Effective date: May 3, 2021
Information We Collect About You
When you use or access the Websites, or use the Applications as an authorized user of one of our business customers, we may collect personal information directly from you, such as the following:
- Contact information, such as your name, email address, or phone number.
- Business information, such as your job title and the name of your employer or organization.
- Registration and account information, including your username, password, company registration code, and security code.
- Professional and employment-related information and education information, such as your resume, cover letter, employment history, and any other information you provide in your employment inquiries or applications.
- Any other information you submit when you contact us through the Websites or Applications, including any information you provide in a submission through our demo request form or chat functions.
We also may collect certain other information automatically when you visit the Websites, or use the Applications as an authorized user of one of our business customers, such as the following:
Browser and Device Information. Certain information may be automatically collected by most browsers or devices, such as information about user devices (such as IP addresses and MAC addresses), operating systems, and browsers.
Pixel Tags and Log Files. The Websites and Applications may also use other tracking systems such as log files and pixel tags. For example, pixel tags, sometimes called web beacons, are similar in function to a cookie and can tell us certain information like what content has been viewed.
Uses and Purposes for Processing Your Information
As a general matter, we use, disclose, transmit, transfer, store, and otherwise process your information when we have an appropriate legal basis. We may process the information we collect from you for the following purposes.
- For our customers’ and our legitimate interests, consistent with your rights and appropriate to the context, including for:
- Providing, developing, maintaining, personalizing, protecting, and improving the Websites, Applications, and our services offers to you and others, including our business customers.
- Operating, evaluating, debugging, identifying and repairing errors, effectuating similar functional enhancements, and improving our Websites, Applications, or other services.
- Understanding how you and our business customers use our Websites, Applications, and other services, performing analytics, analyzing and reporting on usage and performance of the Websites, Applications, and marketing materials, and determining what features and services may interest you and our business customers.
- Communicating with you and others, including responding to your requests and providing promotional information.
- Offering, marketing, or advertising products, programs, and services from us, our affiliates, business partners, and select third parties to you, including through targeted advertising.
- Recruitment and hiring purposes, including evaluating and processing your employment application.
- Storing information about your preferences, recognizing you when you use the Websites, Applications, and customizing your experience.
- Synchronizing users across devices, affiliates, business partners, business customers, and select third parties.
- Creating aggregate or deidentified data.
- Legal and safety purposes, such as maintaining the safety, security, and integrity of our Websites and Applications, other technology assets, services, and our organization; preserving or enforcing our legal rights and property; protecting our users, our employees, and others; and complying with industry standards.
- Protecting against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
- Evaluating or participating in an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
- Such other purposes as you may authorize.
- To the extent you provide your consent.
- To comply with applicable law and legal obligations.
Disclosure of Your Information
We may disclose personal information we collect about you:
- To our business customers, such as individual requests (discussed below) which they may need to address for you.
- To our affiliates and subsidiaries.
- To our business partners, such as partners involved in joint business transactions.
- To our contractors, service providers, and other third parties we use to support our organization, which may include support of any of the data uses described above.
- To comply with applicable law, other legal requirements, and industry standards.
- To investigate or prevent unlawful activities or misuse of the Websites or Applications.
- To protect against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
- To operate, evaluate, debug, identify and repair errors, effectuate similar functional enhancements, and improve our Websites, Applications, or other services.
- To protect the legal rights, property, safety, and security of us, our users, our employees, and others.
- To an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings.
- To such other parties as you may authorize.
Storage and Retention of Your Information
We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected, including provision of the Websites and Applications and to comply with law, resolve disputes, and enforce our agreements, as applicable. For example, if you register on our Websites or Applications, we will store your information for as long as needed to maintain your account, provide any services you requested, enforce any applicable terms that govern your use of the services, and maintain appropriate records to reflect our delivery of services to you.
Your Rights and Choices
You also may choose not to provide the personal information we request through the Websites and Applications. However, not providing information we request may restrict your ability to use certain features of the Websites and Applications. For example, you may be able to restrict the collection of personal information or functionality through your device’s operating system or by disabling cookies, but doing so may prevent you from using the functionality of the Websites or Applications. Some Internet browsers have a “do-not-track” feature that let you tell the Websites or Applications that you do not want to have your online activities tracked. At this time, the Websites and Applications do not respond to browser “do-not-track” signals. We may allow third parties to use the Websites and Applications to collect personal information about your online activities over time and across different websites, applications, and other online products or services.
You may also manage your preferences regarding our use of certain cookies on the Websites by clicking the “Manage Cookies” link at the bottom of our homepage.
For information about interest-based advertising, and to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative (NAI) opt out tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising (https://youradchoices.com/), or, for users in Europe, the EDAA’s opt-out page (http://youronlinechoices.eu/). Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
The Websites or Applications may include links to other websites, applications, information, and services provided by third parties. We are not responsible for the privacy policies or practices of those third parties. We encourage you to review the applicable privacy policies of such third parties if you elect to follow the links provided.
