Privacy Notice

Effective date: 16 September 2026. Please note that this document is updated from time to time.

Jobzly, as stated in the Contact information section ("we" or "Jobzly"), wants to inform you about the ways we process your personal data. In this Privacy Notice we explain what personal information we collect, use and disclose. Personal data means any data relating to an individual who can be identified, directly or indirectly, based on that information. This may include information such as names, contact details, (online) identification data, online identifiers, or other characteristics specific to that individual.

This Privacy Notice applies when you visit and/or use our Website (https://jobzly.app/) or our iOS and Android Apps and the services available through them (the "Services"). It also explains what personal data is collected when you use the Services, and how such personal data will be processed.

By using the Services, you promise us that: (I) you have read, understand, and agree to this Privacy Notice, and (II) you are over 16 years of age (or have had your parent or guardian read and agree to this Privacy Notice for you).

If you do not agree or are unable to make this promise, you must not use the Services. In such case you must (a) contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by instructions on the Services; and (c) leave the Services and not access or use them.

"Personal data" or "Personal information" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (Article 4 (1) of the GDPR).

Personal information we collect

The type of Personal information we collect depends on how you are specifically interacting with us and which Services you are using. Generally, we collect the following categories of Personal information:

• Name and contact details, such as first and last name, age, gender, email address, postal address and other onboarding answers.
• Usage information, such as behavioural information about how you navigate within our Services and which elements of our Services you use, your wish list, preferences, interests, and so on.
• Device identifiers: advertising ID (an advertising device identifier used to track user behaviour for advertising purposes) and Android ID (a unique device identifier provided by the operating system).
• In-app event data: user actions within the app, such as lesson completion, purchases and clicks, and the time spent by the user in the app.
• Campaign data: installation source (information about where the user was acquired from, for example social media or search engine ads) and data about the advertising campaigns that led the user to install the app.
• User information: IP address (used to determine the geographic location of the user), device type and operating system.
• Application performance data: errors and failures that help diagnose problems and improve the application.
• Session information: the amount of time a user spends in the application in a single session.
• Other information shared by you through our Services or communicated to us, including other answers to our onboarding questions.

Please note that we also automatically collect from your device: computer, device and connection information, such as language settings, IP address, time zone, type and model of a device, device settings, and operating system. We need this data to provide our Services, analyse how our customers use the Services, and to measure ads.

How we collect and process your personal information

We and our third-party service providers may collect Personal information from the following sources:

• Direct interactions, such as when you register for our Services, upload content, email us or contact us.
• Automated tracking technologies, such as cookies, web logs and internet tags collecting information automatically about your interaction with our Services.

Cookie files

Read more about cookies and the purposes we use them for in our Cookie Policy.

With whom we share your personal data

Affiliates and subsidiaries

We may share your information with our affiliated entities such as subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.

Service providers

We may provide access to or share your information with select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation course providers, banking, advisory services, identification verification, billing, customer service, data storage, security, fraud prevention, payment processing, user marketing and behaviour analysis, and legal services.

Legal process

We may disclose your information in response to any subpoenas, court orders, or other legal processes we receive, or to establish or exercise our legal rights or to defend against legal claims.

Investigations

We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Notice or the Terms of Service for the Services you accessed, and/or to protect the rights and property of Jobzly, our employees, users, and the public. This may involve sharing your information with law enforcement, government agencies, courts, and/or other organisations.

Third-party integrations

When you initiate a connection with a third-party integration through the Services, we will share information about you that is required to enable your use of that integration. For improving our Services and serving ads, we use third-party solutions. As a result, we may process data using solutions developed by Facebook, Google, TikTok, Apple, PayPal and others, and some of the data is stored and processed on servers of such third parties. This enables us to:

• analyse different interactions with and within the Services (how often users subscribe, which learning goals are the most popular, the average time spent by users on the Services, and so on);
• serve ads, and show them only to particular groups of users, for example to subscribers.

Consequently, we better understand which of our features and content you see the most value in, and are able to focus on them to enhance your experience and increase the quality of our products.

De-identified and aggregated information

As stated above, we may share and monetise de-identified and aggregated information collected as survey data or market research from our subscribers.

Your consent

We may also disclose your information to third parties with your prior consent.

