Sense Talent Labs, Inc. provides a talent engagement platform and associated analytics services to our clients, typically corporations and staffing agencies. This Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights. For residents of California and other US states that provide additional privacy rights, please click here to access information specific to your jurisdiction.
TABLE OF CONTENTS
1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, VIRGINIA, CONNECTICUT, UTAH, COLORADO, NEVADA, AND OTHER STATES
10. CHILDREN'S INFORMATION
11. OTHER PROVISIONS
12. CONTACT US
1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice applies to personal information processed by Sense Talent Labs, Inc. and its subsidiaries and affiliates (collectively “Sense,” “we,” “us,” or “our”), including on our websites, mobile applications, and other online or offline offerings. To make thisPrivacy Policy easier to read, our websites, mobile applications, and other offerings are collectively referred to here as the “Services.”
An Important Note: To take advantage of our services, our customers (referred to herein as “Clients”) share with us information about individuals who they staff or seek to staff (“Consultants”). We process theConsultants’ information and send communications to those Consultants only at the direction of the Client who provided the information, and only on thatClient’s behalf. This Privacy Notice does not apply to any of the personal information that we process on behalf of our customers through their use of our Services (“Client Data”), which may include but is not limited to:
● Contact information(such as name, street address, telephone number, email address)
● Professional credentials and work history (such as current and past employers, dates of employment, and compensation), and educational history
● Month and Day of birth
● Language preference
● Any information that aConsultant provides in response to a communication from us, such as an invitation to complete a survey
Our Clients’ respective privacy policies govern their collection and use of Client Data. Our processing of Client Data is governed by the contracts that we have in place with our Clients, not thisPrivacy Notice. Any questions or requests relating to Client Data should be directed to the appropriate Client.
This Privacy Notice covers the processing of data Sense does on its own behalf, i.e., as a data controller. To that end, we collect personal information for our own business purposes in connection with our business, such as business contact details of potential Clients orConsultants, and may communicate with Consultants who opt into our mobile messaging systems.
AT A GLANCE:
How We Collect Information
We collect information by various means:
● directly from clients and their consultants
● through automated means when you interact with our Services, such as through cookies
● from third-party vendors, data brokers, or business partners from other recruiters
Information We Collect
The information we collect (from both Clients and Consultants) may include:
● contact and demographic information
● professional credentials, education and work history
● information provided to us when completing a survey or otherwise communicating with us
● Mobile Consent & SMS Data, if Consultants opt in to receiving mobile notifications
How We Use Your Information
We use the information we collect to:
● provide Services to our Clients
● analyze the use of, improve, develop, and promote our products and services
● comply with legal requirements
Information Sharing
We may share the information we collect:
● with our subsidiaries and affiliates
● with our service providers and business partners
● with Consultants as required to provide the Services
● as required by legal requirements
● in connection with an actual or proposed merger, acquisition or another corporate transaction
Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.
2. PERSONAL INFORMATION WE COLLECT The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. Generally speaking, we collect personal information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations For residents of certain states, additional disclosures about the information we collect is available in our supplemental disclosure below. See below for more details regarding each category.
A. Personal Information You Provide to Us DirectlyWe may collect personal information that you provide to us.
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Client Account Creation. We may collectpersonal information from you when you create an account as a Client, such asyour first and last name, company name, work email address, phone number,country, information about the number of employees in your company and theApplicant Tracking System (ATS) you use, and other optional information such asjob title and industry. When you create an account in our system, you will alsobe required to provide a username and password.
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Client Data. In connection with your use of the Services, you may upload the personal information of Consultants, as defined in above. Consultants themselves may also contribute Client Data, such as via their interactions with our Services.
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Mobile Messaging. We provide a service toClients that allows them to communicate with Consultants via text message. Ifyou use this service, we will additionally collect Consultant phone numbers, records of their consent to receive mobile/SMS messages, and both metadata and the contents of the text communications.
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Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
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Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us (for example through interactions with our automated support systems).
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Surveys. We may contact you toparticipate in surveys. If you decide to participate, we may collect personalinformation from you in connection with the survey.
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Sweepstakes or Contests. We may collectpersonal information you provide for any sweepstakes or contests that we offer.In some jurisdictions, we are required to publicly share information (such asl names) of sweepstakes and contest winners.
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Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when weattend or host conferences, trade shows, and other events.
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Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
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Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, resume/CV, cover letter, and/or any other information you provide to us. If you submit your information in connection with job opportunities at Sense, we will use and disclose the information to process your application, to monitor recruitment statistics, and to comply with government reporting requirements.We also retain statistical information about applicants to help inform our recruitment activities.
B. Personal Information Collected Automatically We may collect personal information automatically when you use our Services.
