PRIVACY POLICY

PAYCOR

Last Updated: January 16, 2026

Paycor, Inc., a Paychex company, values your privacy, and is committed to providing exceptional client service and ease of mind that your business, financial and/or personal information is secure. We have created this privacy statement and notice (“Privacy Policy”) with your privacy and security in mind. This policy will help you understand what information we are collecting and how it is being used, as we seek to deliver you exceptional service.

This Policy applies to all information provided, transmitted, or submitted to Paycor, including in connection with the services provided to or on behalf of you or your employer (“Services”), when you interact with us, and/or on our websites and/or applications, including those hosted on paycor.com, app.ximble.com, app.7geese.com, recruitingbypaycor.com, newtonsoftware.com, gravityapp.com and all mobile applications released by us through the Apple App Store or the Google Play Store (collectively “Website” or “Websites”).

This Policy governs the information gathering, use, and dissemination practices for Paycor, Inc., and entities that are under its control, are controlled by, or under common ownership with, Paycor (“Affiliates”) (collectively referred to as “Paycor,” “we,” “us,” or “our”). Affiliates includes but is not limited to: Nimble Software Systems, Inc. (Paycor Scheduling), Paltech Solutions, Inc. Dba 7Geese (Paycor Performance), Talenya Ltd. Inc. (Paycor Smart Sourcing), Paycor Paths, Paycor Gravity, and Paycor Recruiting. You may also subscribe to services provided by or through Paychex, Inc. and/or its Affiliates and in which case such services may be governed by the Paychex Privacy Policy.

DISCLAIMER

Paycor believes all the statements and information provided in this Privacy Policy to be accurate and reliable, but presents them without guarantee, expressed or implied.

COLLECTION AND USE OF PERSONAL INFORMATION

Paycor collects personal information from you or about you when:

1. you, or a third party acting on your behalf and under your direction, visit our Website(s) or use the Service(s)
2. you are asked to register before entering a limited access site
3. you request information or contact from Paycor
4. you voluntarily provide it via the Website(s)
5. you utilize a third party to access your account
6. you sign up to receive alerts or notifications
7. you make a purchase, and/or
8. your current, prospective, or former employer or a similarly affiliated entity (referred to as “Employer”) provides it to Paycor to facilitate contracted Services which may include benefits management, payroll services, tax compliance, scheduling and timekeeping, onboarding, related human resources-related services, data analytics, and other services contemplated between the parties

Personal information collected may include:

• Contact Information, including name, street address, email address and phone number
• Gender
• Date of birth
• Employer name(s)
• Employment history
• Job title(s)
• Unique personal identification number (for example: Social Security Number)
• Financial and/or bank account information
• Credit, debit, and/or payment card information, if used
• Credit or debt history regarding creditworthiness or credit history, with proper disclosures

• Profile photo and related photos
• Job application information
• Social networking information (if we are provided with access to your account on social network connection services)
• Correspondence or communication sent via the Website
• Preferred language and country information
• Username and password
• IP address, device identification information, browser fingerprint, and geolocation information
• Biometric information, the collection, storage, and use of which  is  set out in, and governed by, our Biometric Information Policy
• Other reasonably relevant information pertaining to your use of the Website, including without limitation, standard web log information and content provided to Paycor or its designated third parties when contacted for assistance
• Any other information you may voluntarily provide

These categories of information may be disclosed to authorized third parties to facilitate the provision of Services.

LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION, ROLE OF EMPLOYERS, AND HOW PERSONAL INFORMATION IS USED

Paycor only processes your personal information where a lawful basis exists and does so under a legal or contractual obligation, your consent, or for legitimate interests pertaining to Paycor’s business and operations.

