Privacy Policy

1. Data Controller

1.1 The controller of the personal data collected through the Site is Howdy, Inc., a company incorporated under the laws of the State of Texas, United States.

1.2 This Policy applies exclusively to information collected through the Site and does not apply to information obtained offline or through other channels not controlled by Howdy.

2. Information We Collect

2.1 We collect personal data when the user uses the Site, applies for professional opportunities, completes forms, registers for activities, participates in events, or communicates with us through the Site.

2.2 Personal data may include, among others:

2.2.1 Identification and Contact Data

• First and last name
• Email address
• Phone number
• Country and city of residence

2.2.2 Professional Information

• Resume (CV)
• Work experience
• Technologies and skills
• Languages
• Education and certifications
• Links to professional profiles (for example, LinkedIn, GitHub, personal portfolio)

2.2.3 Communication Information

• Messages, inquiries, or requests sent through the Site or associated channels.

2.2.4 Technical and Browsing Data

• IP address
• Browser and device type
• Cookie information
• Pages visited and browsing behavior
• Site analytics and performance data

2.3 Howdy will at no time collect banking information, financial data, or sensitive information. However, if the User provides sensitive personal data, such data will be processed in accordance with this Policy and only to the extent necessary for the purposes described herein or in accordance with applicable regulations.

2.4 While the provision of personal data is voluntary, the User acknowledges that certain data is necessary in order to participate in selection processes and access job opportunities. If such data is not provided, Howdy may not be able to evaluate the User's profile or consider their candidacy for certain positions.

3. Information Provided Voluntarily and Third-Party Data

3.1 The user may provide additional information voluntarily through the Site.

3.2 If the user shares personal data of third parties (for example, professional references), the user declares to have the corresponding consent or authorization to share such information and warrants that the data provided is truthful and legitimate.

3.3 Howdy will not be responsible for third-party information sent without authorization by the user.

3.4 Howdy will process such third-party data only for the purposes set out in this Policy and assumes no responsibility for the improper or unauthorized use of personal data provided by the User without the proper authorizations.

4. Use of Information and Legal Basis

4.1 Howdy processes personal data for specific purposes and only to the extent necessary for such purposes, in accordance with this Privacy Policy. In this regard, the User's personal data may be processed for the following purposes, as applicable:

• Evaluating professional profiles and managing applications.
• Coordinating interviews and internal evaluation processes.
• Contacting the user regarding current or future job opportunities.
• Maintaining and managing a candidate database to consider the User for future job opportunities.
• Sending service-related communications, including notifications, updates, security alerts, and support messages.
• Managing inquiries, requests, and communications with the User.
• Analyzing the use of the platform to improve its functionality, performance, and User experience.
• Conducting aggregated and/or anonymized statistical and behavioral analyses.
• Developing new products, functionalities, and services.
• Sending commercial, promotional, or informational communications about Howdy products or services, only when the User has given prior, express, and informed consent, or there is another valid legal basis under applicable regulations.
• Personalizing content and offers based on the User's interests and behavior.
• Complying with applicable legal obligations.
• Preventing misuse, unauthorized access, fraud, and identity impersonation.
• Responding to requests from competent authorities.
• Ensuring the security of the Site, the Users, and the services offered by Howdy.

5. Disclosure of Information

5.1 Howdy does not sell or rent personal data.

5.2 Information may be shared only in the following cases:

5.2.1 Service Providers

Howdy may share information with external providers that provide technological or operational services, such as CRM platforms, ATS, hosting services, analytics, automation, and communications.

Such providers act as data processors and process data solely in accordance with Howdy's instructions and under contractual obligations of confidentiality and security.

5.2.2 Client Companies

Howdy may share information with client companies only when necessary to evaluate the user's suitability within a selection or hiring process.

5.2.3 Legal Requirements

Howdy may disclose information when required by law, court order, competent authority, or when necessary to protect the rights, security, or integrity of Howdy, its users, or third parties.

5.3 Likewise, Howdy may share information with professional advisors, including legal, accounting, auditing, or other consultants, to the extent necessary for the compliance with legal or contractual obligations, the defense of its rights, or the management of its activities.

6. International Data Transfers

6.1 The personal data collected may be transferred, stored, and processed in the United States or other countries where Howdy or its providers operate, which may have different levels of data protection than those of the User's country of residence. By using the Site and providing their personal data, the User acknowledges and accepts such transfers.

6.2 Howdy adopts reasonable measures to ensure that such transfers are made under adequate standards of security and data protection, including contractual agreements with providers and technical security measures.

6.3 In particular, when applicable, Howdy will implement legally recognized mechanisms for international data transfers, such as contractual clauses or other appropriate safeguards, in accordance with applicable regulations.

7. Data Retention

7.1 Personal data will be retained for the time necessary to fulfill the purposes for which it was collected, in accordance with this Privacy Policy, including the management of ongoing selection processes and consideration of the User for future job opportunities.