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Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information(including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using ourServices, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
o
Crash Reports. If you provide crash reports for our mobile application, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.
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Cookies and Other Technologies (Cookie Policy). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“
Technologies”) to automatically collect information through your use of our Services.
o
Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
o
Pixel Tags/Web Beacons. A pixel tag(also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
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Operationally Necessary. This includesTechnologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
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Performance-Related. We may useTechnologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
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Functionality-Related. We may useTechnologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into ourServices or keeping track of your specified preferences, interests, or past items viewed;
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Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
See “
Your Privacy Choices and Rights” below to understand your choices regarding these Technologies. ●
Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digitalServices are used and to continually improve and personalize our Services. Some of our analytics partners include:
o
Facebook Connect. For more information regarding how Meta uses your personal information (including for its own purposes, e.g., for advertising), please visit the
Meta Privacy Policy. To learn more about how to opt-out of Facebook’s use of your information, please click the “ad preferences” link in the privacy policy.
o Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit
Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click
here.
o Hubspot. For more information regarding how Hubspot uses your personal information, please visit
HubSpot’s Privacy Policy.
o LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit
LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click
here.
o Microsoft Clarity. For more information about how Microsoft uses your personal information (including for its own purposes, e.g., for advertising), please visit the
Microsoft Privacy Statement. To learn more about how to opt out ofMicrosoft’s use of your information, please click
here.
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Social Media Platforms. Our Services may contain
social media buttons, such as Facebook, LinkedIn, and YouTube, which might include widgets such as the “share this” button or other interactive mini programs. These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
C. Personal Information Collected from OtherSources
Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g.,relative, friend, neighbor, or co-worker).
3. HOW WE USE YOUR PERSONAL INFORMATION We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
Provide Our Services We use your information, as well as your ClientData to fulfill our contract with you and provide you with our Services, such as:
● Managing your information and accounts;
● Providing access to certain areas, functionalities, and features of our Services;
● Answering requests for customer or technical support;
● Communicating with you about your account, activities on our Services, and policy changes;
● Processing your financial information and other payment methods for products or Services purchased;
● Processing applications if you apply for a job we post on our Services; and
● Allowing you to register for events.
B. Administrative Purposes We use your information, as well as your Client Data, for various administrative purposes, such as:
● Pursuing our legitimate interests such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention;
● Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
● Measuring interest and engagement in our Services;
● Short-term, transient use, such as contextual customization of ads;
● Improving, upgrading, or enhancing our Services, including but not limited to training our artificial intelligence models;
● Developing new products and services;
● Ensuring internal quality control and safety;
● Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
● Debugging to identify and repair errors with our Services;
● Auditing relating to interactions, transactions, and other compliance activities;
● Sharing personal information with third parties as needed to provide the Services;
● Enforcing our agreements and policies; and
● Carrying out activities that are required to comply with our legal obligations.
C. Marketing & Advertising our Products and ServicesWe may use your personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
E. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law.
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Automated Decision Making. Although our Clients may use our automated Services to inform their employment decisions, Sense itself does not make decisions that significantly affect you via solely automated means unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth inbelow.
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De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information. For example, we might create aggregate reports detailing the total number of users we have in a given jurisdiction, or other aggregate insights regarding market trends.
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction suchas a merger, sale, or asset transfer, as described below.
A.
Disclosures to Provide our Services The categories of third parties with whom we may share your personal information are described below.
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Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
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Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
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Affiliates. We may share your personal information with our company affiliates and subsidiaries as described above for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
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Consultants. Depending on how you use our Services, we may share your contact information with Consultants inorder to facilitate the recruiting process.
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Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
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APIs/SDKs. We may use third-party application program interfaces (“
APIs”)and software development kits (“
SDKs”)as part of the functionality of our Services. If you have additional questions about our use of third-party APIs/SDKs, please contact us as set forth in “Contact Us” below.
B. Disclosures to Protect Us or Others We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to:comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers If we are involved in an actual or proposed merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred in connection with such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacychoices you may have about your personal information are determined byapplicable law and are described below.
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Email Communications. If you receivean unwanted email from us, you can use the unsubscribe link found at the bottomof the email to opt out of receiving future emails. Note that you will continueto receive transaction-related emails regarding products or Services you haverequested. We may also send you certain non-promotional communicationsregarding us and our Services, and you will not be able to opt out of thosecommunications (e.g., communications regarding our Services or updates to ourTerms or this Privacy Notice).
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Text Messages.
If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in below.
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Push Notifications. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device.
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Phone Calls. If you receive an unwanted phone call from us, you may opt outof receiving future phone calls from us by following the instructions which maybe available on the call or by otherwise contacting us as set forth in “Contact Us” below.