Paycor may process your personal information to:

1. Facilitate current, prospective, or former Employer requested Services
2. Administer and improve our Websites
3. Develop new services, products, features or technological improvements
4. Conduct research, assessments, and analytics relating to our services
5. Facilitate applicant tracking and recruitment
6. Facilitate billing and collections
7. Contact Employers and consumers with information on Services, new services, products, or upcoming events
8. Market services to current and prospective Employers and consumers
9. Detect fraud or theft or for other security purposes
10. Comply with legal, reporting, and regulatory requirements
11. Provide customer service or support
12. Improve, upgrade, optimize, train, develop or enhance our Services or business operations
13. For other purposes that are compatible with this Privacy Policy or where permitted by applicable law

Paycor may collect, process, and use at its discretion certain personal information that has been de-identified, anonymized, and/or aggregated (so long as no attempt to re-identify the information is made) for lawful purposes (e.g. developing the Services). Paycor may process such de-identified, anonymized, and/or aggregated information without restriction.

In many instances, including for the purposes listed in the preceding paragraphs, your personal information is collected, either directly or indirectly, as a result of your employment with an Employer. In such instances, your Employer is also a Paycor customer and has contracted with us to assist with these Services. In such cases, your Employer may provide us with the personal information necessary to provide the Services to you, and we are merely processing this personal information on behalf of you and/or your Employer. Therefore, in addition to this Policy, you should also familiarize yourself with any policies your Employer may have regarding your personal information.

SHARING OF INFORMATION

We may share personal information with third parties under any of the following circumstances:

• With a potential Employer or as instructed by your Employer
• With our Affiliates, partners, or subsidiary organizations
• In connection with a court order, subpoena, government investigation, or when otherwise required by law, rule or regulation
• In response to lawful requests by public authorities, including to meet national security or law enforcement requirements
• In the event of a corporate sale, merger, acquisition, divestiture, restructuring, reorganization, dissolution, sale or transfer of some or all of our assets, or similar event, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred
• Working with third-party entities to perform certain business-related functions (e.g., mailing campaigns to customers, maintaining databases, providing products or services to you on our behalf, fulfilling or responding to your requests or purchases) to the extent needed for such third parties to perform their specific functions
• In connection with providing aggregated anonymous information concerning member usage of the Services to third parties, such as for advertisers, for purposes that we deem appropriate for service administration
• Our employees, Affiliates, subsidiaries, contractors, agents and third-party partners and vendors to perform Services related to your account, to offer additional services, perform analysis to determine qualification to receive other services, collect amounts due, or for our business operations
• Third-party providers for services that you may sign-up for via our Website or Services or other business partners with whom we work with to develop or market certain products or services
• Cloud providers, customer management platforms, security providers, and similar services in connection with providing products, Services and in the support of daily operation
• Any other entity disclosed by Paycor when you provide the information, or for which you provide authorization.

We will not sell, rent, loan, transfer, or otherwise disclose any personal information to third parties except as set forth in this Privacy Policy, with your consent, or as otherwise disclosed to you at the time of personal information collection.

ARTIFICIAL INTELLIGENCE & AUTOMATED DECISION-MAKING

We may utilize and/or offer access to artificial intelligence tools, products, and/or services (“AI”) for various purposes including to provide our Services, interact with you, improve efficiency and our business operations, and/or for the business purposes detailed in this Policy. Your interactions with us, information provided during the course of Services, and any information you provide to our AI technology may be collected and used as set forth in this Policy. Where permitted by applicable law, we may combine personal information from you with data we obtain from Employers and external sources. When training, testing, validating and/or aligning our own AI models and our third-party AI models, we take appropriate steps to mitigate potential privacy impacts in compliance with applicable law. We will not use your personal information to train models (via generative artificial intelligence) without consent, if applicable. To the extent that we use such information to fine-tune or train AI, we will do so just to provide services to you. We do not use your personal information for automated decision-making or profiling.

