PRIVACY POLICY

KLOK Oy (“KLOK”, or “we”) collects and processes personal data of users of our online services and
website. This Privacy Policy applies to personal data we obtain from individuals (“Users”) through
our websites, online services, and web-based applications (collectively, the “Services”). In regard to
this data we shall be acting as a data controller in the meaning of the EU data protection legislation.

Some of our services might be subject to a separate privacy policy. If a separate privacy policy
applies to a particular service, we will post it on the relevant website or otherwise make it available
in connection with the service in question.

Our Privacy Policy explains what data we process, how we do that and how the data subjects, i.e.
Users, may use their rights (e.g. right to object, right of access).

This Privacy Policy may be updated if required in order to reflect the changes in data processing
practices or otherwise. The current version can be found on our website. We will not make substantial
changes to this Privacy Policy or reduce the rights of Users under this Privacy Policy without
providing a notice thereof.

This Privacy Policy only covers data processing carried out by KLOK. The Privacy Policy does not
address, and we are not responsible for, the privacy practices of any third parties. KLOK disclaims
all responsibility for the processing carried out by third parties, also in cases where Services include
hyperlinks or other links to third parties’ websites or services.

Privacy, security and online safety are important for us, and we process all personal data with due
care and in accordance with applicable laws and regulations.

1. KLOK’S CONTACT DETAILS

Name: KLOK Creative Agency Oy
Company ID: 2288743-1
Correspondence address: Bulevardi 21, 00180 Helsinki, Finland
E-mail address: klok@klok.fi
Website: KLOK.fi

2. PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect the following information types of the Users:

(i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify
individuals, sometimes individuals can be recognized from it, either alone or when combined or
linked with User Data. In such situations, Technical Data can also be considered to be personal data
under applicable laws and we will treat the combined data as personal data.

During the User’s use of the Services, KLOK may collect and process for example the following User
Data from Users: (i) first and last name; (ii) e-mail address; (iii) phone number; (iv) Name and
information regarding the organization the User represents; (v) information that Users provide when
rating our Services or giving feedback on our Services; (vi) any other personal data Users may
provide themselves.

The specific kind of User Data collected will depend on the Services used. User Data is received
directly from Users.

Technical Data may include for example the following data (i) User’s IP address; (ii) browser type
and version; (iii) preferred language; (iv) geographical location using IP address or the GPS,
wireless, or Bluetooth technology on your device; (v) operating system and computer platform; (vi)
the full Uniform Resource Locator (URL) clickstream to, through, and from our Services, including
date and time; and (vii) areas of our Services User has visited.

Cookies

We use various technologies to collect and store Technical Data and other information when Users
visit our Services, including cookies. Cookies allow us to calculate the aggregate number of people
visiting our Services and monitor the use of the Services. This helps us to improve our Services and
better serve our Users. We may also use cookies that make the use of the Services easier, for
example by remembering usernames, passwords and preferences. We may use tracking and
analytics cookies to see how well our Services are being received by our Users, and use unique
cookie identifiers for tracking purposes.

Users may choose to set their web browser to refuse cookies, or to alert when cookies are being
sent. This can usually be done through Internet browser’s settings. Information about how to manage
cookies can be found online.

Please note that some parts of our Services may not function properly if use of cookies is refused.
Google Analytics
Our Services use web analytics services to compile Technical Data and reports on visitor usage and
to help us improve our Services. For an overview of Google Analytics, please visit Google Analytics.

3. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA

Purposes

There are several purposes for the processing of personal data by KLOK:

To provide our Services and carry out our contractual obligations

We process personal data in the first place to be able to offer the Services to Users and to run,
maintain and develop our business. We process and use personal data for example to provide
essential functionalities for customers and Users, i.e. in order to match customers with Users and
vice versa. In some cases, personal data may be processed in order to carry out our contractual
obligations towards the User. We may use the data for example to offer essential functionalities of
the Services and to provide access to the Services. If User contacts our customer service, we will
use the provided information for answering questions and solving possible issues.

For customer communication

We may process personal data for the purpose of contacting Users regarding our Services and to
inform Users of changes in our Services. Data may also be used for research and analysis purposes
in order to improve our Services.

For quality improvement and trend analysis

We may process information regarding the use of the Services to improve the quality of our Services
e.g. by analysing any trends in the use of our Services. When possible, we will do this using only
aggregated, non-personally identifiable data.

For statistical and analytical purposes

KLOK may gather Technical Data and other anonymous and aggregate data in order to generate reports and statistics. We may use statistics and reports for sales and marketing purposes. In
addition, we may provide customers and Users with the aforementioned statistics and reports. For
clarity, such statistics and reports do not include any personal data.

For other legitimate purposes

We process personal data for the purposes of direct marketing, such as the sending of newsletters
or similar marketing material. Users can unsubscribe from receiving such material at any time.

In some parts of the Services, Users may be requested to grant their consent for the processing of
personal data. In this event, Users may withdraw their consent at any time.

4. TRANSFER TO COUNTRIES OUTSIDE EUROPE

The data handled within our service is stored within the EU/EEA.

For our website functions we use service providers in several geographical locations, such as Google
Analytics. As such, we and our service providers may transfer personal data to, or access it in,
jurisdictions outside the European Economic Area or the User’s domicile. We will take steps to
ensure that Users’ personal data receives an adequate level of protection in the jurisdictions in which
we process it. We provide adequate protection for the transfer of personal data to countries outside
of the European Economic Area through a series of intercompany agreements and agreements with
our service providers based on the Standard Contractual Clauses or other similar arrangements.

