Last updated October 4, 2022
- through our website: https://www.recruitbot.com/ (the “Website”), from our website visitors (“Website Users”);
- through the RecruitBot’s recruiting platform (the “Product”) and through third party sources such as LinkedIn, from candidates (“Candidates”), where we act as the data controller of such information; that is, as the party that determines what personal data to collect and for what purposes.
TABLE OF CONTENTS
WHAT PERSONAL INFORMATION DO WE COLLECT?
HOW DO WE USE PERSONAL INFORMATION?
WILL PERSONAL INFORMATION BE SHARED WITH ANYONE?
WHO WILL PERSONAL INFORMATION BE SHARED WITH?
HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS?
IS PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
HOW LONG DO WE KEEP PERSONAL INFORMATION?
DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DOES THE COMPANY HAVE ANY SECURITY PRACTICES?
IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
- WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal information disclosed to us
The personal information that we collect depends on the context of your interactions with us. The personal information we collect can include the following:
FROM OUR WEBSITE USERS:
- Application Data: We collect your name, email, LinkedIn URL, phone number and any other information you disclose on our Career page.
- Contact Form-Related Data: We collect your first name, last name, business email, job title, phone number, preferred contact method, company size, message, referral code, and Internet Protocol Address.
FROM OUR BUSINESS CONTACTS:
- Business and Personal Contact Data. We may collect your first and last name, email address, postal address, phone number, professional title, company name, and other similar contact data.
- Payment information. We may collect your payment card or ACH information.
- Transaction information. We may collect information about payments to and from you, and other details of products or services you have purchased from us.
- Marketing information. We may collect information such as your preferences for receiving communications about our activities, events, publications, and details about how you engage with our communications.
- Communications on Third-Party Platforms. If you have opted into the Gmail or Microsoft Outlook APIs as part of the Services, through automated means, in accordance with the third-party platforms’ terms, we may collect sender and recipient information, subject headings and email content.
- Third-Party Platform Data. We provide you with the option to register using third-party platform account details, like your Google, Microsoft or other social media account. If you choose to register in this way, we will collect the personal information described in the section called “HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS” below.
- Candidates Application Data: We may collect other personal information, such as:
- identification data (such as first name, last name, email address);
- education information (such as institutions attended, dates of attendance, and degrees conferred);
- location data (with accuracy up to the city);
- identifiers (such as unique personal identifier, birth date, account name);
- inferences (such as conclusions drawn about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes);
- online identifiers (such as Internet Protocol address and social media profiles); and
- professional or employment information (such as resume, current and past employers, salary, qualifications, language capabilities, employment dates and employment locations);
- hiring status data (mapping Candidates to relevant jobs, and where they are in the process).
FROM ALL (WEBSITE USERS, BUSINESS CONTACTS AND CANDIDATES):
- Account information, profile information and credentials. We may collect your username, passwords, password hints, and similar security information used for authentication and account access.
- Content you choose to upload to the Website/Services/Product. We may collect information such as text, images, resumes, profiles’ information and decisions, along with the metadata associated with the files you upload.
- Feedback or Correspondence. We may collection information such as when you contact us with questions, feedback, or otherwise correspond with us online.
- Usage information. We may collect information about how you use the Website/Services/Product and interact with us, including information you submit to us and information you provide when you use any interactive features of the Website/Services/Product.
Information automatically collected
We, our service providers, and our business partners may automatically collect certain information when you visit, use or navigate the Website/Services/Product. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website/Services/Product and other technical information. Our service providers and business partners may collect this type of information over time and across-third party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons and similar technologies. Our emails may also contain web beacons.
Information collected from others
We may receive personal information (including the information described above) from third-party sources. This may include information from publicly available sources (such as other published content), marketing partners and data providers, as well as information from other business partners.
In particular, we collect publicly available information about the Candidates, that are published on the Internet – this may include sources such as social media platforms or other websites.
If Candidates have opted into an ATS API including services such as Greenhouse, Lever, SmartRecruiters, or JazzHR, we may collect certain Candidate Application Data, such as identification data, professional or employment information and hiring status data.
Information we create or generate derived from the use of Artificial Intelligence
We may rely on machine learning and artificial intelligence (“AI”) to make certain predictions about the Candidates’ profile on behalf of our customers. We may also further process Candidates’ personal information to further enrich our own database, as a controller.
We may infer new information from other data we collect, including using automated means to generate information about Candidate’s preferences or other characteristics (“inferences”). For example, we may infer Candidate’s gender, sexual orientation, ethnic origin, and veteran status.