Your use of AI tools is dependent upon the information that you or your Employer submits for the Services. You are responsible for ensuring the accuracy of all data input into such tools and for confirming the accuracy and validity of any output. You acknowledge that our tools are not intended or designed to replace or override human decision-making and you may not use our tools to make or substantially assist with any legal, financial, or employment decisions. Once authorized, such tools may capture, record and transcribe our information, comments, and/or voice. We will treat all voice interactions and transactions as though you authorized them, and as though they are authorized interactions and transactions, even if another voice or person initiated or completed them. Paycor does not guarantee the accuracy of content produced via AI.

TEXT MESSAGING

You have an option to choose to receive text messages (SMS) from us to keep you informed of updates. This service is optional and does not require you to purchase goods or services from Paycor or its Affiliates. If you give us your mobile device number and opt into such text messaging as provided below, you hereby consent to Paycor’s use of your mobile device number in accordance with this Privacy Policy and any applicable terms of use until you withdraw such consent. You further consent to receive phone calls or pre-recorded messages, including those from automated dialing systems. Message and data rates may apply.

• To join Paycor’s text messaging program, you can opt-in and configure your text-based notifications and security settings through the Website directly.
• To discontinue receiving SMS messages from Paycor, you can opt-out of your text-based notifications and security settings through the Website.

This Text Messaging section is not applicable to the Recruiting application.

COOKIES AND OTHER AUTOMATED INFORMATION COLLECTION

Cookies.
Please visit the Cookie Policy for information on Paycor’s cookie and automated information collection practices.

Live Chat. 
We and/or a trusted third-party vendor provide you with live chat features to better assist you. When using the live chat features, please only provide necessary information and do not provide sensitive information. For recordkeeping, training, and quality assurance purposes, we or our third-party vendor may record and maintain a transcript of any communications in the live chat.

Recording Use of the Website.
We and/or trusted third-party vendors analyze the performance and traffic of our Website. This may include things like buttons you click, mouse movements, other behavior on the Website, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Please review the entirety of our Cookies and Other Automatic Information Collection section to learn more about cookies, pixels tags, and analytic technologies.

CHOICE AND PREFERENCES

Where Paycor or its Affiliates may provide subscription-based services, such as email newsletters, you can make choices about what information you provide at the point of collection or later at any time after you have received a communication from us while you are subscribed. If you receive email newsletters or marketing emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Any transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services and are not intended for the purposes of marketing. Any such communications you receive from us will be administered in accordance with your preferences and this Privacy Policy.

DATA PRIVACY FRAMEWORK

Paycor, Inc. and Nimble Software Systems, Inc. (collectively “Registrant”) complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland transferred to the United States pursuant to the Data Privacy Framework. Registrant has certified that it adheres to the Data Privacy Framework Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov/s/ .

Registrant retains the personal information of European Union, Swiss, and United Kingdom residents only for as long as it is necessary to fulfill the stated purposes, or as legally required, and thereafter appropriately disposes of such information. Paycor has retention periods for the various records containing personal information. When personal information is no longer necessary or relevant for the identified purpose or to fulfill a legal or business requirement, it is securely destroyed. Paycor will either physically or electronically erase the personal information or otherwise render it incapable of individually identifying you. 

TRANSFERS OF DATA TO THE U.S.

Registrant is EU-U.S. and Swiss-U.S. Data Privacy Framework certified. Nonetheless, Registrant does not rely on such certifications in the absence of the authority to do so.

DATA PRIVACY FRAMEWORK PRINCIPLES

Registrant is committed to ensuring that your personal information is correct, up-to-date, and as publicly available as you wish it to be when displayed on the Website.

