Privacy Policy

STARTDATE LABS, INC. PRIVACY POLICY

Last updated: February 2020

This privacy policy (“Policy”) explains how personal information is collected, used, and disclosed by StartDate Labs, Inc. dbaStartWire(“StartWire,” “we,” or “us”) in connection with your use of the website published on www.startwire.com (the “Site”) so you can make an informed decision about using the Site. We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was last updated. We encourage you to review this Policy from time to time to make sure that you understand how certain types of information you provide will be used.

What Type of Information Do We Collect?

Personal Information. Personal information means information that specifically identifies an individual (such as a name, full mailing address, telephone number, mobile number, e-mail address, or credit card number). Personal information does not include “aggregate” or anonymized information, e.g., data we collect about the use of the Site or about a group or category of services or users, from which personal information that specifically identifies you has been removed. This Policy in no way restricts or limits our collection, use or disclosure of aggregate or anonymized information.

Demographic Information. Demographic information is information that is not unique to you in the sense that it refers to selected population characteristics, such as your ZIP code or postal code, age, preferences, gender, race or ethnicity, occupation, career history, interests and favorites. We may use and disclose demographic information for any purpose.

Behavioral Information. We also collect behavioral information regarding how you use the Site, the areas of the Site you visit, what services you access, and information about your computer hardware and software, including your IP address, geolocation, browser and operating system type, domain names, access times and referring website addresses. This information is necessary for analyzing the use of resources, troubleshooting problems, preventing fraud, improving our services and other lawful purpose. We may use and disclose behavioral information for any purpose.

Third Party Log-in Credentials. In order to use certain services on our Site, we may request your login credentials to third party websites. For example, if you request us to track your job application on a potential employer’s human resource website, we may need your log-in credentials (e.g., login and password) to do so. By submitting your log-in credentials to us, you give us a right to use such login credentials on your behalf to access the third party website and the information derived from such access. We may collect information through our use of the log-in credential (e.g., status of job application) and we will handle such information in accordance with this Policy.

How Do We Collect Information?

Active Collection: We collect certain information you voluntarily provide to us, such as when you sign up to use a service offered on the Site. Such information may include personal information, such as your name and email address. Personal and demographic information may also be collected if you provide such information in connection with any comments you post on or through the Site or participate in any other interactive forums or features on the Site. In addition, from time to time we may collect demographic, contact or other personal information you provide in connection with your participation in surveys, promotional offers, and other activities on the Site.

Passive Collection: When you use the Site, some information is also automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring website, and your activity on the Site. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate only.

Cookies: We may also automatically collect certain information through the use of “cookies,” web beacons or similar mechanisms. Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us improve our Site and your experience. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect certain features or services on our Site. Web beacons are small, invisible graphic images that may be used on the Site or in emails relating to the Site to collect certain information and monitor user activity on the Site.

Disclosure Regarding Third Party Cookies. From time to time we may allow third parties to collect information when you visit the Site. These third parties may utilize cookies, web beacons or other similar mechanisms to collect non-personal information, and such information may be used, among other things, to analyze data, to determine the popularity of certain content, and to better understand the usage and visitation of our Site and the other sites tracked by these third parties. In some instances, the information collected through the use of these technologies may be used to deliver advertising targeted to your interests. Our Service Providers and third-party sites use this information to recognize you across different channels and platforms over time for advertising, analytics, attribution, and reporting purposes. To learn more about the behavioral advertising practices or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info or Networking Advertising Initiative at www.networkadvertising.org/choices. This Policy does not apply to the collection and use practices of the third parties utilizing these technologies.

How Do We Use the Personal Information We Collect?

We use personal information collected through our Site for the purposes described in this Policy or elsewhere on the Site. For example, we may use personal information we collect:

(a) to provide the services, products, or information you request, and to process and complete any transactions in connection therewith;

(b) to request feedback and to otherwise contact you about your use of the Site;

(c) to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;

(d) to monitor and analyze site usage and trends, and to personalize and improve the Site and our users’ experiences on the Site, such as providing ads, content, or features that match their profiles or interests, and to increase the Site’s functionality and user friendliness;

(e) to provide you with news and information about our or third party events, activities, offers, promotions, products, and services we think will be of interest to you;

(f) to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Site;

(g) to notify you about important changes to our Site; and

(h) for any other purpose authorized or requested by you.

