Panjaya Privacy Policy

Last Updated: October 28^th, 2025

This privacy policy (“Privacy Policy”) governs how we, Panjaya Inc. (“Panjaya”, “Company”, “we”, “our” or “us”) use, collect, disclose, and store Personal Data we collect or receive from individuals who are using or accessing our website,  https://www.panjaya.ai, including any of its sub domains, and the services, features or functionalities offered by us (collectively, the “Services”), or from individuals who submit their candidacy to a position with us.

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to Personal Data.

“Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as personally identifiable information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our website or by other means.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. Customer Information
3. Legal bases
4. How we protect and retain your information
5. To whom we disclose your personal data and for what purpose
6. Additional information regarding transfers of Personal Data
7. Your privacy rights. How to delete your account
8. Use by children
9. Interaction with third party products
10. Cookies and Analytic tools
11. Specific provisions applicable under US privacy laws
12. Contact us

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

1. When you browse or visit our website
   Personal Data we collect: Data collected through cookies, analytic tools and log files, such as IP addresses, unique device identifiers, pages visited, and other information derived from your interaction with our Services.
   Why is the Personal Data collected and for what purposes? Such Personal Data is collected to provide you with our Services and improving them, as well as for marketing, analytics, and statistics purposes.

2. When you contact us (such as via email, completing a form on our website or subscribing to updates)
   Personal Data we collect: Full name, email, job title and details about your company (name, size, industry), and any other Personal Data you decide to provide us with.
   Why is the Personal Data collected and for what purposes? To respond to your queries, to send you updates, news, promotions, communications, surveys, and other marketing communications.
   You can opt-out from receiving marketing communications at any time, by contacting us at: privacy@panjaya.ai, or as outlined in section ‘Your Privacy Rights. How To Delete Your Account’ below.

3. When we process your job application
   Personal Data we collect: Full name, email address, phone number, your CV, your LinkedIn profile URL, your personal website, your cover letter, your portfolio, answers to the candidates’ questionnaires (e.g., qualification for the job) and any other Personal Information you chose to decide to provide/supply us with.
   Why is the Personal Data collected and for what purposes? To process your job application and to assess you as a candidate, or to protect our rights.

4. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter and LinkedIn)
   Personal Data we collect: Full name, company name, position and title, work history, possible email, other information provided by the social media networks when you interact with an advertisement (e.g., information provided by the social media channel when you click on an ad) and any other Personal Data you chose to decide to provide us with.
   Why is the Personal Data collected and for what purposes? To establish a business connection and to communicate with you and to send you marketing communications.

In addition to the foregoing, please note that some of the abovementioned Personal Data will be used for the following purposes:

1. Detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes.
2. Complying with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
3. Conducting a due diligence of the Company in connection with a third party contemplating the purchase or investment of the Company.

In certain cases, we may anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

CUSTOMER INFORMATION

For the avoidance of doubt, Panjaya is processing Customer Information on behalf of its customer with whom it has contractual relationship (as further outlined above). In such cases, the customer is responsible for the security, integrity and authorized usage of Customer Information in the context of the Services and also for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Customer Information. In the context of Panjaya’s services, the customer can upload, add, input and/or receive to the platform (at the customer’s sole discretion) information, including Personal Data (“Customer Information”).

Customer Information is not regulated by this privacy policy, and this paragraph is provided only for transparency purposes, as well as other policies that Panjaya makes available, for example the notice for users of the platform, see here. If you have any questions related to the Customer Information, please contact the applicable customer directly.

LEGAL BASES

We process Personal Data about individuals under one of the following legal bases:

1. Consent: We process your Personal Data based on your consent, such as for marketing, for analyzing your interaction with the Services, to communicate with you or respond to your requests, etc. We may rely on your consent which we obtain through our cookie notice and consent management in order to implement tracking technologies. You may withdraw consent at any time by using the cookie preference settings (further information can be found in the ‘COOKIES AND ANALYTIC TOOLS’ section below).
2. Performance of a contract: Where we process Personal Data about individuals who engaged with us directly to receive our Service, or applied as candidates, we do so as necessary to fulfill our contractual obligations.
3. Legitimate interest: We process Personal Data about individuals in accordance with our legitimate interests, such as, as applicable, to improve and enhance our Services, to understand how our Services are used, to optimize our marketing, advertising, customer services and support operations, to maintain the security of our Services, to enforce any applicable terms and conditions of service, to protect or defend the Services and our rights, recruitment planning, and maintaining a well-managed and orderly workforce and business and management forecasting.
4. Compliance with our legal obligations: Where we process Personal Data to comply with any applicable legal obligations to which we are subject, such as, reporting of illegal activity.

HOW WE PROTECT AND RETAIN YOUR INFORMATION

1. Security: We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2. Retention of your Personal Data: We may retain your Personal Data until we no longer need the information for the purposes outlined in this Policy, or you until we adhere to your valid deletion request (as further outlined below). Please note that in some circumstances we may store your Personal Data for longer periods of time, for example where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, for us to have an accurate record of your dealings with us in the event of any complaints or challenges, if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings or to enforce our terms and conditions and policies.
   Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you.

