center of our commitments, that of respecting and protecting the privacy and personal data of our customers and users, and therefore to comply with the regulations in force, and in particular the Law No. 78-17 of January 6, 1978 "data processing and freedom" in its amended version and the European Data Protection Regulation No. 2016/679 (known as "RGPD") which came into force on May 25, 2018, but also to ensure better protection of the data that we use with the objective of improving our goods and services.

This Policy applies to the processing of personal data carried out by RINGO in its capacity as data controller via its website www.modjo.ai and the app.modjo.ai application.

This Policy does not apply to the processing of personal data for which RINGO acts as a processor. For the processing of personal data relating to your customers or prospects, which you may entrust to us in the context of the use of our services, you act as the controller and we act as the processor within the meaning of the RGPD. It is therefore your responsibility to ensure that the information and rights of the persons concerned are respected and, more generally, the applicable regulations.

In order to reflect our desire to inform you, this Privacy and Data Protection Policy will enable you to understand how and why your personal data is collected and processed by RINGO and how to exercise your rights.

If your personal data is processed by a RINGO Client, please refer to their privacy policy or the information they have provided to you regarding the processing they perform.

This Privacy Policy may be updated from time to time, particularly to reflect changes in our services, technologies or applicable regulations. These updates will be effective immediately upon being made available and viewable on our website or via the Modjo application.

If you have any questions about this document and, in general, about the collection and processing of your personal information by RINGO, please do not hesitate to contact us via the following e-mail address: dpo@modjo.ai

Who is this Policy for?

This Privacy Policy is intended for anyone who may provide or entrust us with personal information through our products and services. This includes users of the modjo.ai website, RINGO's customers and prospects, and applicants for employment with RINGO. This Privacy Policy applies only to the processing carried out by RINGO as data controller.

When another company uses Modjo, RINGO acts as a processor. The information about the processing of personal data that this other company performs through Modjo is provided directly by that company and may be different from that provided in this Policy.

What is "personal data"?

Within the meaning of the RGPD and the "Informatique et Libertés" law, "personal data" consists of any information relating to a natural person who can be identified directly or who is indirectly identifiable, such as surnames, first names, email and postal addresses , his image, an IP address, location data, a license plate

What personal data do we collect?

The personal data we collect when you contact us, we contact you or you use our services may include, but is not limited to, data relating to:

• your identification (e.g. name, first name, e-mail address, login, phone number);
• your professional life (e.g. position, company, contact information);
• information sent via the "Contact Us" feature or the support and complaint services;
• Information about the recruitment and professional life of job applicants, collected during your application via Welcome to the Jungle or via the profile search tools available on Linkedin;
• telephone and video conference interactions between our employees and our customers, prospects and candidates (e.g. telephone number, audio and video recording, date and time)

We record telephone calls and video conferences between our employees and our prospects and clients, as well as between members of our recruitment team and job candidates.

When you browse our websites and services, we may also collect:

• information about your use of our sites and services, including data traffic and records of the choices you make online;
• log files and statistics relating to actions taken on our sites and services;
• technical information about any device and operating system you use when you visit our sites, including your device ID, Internet Protocol (IP) address, your device's browser version, the pages of our service you visit, the time and date of your visit, the time spent on those pages, and other statistics. To collect and process tracking data on our sites, we use cookies; to better understand how they work and what they are used for, you can review our Cookie Policy available at: https: //www.modjo.ai/legals/cookie-policy

Why do we need to collect personal data?

RINGO collects personal data for the following purposes:

• Provide and manage our websites and services
• To understand your uses and adapt our products and services accordingly
• To communicate with our customers and prospects and to improve the quality of our services, i.e. to answer your questions and inform you of our news, as well as to carry out commercial and marketing prospecting operations
• Resolve any disputes or resolve any bugs or problems with the use of our services
• Identify and recruit new employees

We record telephone calls and video conferences between our employees and our customers and prospects for the following purposes:

• Promote the training of our employees
• To improve the follow-up of the exchanges and commercial relations that we maintain with our customers and prospects
• Promote collaboration between teams

To achieve these goals, we use features such as note-taking, translation of recordings and intelligent summaries of exchanges.

We record phone calls and video conferences between members of our recruiting team and job candidates for the following purposes:

• Promote the training of our recruitment team members
• Facilitate and improve the recruitment process

In order to carry out the processing of personal data for these purposes, RINGO relies on the pursuit of the following legitimate interests: to establish and maintain a commercial relationship with its customers and prospects, to promote the collaboration and training of its teams and to provide useful and attractive user interfaces.

With respect to recordings made between members of our recruitment team and job applicants, RINGO relies on the pursuit of the following legitimate interests: team building and recruitment of new employees.

The personal data collected are necessary for the proper achievement of the purposes of the processing. Failure to provide this data would result in these purposes not being properly achieved. However, at any time, you may object to the recording and processing of your telephone and video conference interactions with Modjo.

RINGO relies on the consent of the user to place and read cookies for the purposes of measuring ads and content, customizing ads and content, audience tracking and product improvement and development**.** You can withdraw your consent as easily as you have given it within our Cookie Policy. All information about cookies can be found in this Cookie Policy.

What are your rights?

The information that you agree to give us, through the use of our sites and services, remains your personal data.