Registrant affirms the following in compliance with the Data Privacy Framework Principles:

• Registrant is subject to the jurisdiction and enforcement authority of the US Federal Trade Commission.
• EU, Swiss, and UK individuals whose personal data has been transferred into the United States pursuant to the Data Privacy Framework have the right to access their data and to correct, amend or erase data that is incorrect or has not been processed in accordance with the Data Privacy Framework principles.
• For personal information that Registrant processes as a controller, individuals wishing to exercise this right may do so by utilizing Registrant’s Access Request Portal or as otherwise disclosed in this Policy.
• If your personal information has been provided to the Registrant by your Employer, we may not have the authority to grant you access to that data. In that case we will either refer you back to your Employer or pass your request on to the appropriate party.
• Registrant may be required to release personal data in response to lawful requests by public authorities, including to meet national security and law enforcement requirements.
• Registrant’s accountability for personal data that it receives in the United States under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Registrant remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Registrant proves that it is not responsible for the event giving rise to the damage.
• Registrant does not transfer data to non-agent third parties, nor do we permit the use of such information for reasons other than those for which the data was originally provided. If this practice should change in the future, Registrant will update this policy accordingly and provide individuals with appropriate opt-in or opt-out choice prior to releasing that information.
• Registrant will provide an individual opt-out choice, or opt-in for sensitive data, before we use your data for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please do so by utilizing Registrant’s Access Request Portal or emailing the Privacy Team at the email address linked below.

INQUIRIES

In compliance with the Data Privacy Framework Principles, Registrant commits to resolve complaints about your privacy and our collection or use of your personal information. If you have inquiries or complaints regarding this Policy or would like to access your personal information, you should first contact Registrant via: (1) utilize Paycor’s Access Request Portal or email the Privacy Team; or (2) mail to Attn: Privacy Request, Paycor Inc., 4811 Montgomery Rd., Cincinnati, Ohio 45212.

Registrant has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to an independent dispute resolution mechanism, the BBB EU DATA PRIVACY FRAMEWORK. If you are an individual in the European Union, Switzerland or United Kingdom and do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your Data Privacy Framework complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Data Privacy Framework Annex 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2

NOTICE FOR RESIDENTS OF CALIFORNIA

If you are a Paycor Applicant, Employee, Independent Contractor, or Paycor Business Contact who resides in California, click here for more information.

If you are a California resident who is not a Paycor Applicant, Employee, Independent Contractor, or Business Contact you may exercise any rights afforded to you under applicable privacy laws by contacting your Employer directly. Please note that any data Paycor may hold about you is subject to its obligations as a Service Provider. The CCPA treats service providers differently than the businesses they serve, and ultimately, the business is responsible for responding to consumer requests.

EXTERNAL LINKS

This Website contains links to other websites. Paycor is not responsible for the privacy practices or the content of such websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

SECURITY

Paycor endeavors to maintain security measures to protect the loss, misuse, and alteration of the information under our control. We take a number of security precautions to assist with maintaining the integrity and confidentiality of our data. These precautions can be categorized as internal security and external security. At Paycor, we use these security categories to limit the individuals or groups authorized to access and/or change data in such categories. This helps us try to prevent unauthorized individuals from accessing, copying, editing, or deleting data. We also implement an audit system that tracks access, both successful and unsuccessful, to confidential data. This audit information is used to constantly evaluate and refine our security measures and to identify individuals who might attempt to inappropriately access data and to take remedial action. Paycor uses industry-standard technology to encrypt and authenticate transactions. Learn more about Paycor’s Security practices at https://www.paycor.com/security.

The Internet is not a 100% secure environment, and as a result, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, or physical safeguards. It is your responsibility to protect the security of your login information and computing device. Please help keep your account safe by using strong, confidential passwords and multi-factor authentication. Depending on the situation, you may want to implement security measures in addition to those provided by Paycor.

INFORMATION OF MINORS

The Website is not directed to, or intended for use by, children under 13 years of age. In some jurisdictions, different age restrictions apply as outlined below.

• Member States of the European Union (EU), European Economic Area (EEA), and Switzerland: The Website is not directed to, or intended for use by, children under 16 years of age.

Paycor does not knowingly collect or transmit any information from children under 13 years of age (or 16 years of age as may be applicable). If you are under 13 years of age (or 16 years of age as may be applicable), you may not use our Website.

