Walnut Exchange – Privacy Policy

Last Updated: March 29, 2026

Effective Date: March 29, 2026

This Privacy Policy ("Policy") describes how Walnut Exchange Inc. and its affiliates ("Walnut Exchange," "we," "us," or "our") collect, use, disclose, and protect the personal information of visitors and users ("you" or "your") of the Walnut Exchange website, platform, mobile applications, and related services (collectively, the "Platform").

By accessing or using the Platform, you agree to the terms of this Policy. If you do not agree with this Policy, you should not access or use the Platform.

1. What Information We Collect

We collect Personal Information and Non‑Personal Information in order to provide, maintain, and improve the Platform.

1.1 Personal Information

Personal Information is data that can identify you, such as:

• Contact & profile data: Name, email address, phone number, job title, company.
• Account data: Username, password, profile photo, referral history.
• Professional data: Resume/CV, work history, professional networks.
• Usage data: Jobs posted, referrals made, messages, interactions.
• Communications: Emails or messages you send through the Platform.

You provide much of this information when you:

• Create an account
• Submit referrals
• Apply to join as a Talent Connector
• Post job openings
• Interact with other users
• Communicate with our support team

1.2 Non‑Personal Information

Non‑Personal Information is data that does not directly identify you, such as:

• Browser type, operating system, device information
• IP address (may be pseudonymous)
• Usage and interaction data
• Cookies and tracking data

2. How We Collect Information

We collect information:

• Directly from you when you enter it on the Platform
• Automatically as you navigate the Platform (e.g., cookies, logs)
• From third‑party services (e.g., LinkedIn/other account login data if you choose to connect them)

3. How We Use Your Information

We use your information to:

3.1 Provide & Improve Services

• Operate, maintain, and enhance the Platform
• Match Companies with Talent Connectors and referred talent
• Facilitate referrals, job posts, introductions, and messages

3.2 Communications

• Send account notifications
• Respond to support requests
• Provide updates, marketing communications (if you consent)

3.3 Analytics & Security

• Analyze usage to improve features
• Detect and prevent fraud or abuse
• Protect Platform integrity and user safety

4. Why We Process Your Information

We process your personal information only where we have a valid reason to do so:

• To deliver our services: Processing necessary to operate the Platform and fulfill what you've asked us to do.
• With your consent: For marketing communications and certain optional features. You may withdraw consent at any time.
• For legitimate business purposes: Improving services, preventing fraud, and maintaining Platform security.

5. Cookies & Tracking Technologies

We and our partners use cookies and similar technologies to:

• Remember preferences
• Track site usage
• Deliver personalized content
• Measure performance

You may control cookies via your browser settings or opt‑out controls where available. Disabling some cookies may affect Platform functionality.

6. How We Share Information

We DO NOT share your Personal Information with unaffiliated third parties except as described below:

6.1 With Service Providers

We may share Personal Information with vendors who help us run the Platform (e.g., hosting, analytics, security).

6.2 With Other Users

• Referral data: When you make a referral, the referred candidate's contact info (with consent) may be shared with the hiring company.
• Company data: Companies see candidate details relevant to job evaluation.

6.3 Legal & Safety Requirements

We may share information if required by law, to enforce our Terms, or to protect rights and safety.

6.4 Business Transfers

Information may be shared in connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations.

7. Your Rights & Choices

Depending on your location, you may have rights to:

• Access the Personal Information we hold about you
• Correct or update inaccurate data
• Delete your account or certain information
• Withdraw consent for processing where consent is the basis for it
• Opt‑out of the sale or sharing of your Personal Information (we do not sell personal information)
• Opt‑out of marketing communications at any time

To exercise any of these rights, contact us at privacy@walnutexchange.com.

8. Data Security & Retention

8.1 Security

We implement administrative, technical, and physical measures to protect information from loss, misuse, and unauthorized access.

8.2 Retention

We retain Personal Information as long as necessary for Platform operation, legal compliance, and legitimate business purposes.

9. International Transfers

Your information may be stored or processed in countries different from your residence. We use appropriate safeguards (e.g., contractual protections) where required by law.

10. Children's Privacy

The Platform is not directed at children under 18 (or the applicable age in your location). We do not knowingly collect Personal Information from children without parental consent.

11. Third‑Party Links & Services

The Platform may contain links or integrate with third‑party services. We are not responsible for their privacy practices. Please review their respective policies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated Policy will be posted with a revised effective date. Continued use of the Platform constitutes acceptance of the updated Policy.

13. Contact Us

Questions, concerns, or requests regarding this Privacy Policy can be directed to:

Walnut Exchange Inc.

Email: privacy@walnutexchange.com

Address: [Insert Business Address]

14. State/Regional Notices

14.1 California Residents (CCPA/CPRA)

If you are a California resident, you may have the right to:

• Request access to the personal information we hold about you
• Request deletion of your personal information
• Opt out of the sale or sharing of your personal information

We do not sell your personal information. To exercise any of these rights, please contact us at privacy@walnutexchange.com.

14.2 Canadian Residents (PIPEDA)

If you are a resident of Canada, you have the right to:

• Access the personal information we hold about you
• Request corrections to your data
• Withdraw consent for further processing

To make a request, please email privacy@walnutexchange.com. We will respond within a reasonable timeframe.