More information regarding the transfers of personal data may be obtained by contacting us on
addresses mentioned in this Privacy Policy.

5. RECIPIENTS

We only share personal data within the organisation of KLOK if and as far as reasonably necessary
to perform and develop our Services.

We do not share personal data with third parties outside of KLOK’s organization unless one of the
following circumstances applies:

It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to perform the Services, KLOK has
taken appropriate contractual and organisational measures to ensure that personal data are
processed exclusively for the purposes specified in this Privacy Policy and in accordance with all
applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside KLOK’s organization if we have a good-faith
belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable
law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or
technical issues; and/or (iii) protect the interests, properties or safety of KLOK, our Users or the
public in accordance with the law. When possible, we will inform Users about such transfer and
processing.

To authorized service providers

We may share personal data to authorized service providers who perform services for us (including
data storage, sales, payment service, marketing and customer support service providers). Our
agreements with our service providers include commitments that the service providers agree to limit
their use of personal data and to comply with privacy and security standards at least as stringent as
the terms of this Privacy Policy. Please bear in mind that if you provide personal data directly to a
third party, such as through a link on our website, the processing is typically based on their policies
and standards.

For other legitimate reasons

If KLOK is involved in a merger, acquisition or asset sale, we may transfer personal data to the third
party involved. However, we will continue to ensure the confidentiality of all personal data. We will
give notice to all Users concerned when the personal data are transferred or become subject to a
different privacy policy as soon as reasonably possible.

With explicit consent

We may share personal data with third parties outside KLOK’s organization for other reasons than
the ones mentioned before, when we have the User’s explicit consent to do so.

Due to the functionalities of our Services, personal data of a User might be transferred to KLOK’s
customers. When a customer searches for suitable employees, only the current title, domicile and
competences of the relevant User are visible to the customer. In order to apply for a certain position
or to submit an application to certain customer, User is required to give a consent for the transfer of
User’s personal data to said customer. The User shall remain anonymous until the User has
separately consented to the transfer of User’s identification and personal data to a certain customer.
By giving the consents and permissions, User warrants and represents that User is allowed and
permitted to give such consents and permissions.

6. STORAGE PERIOD

KLOK does not store personal data longer than is legally permitted and necessary for the purposes
of providing the Services or the relevant parts thereof. The storage period depends on the nature of
the information and the purposes of processing. The maximum period may therefore vary per use.

Typically, we will store User’s personal data for as long as the User is a registered subscriber or a
registered user of our Services or for as long as we have another purpose to do so and, thereafter,
for no longer than is required or permitted by law or reasonably necessary for internal reporting and
reconciliation purposes.

In general, personal data of Users are deleted within reasonable time after the User no longer uses
any part of the Services or when the User makes a request regarding deletion of User’s personal
data.

7. USERS’ RIGHTS

Right to access

KLOK offers access for the Users to the personal data processed by KLOK. This means that Users
may contact us and we will inform what personal data we have collected and processed regarding
the said User and the purposes such data are used for.

Right to withdraw consent

In case the processing is based on a consent granted by User, User may withdraw the consent at
any time. Withdrawing a consent may lead to fewer possibilities to use our Services.

Right to correct

Users have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal
data we have stored about the User corrected or completed.

Right to deletion

Users may also ask us to delete the User’s personal data from our systems. We will comply with
such request unless we have a legitimate ground to not delete the data. We may not immediately be
able to delete all residual copies from our servers and backup systems after the active data have
been deleted. Such copies shall be deleted as soon as reasonably possible.

Right to object

Users may object to certain use of personal data if such data are processed for other purposes than
purposes necessary for the performance of our Services to the User or for compliance with a legal
obligation.

Users may also object any further processing of personal data after prior given consent. If User
objects the further processing of personal data, this may lead to fewer possibilities to use our
Services.

Notwithstanding any consent granted beforehand for the purposes of direct marketing, User has the
right to prohibit us from using User’s personal data for direct marketing purposes, market research
and profiling by contacting us on the addresses indicated above or by using the functionalities of the
Services or the unsubscribe possibility offered in connection with any direct marketing messages.

Right to restriction of processing

Users may request us to restrict certain processing of personal data, this may however lead to fewer
possibilities to use our Services.

Right to data portability

Users have the right to receive their personal data from us in a structured and commonly used format
and to independently transmit those data to a third party.

How to use the rights

The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses
set out above, including the following information: name, address, phone number and a copy of a
valid ID. We may request the provision of additional information necessary to confirm the identity of
the User.

We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

8. LODGING A COMPLAINT

In case User considers our processing of personal data to be inconsistent with the applicable data
protection laws, a complaint may be lodged with the local supervisory authority for data protection.

9. INFORMATION SECURITY

It is our responsibility to protect our platform and data with best possible solutions.
We take all reasonable and appropriate security measures to protect the personal data we store and
process from unauthorised access or unauthorised alteration, disclosure or destruction. Measures
include for example, end-to-end TLS communication encryption and encryption of sensitive user
information. We monitor data security threats and solutions, and take them into account in our
platform solutions and architecture.

We use administrative, organizational, technical, and physical safeguards to protect the personal
data we collect and process. Our security controls are designed to maintain an appropriate level of
data confidentiality, integrity, and availability. We regularly test our websites, data centres, systems,
and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative
effects to the privacy of Users, we will inform the relevant Users and other affected parties, as well
as relevant authorities when required by applicable data protection laws, about the breach as soon
as reasonably possible.

For more information, contact our COO Ilkka Haavisto, Ilkka.haavisto@klok.fi.