For what purposes we process your personal data

Depending on how you interact with us and use our Services, we may use your personal information for the following purposes:

• Improving our Services and developing new products, such as inviting you to participate in surveys or personalising your experience with our Services. This processing is necessary for the purposes of our legitimate interests and by your consent.
• Marketing, such as providing you with marketing or advertising communications that we think you may be interested in. This processing is with your given consent or for our legitimate interests.
• Providing online communities, such as making chat rooms, forums, message boards or news groups available to you. This processing is necessary for the performance of a contract or our legitimate interests. Please remember that any information disclosed in these forums is public. We encourage you to exercise caution when disclosing personal information in them, as this information is made available to other users. Do not disclose information in these public forums that might be considered confidential or proprietary, that you do not wish to be publicly available, or that you are prohibited from disclosing.
• Other general business support purposes, including but not limited to procurement, financial and fiscal management, risk and compliance management, and external reporting. This processing is necessary for compliance with a legal obligation to which we are subject, or is otherwise lawful under applicable data protection laws, or is for our legitimate interests.
• Sending you marketing communications. We process your Personal data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish a legal basis for sending you marketing communications. As a result, you will receive information about our products, such as special offers. If you do not want to receive marketing emails from us, you can unsubscribe by following the instructions in the footer of the marketing emails.
• Personalising our ads. We and our partners, including Facebook and Google, use your Personal data to tailor ads and possibly show them to you at a relevant time. This processing is with your given consent or for our legitimate interests.
• Setting up and administering your account on the Services. This processing is with your given consent, and for the conclusion and/or performance of a contract.
• Providing you with access to our Services and their further use. This processing is with your given consent, and for the conclusion and/or performance of a contract.
• Conducting internal research, development, testing and improvement of the features and functions of our Services. This processing is with your given consent, for the conclusion and/or performance of a contract, and for legitimate interest.
• Providing customer support. This processing is with your given consent, and for the conclusion and/or performance of a contract.
• Meeting our internal and external audit requirements, including our information security obligations. This processing is based on a legitimate interest.
• Administrative, analytical and statistical purposes. This processing is based on a legitimate interest.
• Notifying you of any changes and making other announcements related to the Services. This processing is with your given consent, for the conclusion and/or performance of a contract, and for legitimate interest.
• Managing your subscription and unsubscription. This processing is with your given consent, for the conclusion and/or performance of a contract, and for legitimate interest.
• Protecting against malicious actions of users (such as fraud), detecting and/or investigating a crime in connection with other security considerations. This processing is based on a legitimate interest.
• Processing your inquiries and/or complaints and responding to them. This processing is based on a legitimate interest.
• Responding to requests from data subjects, supervisory and/or law enforcement authorities. This processing is based on a legitimate interest and compliance with legal requirements.
• Protecting other legitimate interests, for example preparing a claim or a defence to a claim. This processing is based on a legitimate interest.

How to opt out of or influence personalised advertising

Android: to opt out of ads on an Android device, open the Google Settings app on your mobile phone, tap "Ads" and enable "Opt out of interest-based ads". You can also reset your advertising identifier in the same section, which may help you see less personalised ads.

iOS: go to Settings → Privacy & Security → Tracking and turn off "Allow Apps to Request to Track", and in Settings → Privacy & Security → Apple Advertising turn off "Personalised Ads".

macOS: go to System Settings → Privacy & Security → Apple Advertising and deselect "Personalised Ads".

Windows: select Start → Settings → Privacy and turn off the setting that lets apps use the advertising ID to make ads more interesting to you based on your app activity.

Merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers' information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (for example a parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Business transfers

If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Services can continue to operate. In such a case, your information would remain subject to the promises and commitments contained in this Privacy Notice until such time as this Privacy Notice is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Jobzly will comply with those restrictions.

Data storage term

We retain Personal information only as long as it is necessary to fulfil the purposes for which it was collected. Due to regulatory requirements, most Personal information is stored as long as you are registered with the Services. If you want to delete your account, all Personal data (such as which segment you belong to or any other information generated for marketing purposes) is erased, unless legislation or regulatory requirements require that we retain it. In that case, such Personal data will be kept as long as required in accordance with the applicable laws and/or regulations.

Legal bases for processing your personal data

EU/EEA data privacy law

With respect to data protection legislation in the European Economic Area, the UK and Switzerland, including the GDPR, Jobzly acts as a "Data Processor" concerning user information of EU/EEA/UK/Swiss-based persons. When preserving transaction records in accordance with regulatory or industry requirements, Jobzly may act in such circumstances as a "Data Controller". When Jobzly sets up a user account we are required to conduct various payment security, anti-money laundering, credit and KYC checks; when managing such Personal data with respect to EU/EEA/UK/Swiss-based individuals, Jobzly acts as a "Data Controller".

