Effective date: August 1, 2025
Applies to: All clients registered on the PENNY HIRE LLC platform

PENNY HIRE, LLC (“PENNY HIRE”) facilitates the process by which clients can interview independent contractors prior to hiring. These Interview Policies and Guidelines govern the terms and expectations related to requesting and conducting interviews through the PENNY HIRE LLC platform. Additional terms related to hiring, onboarding, compensation, and long-term collaboration are addressed in the applicable Client Terms and Conditions and Contractor Terms and Conditions.

1. Definitions

A Client is defined as any company, organization, or individual that registers on the PENNY HIRE LLC platform to solicit talent for commercial purposes, including, but not limited to, temporary assignments, project-based work, or ongoing service contracts. Clients are responsible for evaluating and selecting contractors presented by PENNY HIRE and for complying with all platform policies, including payment obligations and fair interview practices.

A Contractor is defined as an independent service provider based in Latin America (LATAM), vetted and onboarded by PENNY HIRE LLC, who makes themselves available to Clients for potential engagement. Contractors are not employees of the Client; they remain formally employed by PENNY HIRE LLC as independent contractors, subject to applicable local laws and platform compliance requirements.

2. Eligibility

Only Clients with a complete and approved company profile can request interviews with Contractors.

PENNY HIRE LLC reserves the right to deny or delay access to interviews due to compliance, verification, or payment issues.

3. Interview Requests

Clients may request interviews with any Contractor profile available on the PENNY HIRE LLC Platform.

Interview scheduling is subject to Contractor availability and PENNY HIRE LLC's coordination capabilities.

PENNY HIRE LLC does not guarantee the availability of specific Contractors.

4. Programming and Execution

PENNY HIRE LLC will coordinate scheduling of interviews and send invitations.

Interviews are conducted virtually via videoconference (Zoom, Meet, Teams, etc.).

Clients must treat contractors with respect and not discriminate on the basis of race, gender, age, national origin, or any other protected class.

Clients should treat contractors with respect and avoid any form of discrimination.

Interviews should not exceed one (1) hour.

No more than three (3) interviews can be conducted with the same contractor.

Additional interviews beyond the three (3) are subject to a charge of $150 USD per session, which will be billed to the client.

5. Interview Policies

5.1 Exchange of information and confidentiality of the interview

Clients and contractors should not exchange direct contact information (e.g., personal emails, phone numbers, or social media accounts) during the interview.

All information shared is confidential and may only be used for evaluation purposes.

Sharing such information without PENNY HIRE's prior written consent is a violation of platform policy.

5.2 False and misleading information

Providing false, inaccurate, or misleading information during the interview process, whether by the Contractor or the Client, may result in disqualification from the platform, cancellation of potential engagements, or legal action.

PENNY HIRE reserves the right to investigate such claims and take appropriate action, including canceling interviews or contracts and denying services.

5.3 Interview recordings and consent

PENNY HIRE may record interviews for quality control, training, or dispute resolution purposes.

By participating, all parties consent to being recorded.

If either party objects, they must notify PENNY HIRE in writing at least 24 hours before the scheduled interview.

Recordings are stored securely and will not be shared externally without express authorization or legal requirement. 6. Selection and Hiring

If the Client selects a Contractor following the interview process, they agree to the terms outlined in PENNY HIRE LLC's Terms and Conditions of Service, including payment of a non-refundable recruitment fee, a minimum three-month commitment, and the commencement of monthly invoicing upon the Contractor's confirmed start date. PENNY HIRE LLC will coordinate all recruitment, onboarding, and compliance matters as the official contractor. Details regarding these obligations, payment structures, and activation procedures are further defined in the Client's Terms and Conditions of Service, and the Contractor's Terms and Conditions are a binding part of the recruitment process.

7. Non-Circumvention Policy

The Client may not, directly or indirectly, solicit, hire, contract, or otherwise engage any Contractor introduced by PENNY HIRE LLC outside of the Platform, without the prior written consent of PENNY HIRE LLC.

This non-circumvention obligation will remain in force for 12 months.

If the Client breaches this clause by hiring a Contractor independently, whether as an employee, freelancer, consultant, or through an agreement with a third party, the Client agrees to pay PENNY HIRE LLC a conversion fee equal to 100 % of the 12-month service commission. This fee reflects the investment PENNY HIRE LLC has made in the search, selection, and presentation of qualified talent.

