Data Protection Notice

Wigiwork processes personal and company information to:

• operate a privacy-first professional discovery and hiring platform;
• find and invite suitable professionals outside Wigiwork for relevant roles or company searches;
• present eligible members' protected Public profiles to external hiring companies and recruiters or agencies advertising roles through the Wigiwork outreach program;
• verify identity, hiring authority, and business legitimacy;
• protect candidate privacy and confidentiality;
• prevent fraud, identity abuse, and unauthorized access;
• comply with applicable laws and sanctions; and
• maintain a secure environment for candidates and employers.

We apply reasonable, risk-based technical, administrative, and organizational safeguards across our data-processing activities.

2.1 Candidate Verification

Accounts require verified email and phone verification. Email is the main account communication channel. Wigiwork may use a verified phone number for verification, security, Access Request alerts, message alerts, account alerts, and other service or system notifications, subject to notification settings where available. Wigiwork does not use phone numbers for marketing.

Account contact information may also be used for profile contact information, subject to candidate-authorized disclosure. Your verified mobile number is pre-filled into your profile contact details and can be removed at any time. Applicable contact requirements and disclosure controls are described in Visibility & Identity Controls.

Candidates may complete a private verification check to receive a Verified Tick. Candidate verification is optional unless Wigiwork specifically requires it for security, fraud prevention, safety, legal compliance, account integrity, platform integrity, or access to a particular feature.

For candidates using anonymous profiles, completing verification does not expose their real identity or change their selected visibility settings.

Wigiwork does not use identity documents for ranking, recommendations, matching, or visibility decisions.

2.2 Employer & Recruiter Verification

Private identity verification is recommended for the Account Owner and may be required by Wigiwork. Where required, the employer workspace is restricted until verification is complete. Recruiters, agency users, client-side users, and other authorized organization users within that workspace do not routinely require a separate private identity check and may access features according to their assigned permissions, as described in Eligibility & Verification.

Wigiwork may require additional or renewed verification of a specific user where reasonably necessary for security, fraud prevention, candidate protection, legal compliance, or platform integrity.

Employers and recruiters may also be required to provide:

• business registration documents;
• proof of hiring authority;
• recruiter authorization documents;
• agency or employer agreements; and
• compliance documentation.

Wigiwork does not guarantee that every inaccurate, misleading, or fraudulent statement about identity, affiliation, or authority will be detected. Users should exercise appropriate care when interacting with employers, recruiters, agencies, or other third parties.

2.3 Third-Party Verification Providers

Wigiwork may use third-party verification providers to conduct individual, company, affiliation, or authority checks.

Depending on the verification flow, information may be collected directly by the provider. Wigiwork receives only the limited verification result and related information required for account administration, security, fraud prevention, compliance, access control, or verification-status purposes.

Where biometric information is used to uniquely identify or authenticate a person, Wigiwork applies the applicable legal basis, additional condition, and safeguards required under applicable law.

Verification providers process information subject to applicable contractual, confidentiality, security, data-protection, and retention requirements.

Where applicable, successful verification may be recorded and displayed through a Verified Tick. The meaning and limitations of the tick are explained in the Verified Tick Notice.

To maintain trust, prevent conflicts of interest, and protect candidate privacy, recruiters and staffing agencies must:

• accurately disclose the employer clients they represent;
• identify the specific hiring client for each job posting, search, or hiring action performed through Wigiwork; and
• provide supporting information or verification when reasonably requested.

Failure to disclose this information may result in restricted access, suspension, termination, or other action permitted under Wigiwork's applicable terms and policies.

4.1 Purpose-Driven Safety Measures

Wigiwork uses automated and manual processes to:

• prevent identity misuse and account manipulation;
• detect suspicious or harmful behavior;
• apply geographic, risk-based, and compliance restrictions;
• protect candidate profiles; and
• enforce NDA-Safe™ confidentiality rules.

These measures support platform integrity and user protection.

4.2 Protection of Safety Measures

Wigiwork limits disclosure of security-sensitive fraud-detection methods and implementation details. This does not limit information, explanations, or review rights required by applicable law.

Users must not attempt to reverse-engineer, probe, bypass, or interfere with Wigiwork's security, safety, privacy, or compliance controls.

4.3 Legal Basis

Where applicable, fraud-prevention and safety processing is based on legitimate interests, legal obligations, contractual necessity, consent, or another legal basis available under applicable law.

5.1 Geographic Restrictions

Wigiwork may restrict access where required or permitted by applicable sanctions, export controls, legal obligations, safety requirements, or compliance rules.