- HOW DO WE USE PERSONAL INFORMATION?
We may use the information we collect or receive:
FROM OUR WEBSITE USERS:
- To process your job application. If you share your interest in one of our open positions published in the “Career” page of our Website, and seek more information from us.
- To answer information requests. For example, this is the case if you request a Demo on our Website page “Request a Demo”.
- For internal business purposes, such as: (i) to ensure access to and maintenance of our Website, to ensure its proper functioning and to carry out statistical analyses on the use of the Website and the frequency of visits; (ii) to improve our Website and customize your browsing experience; and (iii) to track any fraudulent activities and other inappropriate activities and monitor content integrity on our Website.
FROM OUR BUSINESS CONTACTS:
- To operate the Services. Specifically,
- To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Microsoft accounts), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of our contract with you. See the section below headed “HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS” for further information.
- To provide our Services to our customers, including using search and machine learning to process decisions you have made about Candidates to match other Candidates to specific employment positions for prospective employers.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To respond to your requests, questions, and feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To send emails on your behalf and to review and track your emails for the purposes of tracking recruitment processes if you have authorized access to your Gmail or Microsoft Outlook as part of the Services.
- To provide information about our products and services.
- To understand your needs and interests, and personalize your experience with the Services and our communications.
- To provide support and maintenance for the Services.
- To send you marketing and promotional communications. We and/or our third-party marketing partners may use personal information for our marketing purposes. Our use of your personal information for marketing and promotional communications does not include personal information that we may obtain through any integration that you enable through Gmail or Microsoft Outlook as part of the Services. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
- To display advertisements. We may work with advertising partners to display advertisements on the Services or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising”.
- To conduct analytics activities related to the use of our Product: We re-use the personal information collected while you use the Product, to identify future opportunities for development, and to improve and personalize the Product.
- To share your personal information across customers: We allow the sharing of your personal information across our customers who have not opted-out on a reciprocal basis, in order to increase your chances to find job opportunities.
- To maintain a database of Candidates: We keep a database of Candidates’ profiles enhanced with machine learning and AI.
FROM ALL (WEBSITE USERS, BUSINESS CONTACTS AND CANDIDATES):
- For research and development. We analyze use of the Website/Services/Product to improve the Website/Services/Product and to develop new products and services, including by studying user information.
- To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
- For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Website/Services/Product; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
- To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Website/Services/Product and promote our business.
- WILL PERSONAL INFORMATION BE SHARED WITH ANYONE?
We may process data or share personal information in the following situations:
Third Parties Designated by You. When you use the Website/Services/Product, the personal information we have collected (such as contact details, and employment) will be shared with the third parties that you designate to receive such information.
Vendors, Consultants and Other Third-Party Service Providers (collectively, Service-related third-party vendors). We may share your data with third party vendors, service providers, contractors or agents who perform services on our behalf or help us operate the Website/Services/Product and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts.
Partners. Excluding personal information that we may collect from any integration with Gmail or Microsoft Outlook, we may share your personal information with partners or enable partners to collect information directly via our Website/Services/Product. We may allow selected third parties to use tracking technology on the Website/Services/Product, which will enable them to collect data about how you interact with the Website/Services/Product over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
Third party platforms and social media networks. If you have enabled features or functionality that connect the Website/Services/Product to a third-party platform (such as Gmail and Microsoft Outlook) or social media network (such as by logging in to the Website/Services/Product using your account with the third-party, providing your API key or similar access token for the Website/Services/Product to a third-party, or otherwise linking your account with the Website/Services/Product to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
Business Transfers. We may sell, share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, reorganization, financing, or acquisition of all or a portion of our business to another company or in the event of a bankruptcy or dissolution.
Business Customers. When we collect certain personal information (other than for personal information collected through any third-party platform integration), such personal information may be viewed by our business customers. We do not control how our business customers use your personal information.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
- HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS?
If you choose to register or log in to our services using a third-party platform account, we may have access to certain information about you.
Our Website/Services/Product may offer you the ability to register and login using your third-party platform account details (like your Google or Microsoft logins). If you choose to login to the Website/Services/Product via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Website/Services/Product, we may collect information from that platform or network. Where you choose to do this, we may collect certain information about you from your third-party platform provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, profile picture as well as other information you choose to make public.
- IS PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
We are headquartered in the United States and may have service providers in other countries. If you are accessing our Website/Services/Product from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in the United States and other countries. Laws in these countries, provinces, or states regarding processing of personal information may be less stringent than the laws in your country, province or state. European Economic Area / United Kingdom (“EEA/UK”) users should read the information provided below about transfer of personal information outside of the EEA/UK.