What Personal Information Do We Share With Third Parties?

We will not share the personal information we collect from you through this Site with third parties, except as described in this Policy or on the Site. We may share personal information as follows:

(a) with vendors, consultants, and other service providers, such as payment processors (“Service Providers”) who are engaged by or working with us in connection with the operation of the Site or the services we provide and who need access to such information to carry out their work for us;

(b) when you give us your consent to do so, such as if you opt in to receive marketing communications from third parties or if we otherwise notify you on the Site that the information you provide will be shared in a particular manner and you provide such information;

(c) when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to: (a) comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants, or court orders; or (b) protect the rights, property, or safety of StartWire, our users, our employees, copyright owners, third parties or the public, including without limitation to protect StartWire or our users from fraudulent, abusive, inappropriate, or unlawful use of our Site;

(d) to enforce or apply this Policy, our Terms and Conditions, or our other policies or agreements; and

(e) in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, as well as in the event of bankruptcy, insolvency, receivership or in any other situation where personal information may be disclosed or transferred as one of the business assets of StartWire.

The Site includes features which enable you to post content or otherwise share information about yourself and your posting or resume. You understand that if you use such features or otherwise post any content through the Site, the information you post will be available to other users and other websites, and in some cases may be publicly available. We recommend you be cautious about giving out personal information to others or sharing personal information through the Site.

We are not responsible for the actions of Service Providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties, and we encourage you to become familiar with their privacy practices before disclosing information directly to any such parties.

How Will You Handle My Resume?

If you submit your resume to the Site, then all parties with access to our searchable resume database (or copies thereof) will have access to your resume. Employers or other parties with access to our searchable resume database may be located in countries whose data protection legislation may not be equivalent to the laws in your country. For example, your resume may be viewed and accessed by employers outside the European Economic Area who have access to our searchable database. By making your resume searchable, you are expressly consenting to such transfers of data.

We attempt to limit access to our searchable resume database to legitimate users such as bona fide employers, recruiters, hiring managers, headhunters and human resource professionals, as well as law enforcement and national security agencies, but we cannot guarantee that other parties will not gain access to this database. We cannot control the use made of resumes by third parties who access such resumes while they are in our searchable database. Even if we offer functionality that allows you to remove your resume, employers, recruiters and others who have paid for access to that database, as well as parties who have otherwise gained access to the database may have retained a copy of your resume in their own files or databases. We cannot control the retention, use or privacy of resumes or profiles that have been downloaded by third parties. Accordingly, you should not put sensitive information, personality profiles, or other information you would not want made public, in your resume.

We will use personal information within your resume in accordance with this Policy, however, we may use demographic, aggregate and behavioral information for any purpose.

Links to Other Websites

Our Site may contain links to websites operated by third parties. Any personal information you provide on or through the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. This Policy does not apply to such linked websites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other websites operated by third parties that are linked to from the Site. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.

What Steps Do We Take To Protect Your Information Online?

We take reasonable measures to protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission that can be guaranteed against any interception or other type of misuse. To protect the confidentiality of your personal information, you should keep your password confidential and not disclose it to any other person. You are solely responsible for all use of the Site and our services by any person using your password.

What Choices Do You Have Regarding the Use of Your Information?

You may “opt out” of receiving marketing or promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

California Privacy Policy

Consumer Rights

Under the CCPA, you are entitled to the consumer rights described in this section. For information on how to contact us to exercise these rights, please see the section below entitled “How to Submit a Request.”

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, or sell about you. Specifically, for information we collect about you, you may request that we disclose the following to you:

  • The categories of personal information we have collected about you.
  • The categories of sources from which we collected the personal information.
  • The business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom we share personal information.
  • The specific pieces of personal information we have collected about you.

In addition, for information that we sell or disclose about you for a business person, you may request that we disclose the following to you:

  • The categories of personal information that we have collected about you.
  • The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold.
  • The categories of personal information that the we disclose about you for a business purpose.
Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain the personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale of Personal Information

You have the right to direct us not to sell your personal information. To opt-out of the sale of your personal information by us, you may go to our “Do Not Sell My Info” page.