UPDATING PERSONAL INFORMATION

Keeping Your information accurate and up-to-date is very important. You control the accuracy of your personal information. If your personal information changes, please have your Employer correct, update, or delete it from our Website.

Outside of its legal obligations to your Employer, Paycor has no obligation to maintain or provide any of your personal information and may, unless legally prohibited, delete all your personal information in our systems or otherwise in our possession or under our control. We may also retain all or a subset of your personal information for business or legal purposes.

Paycor responds to requests within the time limit set out by the applicable privacy legislation and, if applicable, provides the individual with an estimate of any cost associated with administering and responding to the request. Paycor requires sufficient information to authenticate requests for access.

UPDATES TO THIS PRIVACY POLICY

It may be appropriate to update our Privacy Policy and other terms and conditions from time to time. We reserve the right to update this Privacy Policy in our sole discretion at any time, with or without advance notice, unless otherwise required by law or the Data Privacy Framework Principles. We will post any changes on the Privacy Policy page of the Website. We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the personal information we receive from you.

If you have any questions about this privacy statement, the practices of this Website, or your dealings with this Website, you can contact our Data Protection Officer and privacy team through the following methods:

Email

Call: Call 800.381.0053

Send mail to:
Attn: Privacy Request
Paycor
4811 Montgomery Road
Cincinnati, OH 45212

If you are a Paycor client, contact your Paycor Specialist

Paycor, Inc.

4811 Montgomery Road
Cincinnati, OH 45212

Paycor Gravity

Last Updated: January 16, 2026

The Gravity application is used by individuals and Employers (as applicable, “you”) to share jobs on social networks, manage employee referral programs, and incentivizes people to share jobs and generate applicants.

In addition to the provisions outlined in the Paycor Privacy Policy, the following information below applies to the use of Paycor Gravity.

Collection of Personal Information

Personal information collected may include:

• Job openings that you share via the Gravity application
• Any further personal data contained in any files that you share via the Gravity application

Cookies

When you sign in through the Gravity application, Paycor will assign you a unique identifier and send such information to your computer or device hard drive in the form of a cookie, which is a very small bit of code. This code is uniquely yours and allows you to use the Gravity application’s functionality with minimal subsequent registration procedures. Cookies are also used to record you as the source of any candidate or job referrals on the Gravity application. If you apply for a job opening that has been shared through the Gravity application, Paycor will assign you a unique identifier and send such information to your computer or device hard drive in the form of a cookie. This code is unique to you and will correlate your job application to the person that posted such job opening on the Gravity application. It does not contain any of your personal information.

Personal Profile Information

When you register on the Gravity application, Paycor uses a third-party provider, Akamai, to manage the Gravity application login registration process and create a personal profile for you on the Gravity application (“Personal Profile”). Each Personal Profile is assigned a unique personal identification number and requires that you choose a username and password to access your Personal Profile on the Gravity application, which helps Paycor to ensure that only you can access your Personal Profile and personal information on the Gravity application. Because you assist Paycor in developing your Personal Profile username and password, you have a significant role in protecting your Personal Profile and personal information. No one can access or edit your Personal Profile without knowing your Personal Profile username and password, so do not share these with others.

Personal Choices

Paycor acknowledges an individual’s right to access their personal information. If you want to review or update your personal information, you may do so on the Gravity application by visiting your Personal Profile. Note that if you are a candidate (and not a user of the Gravity application) who would like to access your personal information, you will need to request this information from your Employer.

Social Network Profiles

When you post a job opening on the Gravity application, Paycor will request your permission to access your social networks including, without limitation, Facebook, Twitter, and LinkedIn so that you can share such job openings with your social network connections. Paycor will not post any job openings or other content on your social networks or amend any of your posted job openings or content without your authorization. The Gravity application will also not track any of your social network activity, other than when you specifically use the Gravity application to share job openings on your social networks. All use of your personal information by any social network service provider is subject to each network’s posted terms of service and privacy policy.

