1. Introduction

Staff Rodeo Inc. (“Staff Rodeo,” “Company,” “we,” “us,” or “our”) is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information from users (“User,” “you,” or “your”) of our staffing technology platform and related services (collectively, the “Services”).

This Privacy Policy applies to all information collected through our Services, as well as any related services, sales, marketing, or events. By using our Services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy and in accordance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Ontario’s privacy legislation, and, where applicable, the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA).

Our Services are not directed at children under the age of 16, and we do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a child, we will delete it promptly.

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide when:

• Creating and managing user accounts
• Using our staffing platform and services
• Communicating with our support team
• Participating in surveys, promotions, or feedback requests
• Subscribing to newsletters or marketing communications

This information may include:

• Contact information (name, email address, phone number, mailing address)
• Account credentials and security information
• Professional information (job title, company details, industry)
• Payment and billing information
• Communication preferences and settings
• Candidate and client data entered through our platform

2.2 Automatically Collected Information

We automatically collect certain information when you access our Services:

• Device information (IP address, browser type, operating system)
• Usage analytics (pages visited, time spent, click patterns)
• Location data (general geographic location based on IP address)
• Cookies and similar tracking technologies
• Log files and server data

Sensitive information: Candidate resumes, employment histories, or other HR-related data may be processed only as necessary for providing the Services and in accordance with applicable employment and privacy laws.

3. How We Use Your Information

We process personal information for legitimate business purposes and in accordance with applicable law. Specifically, we use your information to:

3.1 Service Provision and Operations

• Provide, operate, and maintain our staffing platform
• Process transactions and manage billing
• Authenticate users and manage accounts
• Deliver customer support and technical assistance
• Fulfill contractual obligations and service agreements

3.2 Communication and Marketing

• Send transactional communications and service updates
• Respond to inquiries and provide customer support
• Deliver marketing communications (with consent)
• Send newsletters and industry insights

3.3 Service Improvement and Analytics

• Analyze usage patterns and service performance
• Develop new features and improve existing services
• Conduct market research and gather feedback
• Ensure platform security and prevent fraud

Where required by law, we will obtain your explicit consent before processing sensitive personal information or using your information for marketing purposes.

4. Information Sharing and Disclosure

We do not sell, rent, or trade personal information. We may share your information only in the following circumstances:

4.1 Service Providers

We may share information with trusted third-party service providers who assist us in operating our business, including:

• Cloud hosting and data storage providers
• Payment processing and billing services
• Customer support and communication platforms
• Analytics and marketing tools
• Security and fraud prevention services

4.2 Legal Requirements

We may disclose personal information when:

• Required by law or legal process
• Necessary to protect our legal rights or property
• Required to investigate potential violations of our Terms of Service
• Necessary to protect the safety of users or the public

4.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, personal information may be transferred as part of the transaction, subject to appropriate confidentiality and privacy protections.

All third-party service providers are bound by contractual obligations (including Data Processing Agreements where legally required) to protect your information and use it only for the purposes specified by us.

5. Data Security and Protection

We implement comprehensive security measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• Industry-standard encryption for data transmission and storage
• Regular security assessments and vulnerability testing
• Access controls and authentication mechanisms
• Employee training on privacy and security best practices
• Incident response procedures for potential data breaches

While we strive to protect personal information, no method of transmission or storage is completely secure. We cannot guarantee absolute security but are committed to maintaining reasonable safeguards appropriate to the sensitivity of the information.

If we detect a data breach that creates a risk of harm, we will notify you and the appropriate regulators without undue delay, as required by law.

6. Your Privacy Rights

Under applicable Canadian privacy laws, you have certain rights regarding your personal information:

6.1 Access and Correction

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Update your account information and communication preferences

6.2 Data Portability and Deletion

• Request a copy of your personal information in a portable format
• Request deletion of personal information (subject to legal requirements)
• Withdraw consent for processing where consent is the legal basis

6.3 Marketing Communications

You may opt out of marketing communications at any time by:

• Using unsubscribe links in email communications
• Updating preferences in your account settings
• Contacting our support team directly

To exercise these rights, please contact us using the information provided in Section 11. We will respond to your request within a reasonable timeframe as required by applicable law.

In jurisdictions such as the EU and California, you may also have the right to object to certain processing activities, restrict processing, or opt out of the sale or sharing of personal information. We do not sell personal information, but if this changes, you will be notified and given the right to opt out.

We will respond to all valid requests within 30 days, or within the timeframe required by applicable law.

7. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance your experience and collect usage information. These technologies help us:

• Remember your preferences and settings
• Analyze website traffic and user behavior
• Improve our Services and user experience
• Deliver targeted content and advertisements

You can control cookie preferences through your browser settings. However, disabling certain cookies may limit the functionality of our Services.

Where required (e.g., in the EU), we will present a cookie consent banner giving you the option to accept or reject non-essential cookies before they are set.

8. International Data Transfers

While Staff Rodeo primarily operates in Canada, some of our service providers may be located outside of Canada. When personal information is transferred internationally, we ensure appropriate safeguards are in place to protect your information in accordance with Canadian privacy laws and, where applicable, GDPR-approved mechanisms such as Standard Contractual Clauses.

9. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of information and its intended use.

When personal information is no longer required, we securely delete or anonymize it in accordance with our data retention and destruction policies.

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated through:

• Email notification to registered users
• Prominent notices on our website and platform
• Updates to the “Last Updated” date at the top of this policy

Your continued use of our Services after any modifications indicates your acceptance of the updated Privacy Policy.

Last Updated: September 13, 2025

11. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or want to file a complaint, please contact us:

If you are not satisfied with our response to your privacy concern, you may also contact the Office of the Privacy Commissioner of Canada at:

12. Definitions

For the purposes of this Privacy Policy:

• Personal Information: Information about an identifiable individual, as defined under applicable Canadian privacy legislation
• Processing: Any operation performed on personal information, including collection, use, disclosure, storage, and destruction
• Services: Staff Rodeo’s staffing technology platform and all related services, software, and features
• Third Party: Any individual or entity other than you or Staff Rodeo