Right to No Discrimination

You have the right not to be discriminated against because you exercised any of your rights under the CCPA. We may charge you a different price or rate, or provide a different level or quality of goods or services to you if that difference is reasonably related to the value provided to you by your data.

At this time, we do not charge a different price or rate or provide a different level or quality of goods or services if you exercise any of your rights under the CCPA.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable request to us by contacting us here and providing the requested information or emailing us at ccpa@startdatelabs.com. You may also call 800-572-9470 to submit a request.

To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. We may also require you to provide a written declaration that you are who you say you are.

If you maintain an online account with us, we will verify your identity for a request through the normal account authentication process, meaning you will need to sign on with your email and password.

We are only required to respond to requests to provide personal information to you twice in any 12-month period.

If we cannot verify your identity, we will not be able to comply with your request. We will inform you if we cannot verify your identity. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

Collection, Use, and Sharing of Information

We may have collected the following categories of personal information about you in the twelve (12) months prior to the Effective Date of this policy:

  • Name, email address, zip code, postal address, phone number (including mobile phone), Internet Protocol address, or other similar identifiers.
  • Education, employment history, and other professional or employment-related information.
  • Characteristics of protected classifications under California or federal law (including race and gender) and citizenship status.
  • Geolocation data.
  • Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our Site.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Site, including job postings, advertisements, and other content on our Site.
  • Inferences drawn from any personal information to create a profile about you reflecting your preferences, behavior, attitudes, abilities, and aptitudes.

The actual information we may have collected about you can vary based on your interaction with our Site.

We collect the personal information described above from the following categories of sources:

  • Directly from you when you complete forms on our Site and update your account information.
  • From you when you interact with job postings, advertisements, and other content on our Site.
  • From our business partners who may pass your personal information to us with your consent.

We collect the personal information described above for a variety of business purposes. For example, we may use the personal information to:

  • Achieve the operational purpose for which the personal information was collected or for another operational purpose that is compatible with the context in which the personal information was collected.
  • Tailor your user experience, including, but not limited to, the contextual customization of relevant employment-related information, such as job search results, as well as advertisements and offers.
  • Audit a current interaction with you and concurrent transactions, including, but not limited to, presenting relevant employment-related results, offers, and other information, and auditing compliance with this specification and other standards.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
  • Identify and repair errors that impair existing intended functionality.
  • Perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
  • Undertake internal research for technological development and demonstration.

We may share the personal information described above with the following categories of third parties:

  • To our business partners when you opt-in to their offers on our Site or through our Services.
  • To companies and individuals we engage to perform services on our behalf.
  • To companies that may use your data for career-related purposes and other content that may be relevant to you.
  • If legally required to do so.
  • To protect our rights or property or the rights of our affiliated companies.
  • To protect the personal safety of users or the general public.

We have sold or disclosed for a business purpose the following categories of personal information about Consumers in the twelve (12) months prior to the Effective Date of this policy:

  • Name, email address, zip code, postal address, phone number (including mobile phone), Internet Protocol address, or other similar identifiers.
  • Education, employment history, and other professional or employment-related information.
  • Characteristics of protected classifications under California or federal law (including race and gender) and citizenship status.
  • Geolocation data.
  • Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our Site.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Site, including job postings, advertisements, and other content on our Site.
  • Inferences drawn from any personal information to create a profile about you reflecting your preferences, behavior, attitudes, abilities, and aptitudes.

We may have sold or disclosed the personal information for the categories of business purposes described above to the categories of third parties described above in this policy.

The actual information about you we may have sold or disclosed for a business person can vary based on your interaction with our Site.

We require in our Terms of Service that you be of sufficient legal age to use our Site. Accordingly, we do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization.

Contact for More Information

If you have any questions or concerns about our California Privacy Policy, please contact us at ccpa@startdatelabs.com or 800-572-9470.

Children Under Age 13

The Site is not intended for children under age 13. No one under age 13 may provide any information to or on the Site. We do not knowingly collect personal information from children under age 13; nor do we allow such persons to use the Site or our services. If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 13, please contact us at privacy@startdatelabs.com.

Questions?

If you have any questions about this Policy, please contact us at privacy@startdatelabs.com.

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