7.2 In particular, Howdy may retain information related to applications for a reasonable period after the conclusion of each selection process, in order to consider the User for future opportunities, unless the User requests its deletion.

7.3 Likewise, personal data may be retained for additional periods when necessary to comply with legal, regulatory, accounting, or reporting obligations, as well as to prevent fraud, ensure business continuity, or defend Howdy's rights against potential claims.

7.4 When personal data is no longer necessary for the purposes described, it will be securely deleted or anonymized, in accordance with applicable regulations.

7.5 The User may request the deletion of their personal data at any time, unless there is a legal obligation or legitimate basis justifying its retention. In such cases, Howdy may proceed to block or limit the processing of the data in accordance with applicable regulations.

8. Information Security

8.1 Howdy implements reasonable technical, administrative, and organizational measures to protect personal data against loss, unauthorized access, misuse, alteration, or disclosure. These measures include, among others, internal security policies, information access controls, staff training on data protection, and the use of appropriate protection tools, in accordance with industry standards.

8.2 Likewise, Howdy has procedures in place to manage potential security incidents and, where applicable, will notify users and/or competent authorities in accordance with applicable regulations.

8.3 However, the user acknowledges that no system is completely secure and that, despite reasonable protection efforts, the absolute security of information transmitted over the Internet cannot be guaranteed.

9. Automated Decisions and Profiling

9.1 Howdy may use technological tools to organize, classify, or analyze professional information in order to improve internal selection processes.

9.2 Howdy does not make decisions exclusively based on automated processing that produce significant legal effects on the user without human intervention.

10. Cookies and Analytics

10.1 The Site uses first-party and third-party cookies. Cookies are small text files that are stored on the user's device when browsing a website and allow for the technical operation of the site, as well as the collection of certain information about browsing. In particular, the Site uses cookies to:

• Remember browsing preferences.
• Analyze the use of the Site.
• Improve the user experience and Site performance.

10.2 The use of cookies is subject to the consent granted through the corresponding banner and to the configuration of the user's browser.

10.3 The user may disable cookies from their browser, although this may affect the operation of the Site.

11. User Rights

11.1 The user may exercise the following rights in accordance with applicable regulations:

• Access their personal data.
• Request the rectification, update, or deletion.
• Request portability, where applicable.
• Withdraw consent at any time, when the processing is based on consent.

11.2 To exercise these rights, the user may send a request to info@howdy.com. Howdy may request additional information to verify the identity of the requester before processing the request.

11.3 The exercise of these rights may be subject to certain limitations in accordance with applicable law.

11.4 Requests will be handled within the timeframes and in accordance with the procedures established by applicable regulations.

12. Right to File a Complaint Before a Competent Authority

12.1 If the User considers that the processing of their personal data infringes applicable regulations, the User may file a complaint with the competent data protection authority in their country of residence or in the corresponding jurisdiction.

12.2 In the Eastern Republic of Uruguay, the competent authority on personal data protection matters is the Personal Data Regulatory and Control Unit (Unidad Reguladora y de Control de Datos Personales – URCDP), before which the User may file the complaints and claims as deemed appropriate in accordance with applicable regulations.

13. Children's Privacy

13.1 The Site is not directed to minors under 18 years of age. Howdy does not intentionally collect personal data from minors.

13.2 If it is detected that a minor has provided personal data without authorization, Howdy will proceed to delete such data to the reasonable extent possible.

13.3 Parents, guardians, or legal representatives who consider that a minor has provided personal data to Howdy may request its deletion through the contact channels indicated in this Privacy Policy.

14. Changes to This Privacy Policy

14.1 Howdy may modify this Privacy Policy at any time.

14.2 Modifications will enter into force upon their publication on the Site. We recommend reviewing this section periodically to stay informed about possible updates. Continued use of the Site after the publication of modifications will imply acceptance of such updates.

15. Contact

15.1 For any inquiries related to this Privacy Policy or to exercise rights related to the processing of personal data, the user may contact us via email at: info@howdy.com

16. Jurisdiction and Applicable Law

16.1 This Policy shall be governed and interpreted in accordance with the regulations in force in the Eastern Republic of Uruguay regarding the protection of personal data, including Law No. 18,331, its amendments, regulations, and other applicable supplementary provisions.

16.2 Notwithstanding the foregoing, when mandatory rules for the protection of personal data corresponding to other jurisdictions are applicable, based on the country of residence of the data subject or the place where the processing is carried out, the Company will endeavor to adapt its practices to such provisions to the extent appropriate.

16.3 Any conflict arising from the application, interpretation, validity, and/or execution of this Policy will be submitted to the jurisdiction of the competent courts of the city of Montevideo, Eastern Republic of Uruguay, with express waiver of any other forum or jurisdiction that may apply, except for mandatory legal provision to the contrary.