We operate internationally and your personal information may be transferred outside the jurisdiction you are located. The data protection laws in other jurisdictions may differ from the jurisdiction where you are located and may not provide the same level of protection compared to the laws in the jurisdiction in which you are located.
When we transfer personal information subject to the data protection laws of the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland outside of the EEA, UK, or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules, or another framework deemed adequate by the European Commission.
Additional Information for Individuals Located in the EEA, UK, and Switzerland
If you are located in the EEA, UK, or Switzerland, you may have additional rights to withdraw consent, request access to, correction of, erasure of, or the transfer of your personal information, or object to or restrict the processing of your personal information. You may exercise these rights, if applicable, or contact our Data Protection Officer, by contacting us as described in the “Contacting Us” section of this Policy. Individuals located in the EEA, UK, or Switzerland may also have the right to lodge a complaint with an EEA, UK, or Swiss supervisory authority, as applicable.
Additional Information for Residents of California
This section applies only to residents of the State of California and generally describes how we collect, use, and disclose the personal information of California residents and their households (“California Personal Information”). However, California Personal Information does not include, and this section does not apply to:
- Personal information collected as part of a clinical trial subject to the Federal Policy for the Protection of Human Subjects, also known as the Common Rule, pursuant to good clinical practice guidelines issued by the International Council for Harmonisation or pursuant to human subject protection requirements of the United States Food and Drug Administration.
- Personal information reflecting a communication or a transaction between us and a California resident’s organization that relates to obtaining products or services from us.
- Personal information, emergency contact information, and benefits administration information we collected about a California resident in the course of that California resident acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that California resident’s role as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor.
- Other personal information excluded or excepted from requirements the California Consumer Privacy Act of 2018 (“CCPA”).
Additionally, this section applies only to the extent we direct the purposes and means of California Personal Information processing and otherwise qualify as a “business” under the CCPA. It does not apply to our activities as a “service provider,” as that term is defined under the CCPA, to our business customers or to California Personal Information that we process in that capacity.
- California Personal Information We Collect
We may collect, and may have collected in the preceding 12 months, the following categories of California Personal Information:
- Identifiers, including online identifiers.
- Commercial information.
- Internet and other electronic activity information.
- Inferences drawn from your activity.
- Geolocation data.
- Other categories of personal information described in California law.
- Sources of California Personal Information We Collect
We collect California Personal Information from the sources described in the “Information We Collect About You” section of this Policy.
- Purposes for Which We Use California Personal Information
We may collect and use the categories of California Personal Information described in the “California Personal Information We Collect” section above for one or more of the business and commercial purposes described in the “Uses and Purposes for Processing Your Information” section above.
- Disclosures of California Personal Information for a Business Purpose
In the preceding 12 months, we may have disclosed the categories of California Personal Information listed below to the categories of third parties identified below for a business purpose:
- Identifiers, including online identifiers—with our affiliates and service providers.
- Commercial information—with our affiliates and service providers.
- Internet and other electronic activity information—with our affiliates and service providers.
- Inferences drawn from your activity—with our affiliates and service providers.
- Geolocation data—with our affiliates and service providers.
- Other categories of personal information described in California law—with our affiliates and service providers.
- Sales of California Personal Information
In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age.
- California Personal Information Rights and Choices
The CCPA provides California residents with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights to the extent we direct the purposes and means of the processing of your California Personal Information processing and otherwise qualify as a “business” under the CCPA.
- Access to Specific Information and Data Portability Rights. California residents have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will disclose to you, depending on the scope of the request:
- The categories of California Personal Information we collected about you.
- The categories of sources for the California Personal Information we collected about you.
- Our business or commercial purpose for collecting California Personal Information about you.
- The categories of third parties with which we share your California Personal Information.
- The specific pieces of California Personal Information we collected about you.
- If we disclosed your California Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed California Personal Information for a business purpose identifying the categories of California Personal Information disclosed to those parties in the preceding 12 months.
- Deletion Request Rights. California residents have the right to request that we delete California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the “Exercising Access, Data Portability, and Deletion Rights” section below, we will delete your California Personal Information from our records, unless an exception applies.
- Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1 877 819 6025
- Emailing us at [email protected]
You may designate an authorized agent to submit requests on your behalf through a signed written permission that authorizes the agent to act on your behalf. We may mandate additional requirements when submitted through an authorized agent, such as requiring you to verify your identity directly with us or to directly confirm the authorized agent’s permission to act on your behalf.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. In order to verify your request, we may attempt to verify your identify by asking you to confirm information that we have on file about you or your interactions with us. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
- Non-Discrimination. Subject to certain exceptions, you have the rights to not receive discriminatory treatment for exercising your access, data portability, opt-out, and deletion rights described above.
Changes to this Policy
We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the Effective Date of the Policy, above. We encourage you to periodically review this Policy for the latest information on our privacy practices.
If you have any questions or comments about this Policy or our privacy practices, or you would like to ask for access to or amendment of deletion of your personal information, please contact us by email at [email protected] or by mail at Privacy Office, Calyx, 2 Federal Street, Billerica, MA 01821.