TO WHOM WE DISCLOSE YOUR PERSONAL DATA AND FOR WHAT PURPOSE

We may disclose your Personal Data as follows:

1. Entities within the Company’s group: We may disclose your personal information with our affiliated companies as necessary for administrative, management or other business-relates purposes, to operate our website, to communicate with you, to offer and provide our Services to you, etc.
2. Service providers: We may use third party service providers to process your personal information for the purposes outlined above, including, without limitation: (i) with cloud service providers for hosting purposes; (ii) with websites and web content creation platforms in order to help us manage our website; (iii) with email providers, marketing, CRM, other similar tool providers; (iv) with analytic companies, in order to help us understand and analyze information we collect in accordance with this policy; and (v) with recruiters, hiring managers and other interviewers. We may also share such data with our business, legal and financial advisors.
3. Legal and regulatory entities: To the extent necessary, we may disclose your personal information with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Panjaya, our services, customers, employees, property, and the public.
4. Mergers and acquisitions: If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.

Where you have otherwise provided your consent to us for sharing or transferring your information we will disclose your personal information in accordance with your consent.

When disclosing Personal Data to third parties, they are required to secure the Personal Data they receive and to use that Personal Data only in compliance with all applicable data protection regulations.

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@panjaya.ai (as further outlined in ‘YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT’ section below).

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

In order to run our business and provide our website and Services, we transfer Personal Data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your Personal Data may be processed in countries with privacy laws that are different from privacy laws in your country.

Where we transfer your Personal Data outside of EEA or the UK (for example to third parties who provide us with services), we rely on the mechanisms required by applicable law, in particular: i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), ii) Standard Contractual Clauses issued by the European Commission, or iii) the recipients certification to the EU-US Data Privacy Framework and/or the Swiss or UK extensions. Panjaya also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by applicable law.

YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

1. You have the right to withdraw consent to the processing, where consent is the basis of processing.
2. You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
3. You have the right to request the rectification of inaccurate personal information about you.
4. You have the right to object to unlawful data processing under certain conditions.
5. You have the right to request the deletion of past data about you under certain conditions.
6. You have the right to request that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
7. You have the right to request that personal information concerning you will be transferred to another controller in a structured, commonly used, and machine-readable format, subject to certain conditions.
8. The personal information we collect is not used for automated decision-making and profiling.
9. As outlined below, you can opt out of direct marketing by contacting us directly, or by following the instructions through the unsubscribe options in our email messages.
10. You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising” (all as defined under the US privacy laws), often referred to as “interest-based advertising” or “targeted advertising”.
11. You have the right not to be subject to unlawful discrimination by us for exercising any of the rights above.

For EU and UK residents: If you think we have infringed data protection laws, you also have the right to lodge a complaint with a data protection supervisory authority in the EEA country in which you live or work, or where you think we have infringed data protection laws, or with the UK ICO, as applicable to you

You can exercise your rights by contacting us at privacy@panjaya.ai. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Please be aware that only you, or someone legally authorized to act on your behalf, may make a request related to Personal Information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

Opt-out from marketing emails: We may send you direct messages and other updates about new features, offering, events and special opportunities. You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@panjaya.ai. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@panjaya.ai. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of majority under applicable law (“Age of Majority”). If you are under the Age of Majority, do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@panjaya.ai.

INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service

COOKIES AND ANALYTIC TOOLS

Cookies. Our Services may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

We reserve the right to remove or add new analytic tools.

SPECIFIC PROVISIONS APPLICABLE UNDER US PRIVACY LAWS ¹

1. Collection, Disclosure and Sharing of Personal Information

In the preceding 12 months, we have collected the following Personal Information:

Categories of Personal Information	Data Types
Identifiers	For example, name, surname, email, phone number, username, password, social media accounts, and profile picture
Personal information categories listed in the California Customer Records Statute	For example, name, address, telephone number, profile picture, education and employment information (from business partners and candidates).
Internet or other similar network activity	For example, IP addresses, unique device identifiers, device and operating system, browser version, pages visited, advertisements viewed or clicked on, your geographic location, log data and other information derived from your interaction with our Services.
Geolocation data	IP address and your geographic location
Professional or employment-related information	From our customers: title or profession, employer, etc. From candidates: current or past job history.
Education information	Including information about candidates’ educational background, such as education records and transcripts that are not publicly available.

Sources of Information

In the preceding 12 months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

• Directly, through your activity on our Services: For example, from forms you complete on our website, or when you apply to a job.
• Automatically from you: We track your activities across the internet, for example, when you view or interact with certain content, web page or ad. or when we collect your usage data automatically from measurement tools such as those implemented on our websites.
• From third-parties: For example, from advertisers, service providers who assist us in performing the Services for our customers, social networks, and data brokers.

We do not “Sell” but we may “Share” Personal Information about you, as these terms are defined under US Privacy Laws.

In the preceding twelve (12) months we may have shared and disclosed your Personal Information, as described below:

Category of Recipient	Type of Data	Disclosed or Shared
Advertisers	Unique identifiers, IP address, user activity data (interaction with Ads)	Shared
Service Providers	All types of Personal Information	Disclosed
Any acquirer of our business	All types of Personal Information	Disclosed
Legal and regulatory entities	Subject to law enforcement or a competent authority request.	Disclosed

When we disclose Personal Information, we ensure that the recipient only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Personal Information they receive, and to use it for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulation (such service providers may use other Non-Personal Data for their own benefit).

2. Purposes for Collection, Use, & Sharing

In addition to the practices detailed above, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

• Auditing related to our interactions with you;
• Legal compliance;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
• Debugging;
• Performing services (for us or our service provider);
• Internal research for technological improvement;
• Internal operations;
• Activities to maintain and improve our services; and
• Other one-time or short-term uses.
3. California Privacy Rights:

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@panjaya.ai. Please note that we are only required to respond to one request per customer each year.

4. California Do Not Track Notice (Shine the Light):

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.

CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@panjaya.ai