These restrictions may apply where a user is located in, ordinarily resident in, or attempting to access Wigiwork from a prohibited or restricted location.

5.2 Region-Based Verification

Some countries or regions may require additional verification before access to particular candidate or employer functions is permitted.

5.3 Location Information

Wigiwork may use relevant location information where reasonably necessary for compliance, safety, fraud prevention, service availability, or enforcement of geographic restrictions.

Wigiwork applies data-minimisation and privacy-by-design principles, including:

• candidate-controlled visibility options;
• limiting Wigiwork-controlled direct identity and contact fields to candidate-authorized Profile Access, another specific sharing control, or disclosure required by law;
• limiting the use of Wigiwork-controlled direct identity fields for ranking, matching, recommendations, or visibility decisions;
• collecting information reasonably required for platform operation, safety, security, verification, and compliance;
• keeping optional profile fields optional where appropriate; and
• minimizing sensitive information where reasonably possible.

Wigiwork-controlled direct identity and contact fields are shared only when a candidate grants candidate-authorized Profile Access, uses another specific sharing control, or where disclosure is required by law, subject to platform limitations and the residual risks described in the Anonymous Profile Protections.

6A. WigiPic Processing

Uploading a photo to generate a custom WigiPic is optional. We use that photo only to generate your own avatar and retain it only as long as reasonably necessary for that purpose or limited security, legal or technical reasons. We do not use it to identify you, generate other users' avatars, or train, fine-tune or improve AI models.

A photo-based WigiPic may present a greater recognition or re-identification risk than an archive-selected avatar. Uploaded source photos and generated WigiPics are not protected by Wigi-DNA™.

Further processing and retention information is provided in the Privacy Policy and Data Retention & Storage.

6B. Public Discoverability

Public Discoverability is enabled by default and may be disabled after onboarding. When enabled, eligible protected Public profiles may appear in public Wigiwork search, supported external search and discovery services, and the Wigiwork outreach program. Wigiwork-controlled direct identity and contact fields remain hidden. The effects and limits of this setting are described in Visibility & Identity Controls.

Where applicable, Public Discoverability is based on Wigiwork's legitimate interests in supporting protected profile discovery and relevant employment opportunities, subject to candidate controls, safeguards, and applicable privacy rights.

6C. Professional Sourcing and Outreach

Where permitted, Wigiwork uses professional and hiring-contact information from public professional networks and directories, websites, search services, job boards and advertisements, and professional-information providers.

This may include contact details, skills, experience, qualifications, and job information. We use it to identify relevant professionals and opportunities and send outreach invitations. We do not seek sensitive personal information for professional matching or outreach.

The Privacy Policy explains the applicable purposes, legal bases, recipients, and controls.

We retain information only for as long as reasonably necessary for the purposes described in this Notice or to meet applicable legal obligations. Retention periods and the rules for account deletion and outreach records are set out in the Privacy Policy and Data Retention & Storage.

Wigiwork does not sell candidate personal data, anonymous-profile data, Wigi Highlights, identity-protected candidate information, or Company Data as standalone data assets.

Profile Access means candidate-authorized access to additional profile information through an Access Request, Automatic Access, Share Profile, an External Private Share Link, sharing authorized through an outreach invitation, or another candidate-authorized method expressly described in the applicable policy.

A candidate accepting an outreach invitation authorizes company-specific profile sharing under the applicable invitation conditions. No further approval is required for that authorized share. New members' profiles are shared only after onboarding is complete and the conditions are met. Existing members with completed profiles authorize immediate sharing by accepting a valid invitation.

This is different from a company's Connect action, which starts an Access Request and does not itself authorize identity disclosure. Access remains subject to candidate approval, applicable Automatic Access settings or another candidate-authorized sharing arrangement.

Sharing remains limited to its authorized recipient, purpose, access level and duration and is subject to expiry and revocation. Invitation acceptance does not authorize unrelated marketing communications. Detailed conditions are described in the Privacy Policy, Terms of Service and Visibility & Identity Controls.

Where a candidate grants Profile Access to an employer organization through an applicable internal workflow, access may be exercised by authorized users of the relevant employer account for the hiring purpose authorized by the candidate.

Any use or internal handling remains subject to the applicable access level, purpose, confidentiality, expiry, revocation, deletion, and identity-protection requirements.

Employer organizations remain responsible for ensuring that their authorized personnel and systems comply with applicable confidentiality, purpose, expiry, revocation, deletion, and identity-protection requirements.