- HOW LONG DO WE KEEP PERSONAL INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we achieve these purposes through other means, and the applicable legal requirements. When we have no require the personal information we have collected, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
- DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from or about children under 18 years of age. If we learn that personal information from individuals less than 18 years of age has been collected without the consent of the child’s parent or guardian, we will delete it as soon as reasonably practicable. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
- WHAT ARE YOUR PRIVACY CHOICES?
Opting out of email marketing. Business Contacts can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us. You will then be removed from the marketing email list – however, we may still send you service-related emails for the administration and use of your account.
Access or update your account information.
FOR BUSINESS CONTACTS: If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. Upon your request to either terminate or deactivate your account, we will proceed as agreed contractually. However, some information may be retained in our systems to prevent fraud, troubleshoot problems, assist with any investigations, be retained for invoicing / bookkeeping, enforce our Terms of Service and/or comply with legal requirements.
Targeted online advertising. Some of the business partners that collect information about Business Contacts’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. Business Contacts may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link).
Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services/Product to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services/Product. We will tell you what information you must provide to receive the Services/Product by designating it as required at the time of collection or through other appropriate means.
Third-party platforms. If you choose to connect to the Website/Services/Product via a third-party platform, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Website/Services/Product using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform, that choice will not apply to information that we have already received from that third-party.
- CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
See our Important Information for California Residents for additional information.
5125 Louise Ave
Encino, CA 91316
The Website/Services/Product may contain links to other websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
- DOES THE COMPANY HAVE ANY SECURITY PRACTICES?
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
The information provided in this section applies only to individuals in the EEA/UK.
Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.
|FROM OUR WEBSITE USERS|
|These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|FROM OUR BUSINESS CONTACTS|
||Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.|
||These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
||These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|FROM ALL (WEBSITE USERS, BUSINESS CONTACTS AND CANDIDATES)|
||Processing is necessary to comply with our legal obligations.|
For performance, functional and advertising cookies, we rely on your consent.
For strictly necessary cookies, we rely on our legitimate interests.
Automated Decision-Making and Profiling. We may use automated decision-making and/or profiling in regard to your personal information for some services and products, for example, we rank candidates that match the filter criteria provided by users. We may process the following categories of sensitive data about you: gender, sexual orientation, ethnic origin Individuals can request a manual review of the accuracy of an automated decision or limit or object to such automated decision-making and/or profiling by contacting us at firstname.lastname@example.org.
European data protection laws give you certain rights regarding your personal information. If you are located within the EEA/UK, you may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to a copy of your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Exercising These Rights. You may submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
- For users in the UK – the contact information for the UK data protection regulator is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Tel. +44 303 123 1113
Cross-Border Data Transfer
We may transfer your personal information outside of the EEA/UK. Some of these recipients are located in countries in respect of which either the European Commission and/or UK Government (as and where applicable) has issued adequacy decisions, in which case, the recipient’s country is recognized as providing an adequate level of data protection under EEA/UK data protection laws (as applicable) and the transfer is therefore permitted under Article 45 of the GDPR.
Some recipients of your personal data may be located in countries outside the EEA and/or the UK for which the European Commission or UK Government (as and where applicable) has not issued adequacy decisions in respect of the level of data protection in such countries (“Restricted Countries”). For example, the United States is a Restricted Country. Where we transfer your personal information to a recipient in a Restricted Country, we will either:
- enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or
- rely on other appropriate means permitted by the EU GDPR/UK GDPR, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal information against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details above.
- Important Information for California Residents
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. Because we don’t knowingly collect the Personal Information of minors under 16 years of age, we do not sell such information.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
How to exercise your rights
You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
- calling us toll free at (888) 481-6811
- emailing firstname.lastname@example.org
- Right to opt-out of the “sale” of your Personal Information. You can request to opt-out of the “sale” of your Personal Information here: Do Not Sell My Personal Information.
We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Categories of Personal Information We Collect, Use, and Share
Statutory category of personal information (PI)
|Source of the PI||Purpose for collection||Categories of third parties to whom we may“disclose” the PI for a business purpose||Categories of third parties to whom we may “sell” the PI|
|Professional or Employment Information||
|Protected Classification Characteristics||
|Statutory category||Definition (categories may overlap)||What we collect|
|Education Information||Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.||
|Identifiers||Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||
|Inferences||The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.||
May be derived from your:
|Online Identifiers||An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.||
|Professional or Employment Information||This term is not defined in the CCPA, but likely includes any information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations).||
|Protected Classification Characteristics||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||