EU/EEA/UK/Swiss-based users will be asked to expressly consent to the provision of personal information or the initial setting of cookies when visiting Jobzly web properties, so that there is a clear legal basis for processing such data. In other cases, personal information will be processed legally by virtue of the performance of contractual obligations relating to Jobzly's legitimate interest, legal obligation, or the defence or preservation of Jobzly's legal rights.

Jobzly complies with legal requirements to provide adequate safeguards for transfers of personal data outside the EU/EEA, the UK and Switzerland, including, where applicable, the European Commission's Standard Contractual Clauses and the EU-US and UK-US Data Privacy Framework.

Individual users from the EU/EEA/UK and Switzerland or other regions with laws governing data collection and use should note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which Jobzly may operate. By providing your personal information with respect to a transaction or through an express consent mechanism, you consent to any transfer and processing in accordance with this Privacy Notice.

Individuals from the EU/EEA/UK and Switzerland may have the right to exercise additional data subject rights under data privacy laws, including the following:

• The right to request information about the purpose of the processing; the categories of Personal data concerned; who else outside Jobzly might have received the data from Jobzly; what the source of the information was (if you did not provide it directly to Jobzly); and how long it will be stored.
• The right to correct the record of your Personal data maintained by Jobzly if it is inaccurate. You may also request that we cease using your data for direct marketing purposes.
• Right of erasure: the right to erasure of personal information that we hold about you if it is no longer necessary in relation to the purpose for which it was originally collected. Please note that Jobzly may need to retain certain data to complete transactions, perform refunds, maintain records or comply with legal obligations, tax and accounting requirements.
• Right to restrict processing of your personal information in certain circumstances, for example where such data is inaccurate or unlawfully held.
• Right to data portability: available in certain circumstances, to receive your personal information in a structured, commonly used format and to have such data transferred to another service.
• Right to lodge a complaint with the relevant supervisory authority (data protection regulator).

In order to exercise any of these rights please contact us at support@jobzly.app.

USA residents' rights

If you are a resident of the USA, you are entitled to the following rights in connection with our processing of your Personal data in accordance with current data protection legislation:

• the right to know about the personal information we collect about you and how it is used and shared;
• the right to delete personal information collected from you (with some exceptions). You may access, review and edit your Personal data at any time by contacting our customer support at support@jobzly.app. We will verify your identity prior to responding to any request.

Please note that when you contact us, you must go through the identification process and describe your specific requirements so that we can process your request and give a lawful response. If we cannot identify you via messages or requests, or if we have reasonable suspicions about your identity, we may ask you to provide proof of identity. This is the only way we can avoid disclosing your Personal data to someone who may impersonate you; the identification process is carried out in your best interests. Any additional information collected for verification purposes will only be used to verify identity.

While we process requests as quickly as possible, please keep in mind that providing a complete and lawful response regarding Personal data is a complex process that can take up to a month or even longer. If we need more time to prepare a complete response, we will let you know.

Additional country disclosures

California

Privacy laws that apply in certain places, like California, treat "businesses" and "service providers" differently. Under those laws, a business is a company that decides why and how to process Personal information, while a service provider processes personal information on behalf of a business in order to provide services. When Jobzly processes the Personal data of its users for its own purposes — such as running your account, providing lessons and improving the Services — Jobzly acts as a business. Where we process data strictly on behalf of and under the instructions of another company, we act as a service provider.

If you live in California, California law gives you the right to ask if we disclose your personal information to third parties for their direct marketing purposes (we do not disclose your personal information for others' direct marketing purposes). It also gives you the right to ask if we sell your personal information to third parties (we do not sell your personal information and have not done so in the past), and if we did, you would have the right to opt out of such sales.

Our California Do Not Track notice

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honour DNT signals or similar mechanisms transmitted by web browsers.

Deletion of content from California residents

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted, and there may be circumstances in which the law does not require us to enable the removal of content.

Sale of personal information. Disclosure for business purposes. Financial incentives

We do not sell any personal information and we do not disclose any personal information for any business purpose. Therefore, we have not sold or disclosed consumers' personal information for business purposes in the preceding 12 months.

California Consumer Privacy Act and interest-based advertising

Under the California Consumer Privacy Act, you have certain rights with respect to the personally identifying information you provide to us.