External Private Share Links remain governed by the candidate's selected link settings and the Visibility & Identity Controls.

Eligible documents and images may include safeguards intended to deter misuse and support investigation of suspected unauthorized use.

Wigi-DNA™ does not apply to WigiPics, avatars, Wigi Highlights, profile outputs, or other unspecified platform content.

Users must not attempt to alter, remove, bypass, reverse-engineer, or interfere with safeguards applied to eligible documents or images.

Wigiwork restricts access to personal and company data to authorized personnel and service providers where reasonably necessary for platform operation, verification, security, fraud prevention, compliance, billing, customer support, incident response, audit, legal obligations, and operational maintenance.

Access is subject to applicable confidentiality, security, and data-protection obligations.

Personal information may be processed outside your country. Where required, Wigiwork uses appropriate safeguards for international transfers.

You may contact privacy@wigiwork.com for information about the transfer safeguards applicable to your personal information and, where applicable, a copy of the relevant safeguards.

Individuals, including people who have not registered, may exercise applicable rights described in the Privacy Policy and Your Privacy Rights notice.

Depending on applicable law, these may include access, correction, deletion, portability, restriction, objection, withdrawal of consent, applicable opt-out rights, and complaints to a privacy regulator.

Requests may be submitted to privacy@wigiwork.com. Registration is not required. Wigiwork responds within the timeframes required by applicable law.

Wigiwork will honour objections to direct marketing, including related profiling. You can stop outreach emails at any time without an account; see the Privacy Policy. Normal account and message notifications remain separate. Minimum suppression information may remain to honour the request.

For other privacy requests, Wigiwork may require proportionate verification of identity or authority where reasonably necessary and permitted by law. Requests may be limited or denied only where permitted by applicable law.

12.1 Automated Processing and AI-Generated Outputs

Where Wigiwork uses automated tools, AI-supported recommendations, Wigi Highlights, Profile Strength, ranking, shortlisting, or other automated or AI-generated outputs, users may exercise applicable rights provided by law.

Professional matching may affect which jobs and profiles are presented. For invitations to a specific job, the completed profile must meet the role requirements before the initial share; later profile updates follow the standard matching and access rules. A company invitation without a linked job does not require a further suitability check after onboarding.

Wigi Highlights are generated from the candidate's complete professional profile and authorised professional documents, including professional information from sections not separately displayed under the selected visibility mode.

Applicable rights may include requesting information, correction, restriction, objection, explanation, contestation, or human review. You may request human review of an inaccurate matching result through support@wigiwork.com or exercise applicable privacy rights through privacy@wigiwork.com.

Wigiwork does not make final hiring decisions. AI-generated outputs may be incomplete, inaccurate, outdated, or misleading and should not be treated as verified facts unless expressly identified as verified by Wigiwork.

For more information, see the AI & Automated Decision Notice.

Wigiwork may restrict, suspend, or terminate access where reasonably necessary to protect confidentiality, platform integrity, user privacy, security, or compliance with applicable laws and policies.

Actions may include:

• restricting or removing access;
• suspending or terminating accounts;
• revoking employer verification;
• preserving information where legally permitted or required; and
• reporting matters to appropriate authorities where required by law.

This Notice may be updated to reflect changes in law, platform features, safety or compliance requirements, or Wigiwork's operations.

Revisions will include a new Last Updated date.

Where required by applicable law, Wigiwork will notify affected individuals of new processing purposes or other material changes before the relevant processing begins.

For data-protection inquiries, privacy questions, rights requests, or legal notices:

Privacy: privacy@wigiwork.com
Legal: legal@wigiwork.com

Wigiwork Inc. PBC
Delaware Public Benefit Corporation
2261 Market Street, Suite 86660
San Francisco, CA 94114-1612
United States
Attn: Data Protection

Contact details for Wigiwork's appointed regulatory representatives, including its EU GDPR Article 27 representative, UK GDPR Article 27 representative, EU AI Act authorised representative, EU Data Act legal representative, and other appointed regulatory representatives, are available on the Regulatory Representatives page.

Wigiwork may operate with distributed personnel, contractors, service providers, or support functions in multiple countries. These locations are operational in nature and are not registered offices unless expressly stated.

Wigiwork applies controls designed to reduce unnecessary identity exposure, subject to candidate-authorized Profile Access, specific sharing controls, legal obligations, platform limitations, and the residual risks described in this Notice, the Privacy Policy, and Anonymous Profile Protections.