PENNY HIRE LLC reserves the right to enforce this clause through legal action and to recover all associated legal costs in the event of non-compliance.

8. Limits and abuse of interviews

PENNY HIRE LLC may limit the number of interview requests per Client to ensure the fairness and efficiency of the platform.

Repeated cancellations, no-shows, or misuse of the interview process may result in temporary or permanent suspension of access to Contractor profiles.

9. Confidentiality

All information exchanged or accessed through the PENNY HIRE LLC Platform, including, but not limited to, information shared during the interview process, onboarding, hiring, or ongoing communications, will be treated with strict confidentiality by all parties.

This includes any oral, written, or electronic communication containing business, technical, personal, or financial information, such as resumes, compensation details, performance data, proprietary business methods, software systems, client or contractor records, evaluation results, internal policies, or any other non-public material.

Clients and Contractors agree not to disclose, reproduce, or use such information for any purpose other than that strictly necessary to evaluate, negotiate, or execute a professional engagement facilitated by PENNY HIRE LLC. Sharing this information with third parties, using it for unrelated commercial gain, or disclosing it without the written authorization of the disclosing party is strictly prohibited.

This confidentiality obligation will remain in effect during the interview process and for the duration of the contract, as well as for a period of two (2) years thereafter, unless otherwise required by law or agreed in writing.

Failure to comply with this clause may result in suspension, legal action, and financial liability.

10. Interview recordings and consent

PENNY HIRE may record all interviews for quality control, training, and dispute resolution purposes.

By participating in the interview process, all parties consent to being recorded.

Recordings are strictly confidential and will not be shared without prior written consent, unless required by law.

If a participant objects to the recording, they must notify PENNY HIRE in writing at least 24 hours before the scheduled interview.

11. Modifications

PENNY HIRE LLC may update these Interview Policies and Guidelines from time to time. Your continued use of the interview feature constitutes acceptance of any changes.

12. Limitation of Liability

To the maximum extent permitted by applicable law, PENNY HIRE LLC shall not be liable to Client, Contractor, or any third party for any direct, indirect, incidental, special, consequential, or exemplary damages, including, but not limited to, lost profits, loss of data, or other intangible losses, arising out of or in connection with the interview process, use of the platform, or any interactions facilitated through PENNY HIRE LLC.

This limitation applies regardless of whether such damages are based on contract, tort, negligence, strict liability, or otherwise, even if PENNY HIRE LLC has been advised of the possibility of such damages. PENNY HIRE LLC's total liability in any matter arising out of or related to these Interview Policies and Guidelines shall not exceed the total fees paid by Client to PENNY HIRE LLC during the twelve (12) months prior to the claim.

13. Disclaimer of Warranties

PENNY HIRE LLC makes no warranties, express or implied, regarding the qualifications, reliability, availability, or suitability of any Contractor presented through the platform.
Contractors are independent professionals, and while PENNY HIRE LLC performs the initial selection and coordination, the final decision to hire a Contractor rests solely with the Client. The Client is responsible for evaluating the Contractor's experience, references, and suitability for the specific position or project. The Platform and Services are provided "as is" and "as available," without warranty of any kind.

14. Compensation

The Client agrees to indemnify, defend and hold harmless PENNY HIRE LLC, its officers, directors, employees, agents and affiliates, from and against any claims, liabilities, damages, losses, costs or expenses (including reasonable attorneys' fees and costs) arising out of or in connection with:

The Client's use or misuse of the PENNY HIRE LLC Platform;

The hiring or attempted hiring by the Client of any Contractor;

Any breach of these Interview Policies and Guidelines or applicable law by the Client or its representatives;

Any claim that a contract organized through the platform violates the rights of a third party.

15. Applicable Law and Jurisdiction

These Interview Policies and Guidelines shall be governed by and construed in accordance with the laws of the Commonwealth of Puerto Rico, without prejudice to its conflict of laws principles.

Any dispute, claim, or legal proceeding arising out of or related to these policies shall be filed exclusively in the state or federal courts located in San Juan, Puerto Rico, and the parties hereby consent to the personal jurisdiction and venue of such courts.