Vouching Content

Paycor may ask you to vouch for people that have applied to job openings you have shared on the Gravity application. Your Employer will be responsible for determining who is allowed to view your responses to such vouching requests.

Sharing Of Information – Gravity

In addition to the circumstances articulated previously in this Privacy Policy above, with regard to the Gravity application, Paycor may also disclose your personal information with:

• Your Employer, solely in regards to the existence of your Gravity application account, information on job openings you share using the Gravity application, your Gravity application account point totals, and vouching recommendations (pursuant to the Vouching Content section); and
• Any other parties to whom you permit disclosure, including, without limitation, social network websites.

Security

The security of your personal information is important to Paycor. With the exception of Personal Profile login information stored by Akamai, as detailed under the Cookies section above, your personal information may be stored locally on your device and may be transmitted to servers owned, leased or utilized by Paycor in the United States.

Paycor Recruiting

Last Updated: January 16, 2026

The Recruiting application is used by companies to post job openings, collect potential job applicant information and track applicants through the hiring process.

In addition to the provisions outlined in the Paycor Privacy Policy, the following information below applies to the use of Paycor Recruiting.

Users

The Recruiting application is accessed and used by two distinctly different types of users:

(1) companies that post job openings and review candidates who apply for those job openings

(2) candidates for those job openings who use the Recruiting application to apply for them (“Applicants”)

Applicants that do not consent to the terms and conditions of this Privacy Policy should not use the Recruiting application.

Text Messaging

Users have an option to choose to receive text messages (SMS) from us to keep you informed of updates. This service is optional and does not require the purchase of goods or services from Paycor or its Affiliates. If users provide a mobile device number and opt into such text messaging as provided below, they hereby consent to the Paycor’s use of the mobile device number in accordance with this Privacy Policy and any applicable terms of use until such consent is withdrawn. Users further consent to receive phone calls or pre-recorded messages, including those from automated dialing systems. Message and data rates may apply.

• Applicants can opt-in through the Recruiting application directly or by requesting that the Employer enable this service.
• To discontinue receiving SMS messages from Paycor, reply STOP to any message you have received from Paycor.

Paycor Scheduling

Last Updated: January 16, 2026

Paycor Scheduling brings together all of Ximble’s most powerful features along with Paycor’s familiar design and usability to bring flexibility to the staff scheduling process.

In addition to the provisions outlined in the Paycor Privacy Policy, the following information below applies to the use of Paycor Scheduling.

Sharing of Information

We may share personal information with third parties pursuant to the use of Paycor Scheduling under any of the following:

• With other users of Paycor Scheduling’s Website, Mobile App, or other products and services under the same underlying subscription or free trial as you (“Other Users”). As a result of your use of the Website or other products or services of Paycor Scheduling, Other Users will have access to information you provide to Paycor Scheduling (including, without limitation, matters regarding your work schedule) and may send you messages via email or through the Mobile App. You hereby consent to such disclosure of information to Other Users, and Paycor Scheduling shall have no responsibility for any communications from Other Users.

Profile Information

We store information that we collect through cookies, log files and clear gifs to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the user’s personally identifiable information to provide offers and improve the content of the Website for the user. This profile is used to tailor a user’s visit to our Website, and to direct pertinent marketing promotions to them. We do not share your profile with other third parties, subject to the exceptions set forth in Paycor’s Privacy Policy regarding sharing of your personal information in certain circumstances.

Paycor Performance

Last Updated: January 16, 2026

Paycor Performance modernizes the entire performance review process. With automated workflows, prompts, tasks, and notifications, remove the manual burden on HR leaders, managers and employees by allowing teams to easily see upcoming activities and ensure all priorities are being met. 

In addition to the provisions outlined in the Paycor Privacy Policy, the following information below applies to the use of Paycor Performance.