You have the following rights with respect to your personal data:

• the right of access allowing you to access all the information concerning you and to obtain a copy, a fee not exceeding the cost of reproduction may be requested
• the right of rectification allowing you to ask for your data to be rectified, completed or updated, depending on the case
• the right to object to the processing of commercial prospecting and, under certain conditions, to the processing of your personal data for purposes other than commercial prospecting. At any time you can oppose the recording of your call with an employee of Modjo
• the right to restrict the processing of your data, allowing you to restrict the processing of your personal data
• the right to erasure allowing you to request that your personal data be deleted

You may exercise your rights in writing by sending us an e-mail to the following address: dpo@modjo.ai.

Your requests will be processed within one month of receipt. This period may be extended by two months if necessary due to the complexity or number of requests. We reserve the right to ask you for a copy of an identity document in order to verify your identity if we have reasonable doubts about your identity.

You can also object verbally, during a telephone conversation or video conference with an employee or a staff member of RINGO, to the processing of your personal data recorded during this exchange. In this case, your request will be met immediately and the processing will not take place.

To learn more about your rights, you can visit the CNIL website: www.cnil.fr

You also have the right to file a complaint with the CNIL.

How does RINGO protect your personal data?

RINGO has implemented a number of technical and organizational actions and measures to meet the requirements of the RGPD regarding the protection and security of personal data.

Although RINGO is not legally required to do so, RINGO has a Data Protection Officer (DPO) who can be contacted at the following e-mail address: dpo@modjo.ai

For each new processing operation implemented by RINGO, our DPO, as part of an internal prior approval procedure, checks its purpose and legitimacy with regard to the company's needs, but also and above all with regard to the risk of infringement of the data protection and privacy of the persons concerned.

With regard to the security measures implemented to protect personal data from any risk of violation, unauthorized disclosure or damage to their integrity, RINGO has deployed all the necessary means with its teams and service providers. For example, the data processed on Modjo is encrypted.

RINGO agrees not to use user data obtained via Workspace APIs to develop, improve or train a generalized AI or Machine Learning model.

In particular, we strive to maintain 24-hour system monitoring to ensure the security of the personal data entrusted to us.

Our sites are regularly scanned for security holes and vulnerabilities and we take precautions to prevent the loss, misuse or alteration of personal data.

When certain services require the use of a third party (subcontractor), RINGO selects its service providers on the basis of strict security and confidentiality criteria defined in advance with regard to the issues at stake, and systematically requires its subcontractors to have a level of security that guarantees an adequate level of protection of the personal data they process on our behalf.

Who are the recipients of the data we process?

Only persons authorized by RINGO may access data, and then only in the context of the tasks entrusted to them. Thus, the only potential recipients of personal data are authorized RINGO employees and subcontractors offering a sufficient level of security. These include the Recall subcontractor, which enables RINGO to record calls, the OpenAI subcontractor, which enables RINGO to generate intelligent summaries of recordings, to automatically segment recordings into chapters, intelligent scoring, and the Deepl subcontractor, which provides translations of recordings.

In the context of its commercial prospecting operations, RINGO may share with a partner the names of client companies or prospects (legal entities) that they have in common. This does not include the identity and contact data of the contacts.

In the course of recruiting, RINGO may share candidate information with outside organizations involved in recruiting candidates (subcontractors) such as recruiting firms or SaaS-based recruitment software.

What are the retention periods for the personal data collected?

RINGO undertakes to keep the personal data entrusted to it for periods limited to the provision of the services or necessary to meet its contractual or legal obligations.

In particular:

• Data related to interactions (phone calls and videoconferencing): Duration of the contractual relationship when it concerns a RINGO client, or 3 years from the last interaction when it concerns a prospect. Intermediate archiving for 5 years from the end of the contractual relationship, then destruction.
• Data related to clients: Duration of the contractual relationship. Intermediate archiving for 5 years from the end of the contractual relationship, then destruction. 13 years from the last interaction. Intermediate archiving for 5 years, then destruction.
• Data related to prospects: 3 years from the last interaction. Intermediate archiving for 5 years, then destruction.
• Recruitment data: For selected candidates, data is kept for the duration of the employment relationship and for 5 years after its termination.For non-selected candidates, data is kept for 2 years from the last contact.Interview recordings of candidates are kept for the time necessary for the recruitment process.
• Browsing data: A maximum of 25 months from the date of collection, then destruction.
• Identity document/information: The time strictly necessary to establish the identity of the person wishing to exercise their rights (only when necessary). Immediate destruction after responding to the request.

Is your personal data transferred to countries outside the European Union?

With regard to hosting and data storage, RINGO requires its hosting service providers to host the data entrusted to it in France. Thus, RINGO's sites and databases are hosted by AWS on servers located in France and in the European Union.

If, for technical reasons or for specific needs related to the maintenance of certain applications, personal data are transmitted or made accessible to RINGO's service providers located outside the European Union, RINGO will first ensure that these service providers guarantee an adequate level of protection of such data and comply with the GDPR.

Thus, RINGO only uses subcontractors with an adequate level of security and data protection, for example through the supervision of data transfers outside the EU by binding corporate rules or through the adoption of the European Commission's standard contractual clauses. Copies of these documents are available upon request by writing to dpo@modjo.ai.