As described in this Privacy Notice, Jobzly and third parties that provide advertising or other functionality on our behalf may use cookies, pixel tags and other technology to help us advertise our products and services to you as informed by your interests. This approach is called interest-based advertising, which means we tailor our ads to you based on information that gives us a sense of what interests you, such as information collected from your activity on the web, including browsing or purchasing products on or through our websites or on third-party websites, your activity on mobile sites and applications, or your responses to our marketing emails.

Jobzly does not sell your data, has not in the past, and is committed to not doing so in the future. While we do not believe Jobzly's interest-based advertising activities constitute a "sale" under the CCPA, we provide you with ways to control the cookies, similar technologies and internet-based information you may share with us.

Changes to this Privacy Notice

Jobzly may update this Privacy Notice from time to time. In the event we materially change this Privacy Notice, including how we collect, process or use your personal information, active clients will be notified in accordance with Jobzly's Terms. Potential clients are notified by means of the publication of the updated Privacy Notice on our App and/or Website. We recommend that you check our Services from time to time to inform yourself of any changes in this Privacy Notice or any of our other policies.

Deleting your account

Should you ever decide to delete your account, you may do so by writing to support@jobzly.app.

If you terminate your account, any association between your account and the 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.

Data retention

We will store your Personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Notice (including providing the Services to you), which includes but is not limited to the period during which you have an account with the App. We will also retain and use your Personal data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

To determine the corresponding retention period for Personal data, in addition to processing objectives, we also consider the volume, nature and category of Personal data, the potential risk of harm from unauthorised use or disclosure of Personal data, as well as the relevant requirements of applicable legislation.

Please note that the regulations of some countries may impose additional requirements, so the Personal data retention period may vary. In particular, if the legislation of the country where a user of our Services resides contains statute of limitation provisions that determine the period during which you can file a claim against us, and we therefore need appropriate evidence of legal relations with you, we can process your Personal data during this period.

We also need to consider any periods for which we may need to retain your Personal data to comply with our legal obligations to you or to regulatory authorities.

Eventually, we can minimise the Personal data that we process, or even make your Personal data anonymous (for research or statistical purposes) so that it is no longer connected with you personally. If Personal data is anonymised, we can use this information essentially indefinitely, since it no longer contains any Personal data.

How "Do Not Track" requests are handled

Except as otherwise stipulated in this Privacy Notice, Jobzly does not support "Do Not Track" requests. To determine whether any of the third-party services we use honour "Do Not Track" requests, please read their privacy policies.

Children's personal information

Our Services are general audience services not directed at children under the age of 16. If we learn that any information we collect has been provided by a child under the age of 16, we will promptly delete that information.

We do not knowingly process Personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at support@jobzly.app.

How you can access and update your information

To access, review, update and/or delete certain user profile information, you may log into the Services and update your account, or contact us at support@jobzly.app. Please remember, however, that if we have already disclosed some of this user profile information to third parties, we cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

Data security: how we protect your information

We are very serious about the security of Personal data. To ensure the secure storage of your Personal data, we have implemented a variety of technical and administrative tools that protect Personal data from any unauthorised or illegal processing and any loss, destruction or damage. We regularly test our security measures to ensure they remain operational and effective.

The Personal data you provide will be safely stored on our servers, which are inaccessible to the public.

We adhere to the principle of data minimisation. We process information related to our users and customers that is really necessary for us to perform certain functions and for the specific goals defined in this Privacy Notice. Your Personal data is available only to a limited number of employees who need access to the relevant Personal data to fulfil their functional duties. We constantly train our employees on our policies regulating data privacy and security issues.

We do our best to protect Personal data, but you need to be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If we learn of a security breach, we will endeavour to notify you, provided that we are obliged to do so under applicable legislation, so that you can take appropriate security measures.

We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect information from unauthorised access by physical and electronic intrusion. If you have any questions about how we protect your information, you can contact us at support@jobzly.app.

How to contact us

Please let us know if you have any questions about this Privacy Notice by contacting us. Please note that when you contact us, you must go through the identification process and describe your specific requirements so that we can process your request and give a lawful response. If we cannot identify you via messages or requests, or if we have reasonable suspicions about your identity, we may ask you to provide proof of identity. Any additional information collected for verification purposes will only be used to verify identity.

While we process requests as quickly as possible, we ask you to keep in mind that providing a complete and lawful response regarding Personal data is a complex process that can take up to a month or even longer. If we need more time to prepare a complete response, we will let you know.

Contact information