International Transfer of Information Collected

7Geese operates out of Canada and stores information with service providers located in the United States. Your personal information may be maintained and processed by us, our Affiliates and other third-party service providers in Canada, the United States or other jurisdictions where our service providers are located.

We take measures to ensure that any personal information transfers comply with all applicable data protection laws and that your personal information remains protected to the standards described in this Privacy Policy. In the event that personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

Paycor Smart Sourcing

Last Updated: January 16, 2026

Paycor Smart Sourcing’s AI-powered, talent-sourcing bots (“Bots”) collect and use data from various online sources to rapidly identify the right talent for each job and to reach out to that talent – sometimes before they may even start searching for their next job.

In addition to the provisions outlined in the Paycor Privacy Policy, the following information below applies to the use of Paycor Smart Sourcing.

Collection and Use of Personal Information

Paycor Smart Sourcing may collect personal information from you or about you:

• When you uploaded personal information to publicly available websites and social media platforms
• From third parties in order to obtain contact information for candidate leads

Personal information collected may include:

• Race, ethnicity, religion, health, and sexual orientation (anonymized) if provided through the use of services

How we process an individual’s personal data

Following collection of personal data, our system creates a candidate profile for each individual whose personal data has been collected. The process involves merging the personal data collected from various different sources and, where there are any discrepancies, uploading the most recent available.

Our system also uses certain predictive algorithms to fill in blanks in individual profiles, such as where the personal data collected does not include a particular skill or experience which might normally be included. In situations such as these, our system in conjunction with information collected by our Bots, predicts whether a person is likely to have a certain skill and adds it to their profile. Before providing the profiles to the customer, the Bots search through the original sources of the personal data collected to determine if any information needs to be updated. Once all relevant data has been updated, the profiles are pseudonymized and provided to the customer. This process may be repeated until the customer selects the individuals they wish to engage or interview; all throughout the customer’s search the profiles remain pseudonymized.

For individuals located within the US, we will provide contact information if we are able to obtain it pursuant to US-based privacy laws. For individuals based in the EU, Israel, and California, we will contact them to notify: that we hold their personal data, how and why we hold and process that personal data, and that they have been selected by a customer for direct contact in connection with a potential job opportunity. For such individuals, we will not provide the customer with the contact and other identifying details until we have obtained their consent.

Paycor Paths

Last Updated: January 16, 2026

Paycor Paths is used by individuals and Employers to deliver personalized and effective employee learning experiences. Through Paycor Paths, companies can offer a safe place to explore authentic and honest thoughts, emotions, and ideas.

In addition to the provisions outlined in the Paycor Privacy Policy, the following information below applies to the use of Paycor Paths.

Sharing of Information

We may share personal information with third parties pursuant to the use of Paycor Paths under any of the following:

• With your colleagues or group members if you are participating in activities hosted by Paycor Paths

• With competition sponsors, pursuant to a contest, who may use your information in accordance with the competition rules and its own privacy policy, which might differ from this Policy.
• Upon Your direction via applications which allow you to share your content and work product with designees.

Use of Information

In addition to the circumstances listed in the Paycor Privacy Policy, Paycor Paths may use your information for the following purposes:

Social Network Profiles

• If you choose to log into our site or Services via social networks, Paycor Paths will request your permission to access your networks, without limitation, Facebook, Twitter, and LinkedIn.

Website Improvement and Personalization

• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Websites or our services.
• For other research and analytical purposes, such as to examine trends in participation, success in campaigns and/or competition, as well as overall web usage.
• If you are an authorized user under an enterprise license, to track your progress through professional development, mentoring, and engagement activities and share such information with your employer and/or enterprise sponsor.

User Generated Content

• You may post content on certain of our Websites to our forums and blogs, including your comments, pictures, and any other information that you would like to be available on our Websites. If you post content to our Websites, all the information that you post will be available to all visitors to our Websites. If you post your own content on our Website or Services, your posting may become public.