Cookies and Personalized Advertising. You can control our use of certain cookies and Technologies in the following ways:
o Website Cookie Controls. When you first visit our website, you will be presented with a banner that informs you about the categories of cookies and other tracking technologies (“Technologies”) used on that site and your options for controlling those technologies based on the jurisdiction applicable to your use of the website. Where applicable, you will have a choice about whether to accept or opt-out of certain cookies and technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law and may be used for targeted advertising.Please note that cookies are browser and device specific. Your request to opt-out or reject the use of these Technologies will be linked to your browser identifier only. If you use a different computer, mobile device, or Internet browser to access our sites, you will need to renew your cookie management choices.
o Browser and Device Controls. You may also stop or restrict the placement ofTechnologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, ourServices may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for
Android,
iOS, and
others.
o Ad Industry Opt-outs. In addition, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy by visiting the
Network Advertising Initiative, the
Digital Advertising Alliance, the
European Digital Advertising Alliance, and the
Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
“Do Not Track” / “GlobalPrivacy Control.” Do Not Track (“
DNT”) is a privacy preference that users can set in certain web browsers. Additionally, some browsers or plug-ins use a “Global PrivacyControl” (“
GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as either a Do Not Sell request or a request to limit the sale or sharing of personal information for targeted advertising depending on the law applicable to your jurisdiction. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your opt-out request.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
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Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing yourpersonal information; (ii) obtaining access to or a copy of your personalinformation; and (iii) receiving an electronic copy of personal informationthat you have provided to us, or asking us to send that information to anothercompany in a structured, commonly used, and machine readable format (also knownas the “right of data portability”);
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Request Correction of your personalinformation where it is inaccurate or incomplete. In some cases, we may provideself-service tools that enable you to update your personal information;
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Request Deletion of your personal information;
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Request Restriction of or Object to our
processing of your personal information where the processing of your personal information: (i) is based on our legitimate interest for direct marketing purposes; (ii) involves processing or sharing of your sensitive personal information for certain non-essential purposes, or in contexts that require your consent; and (iii) for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
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Opt-out of Sale, Sharing for Cross-Contextual Advertising, or Targeted Advertising involving your personal information. Although we do not “sell” your personal information as the term “sale” is typically understood, we may share your information with analytics providers and advertising networks in order to understand how visitors use our websites and serve you ads on and off our websites. You may opt-out of this“sharing” and “targeting advertising” by adjusting your privacy choices as described in section 5.
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Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal. If you would like to exercise any of these rights, please contact us as set forth in ”
below. We will process such requests in accordance with applicable laws.
6. SECURITY OF YOUR INFORMATION We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100%secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information. By using ourServices or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
7. INTERNATIONAL DATA TRANSFERS All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the
EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
8. RETENTION OF PERSONAL INFORMATION We store the personal information we collect as described in this Privacy Notice for as long as you use ourServices, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limitedto, the sensitivity and volume of such data. Additionally, we endeavor to retain all such personal information in accordance with legal requirements.
9. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, VIRGINIA, CONNECTICUT, UTAH, COLORADO, AND NEVADA, AND OTHER US STATESThis Notice at Collection and Supplemental Notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time covering personal information collected in a business or employment context, including, but not limited to, California(collectively, “
Applicable State Laws”).
A. PERSONAL INFORMATION WE COLLECT AND SHAREAs more fully described in the section titled the sources from which we collect personal information include directly from you when you interact with us, automatically from you when you use our sites and Services (for example through cookies and other online technologies), from third parties (for example, from third-party referrals).
Depending on how you use our Services, the information we may have collected within the last twelve (12) months about you, as well as the categories of third parties with whom we have shared this information, are described in the table below.
Category of Personal Information Collected by Sense
Category of Third Parties Personal Information is Disclosed to for a Business Purpose
Category of Third Parties to Whom PersonalInformation is Sold And/or Shared
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number (Consultants only), or other similar identifiers.
● Service providers
● Other users or third parties you share or interact with
● Advertising partners (online identifiers only)
● Data analytics providers (online identifiers only)
● Data Analytics providers (online identifiers only)
● Advertising partners (online identifiers only)
Personal information categories listed in the California Client Records statute (Cal.Civ. Code § 1798.80(e))
A name, Social Security number (Consultants only), physical characteristics or description (Consultants only for demographic purposes), address, telephone number, education, employment, employment history, and financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
● Service providers
● Other users or third parties you share or interact with
● Advertising partners
● Data analytics providers
n/a
Protected classification characteristics under California or federal law
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). (Consultants only)
● Service providers
● Other users or third parties you share or interact with
n/a
Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
● Service providers
● Advertising partners
● Data analytics providers
● Advertising partners
● Data analytics providers
Internet or other electronic network activity
Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
● Service providers
● Advertising partners
● Data analytics providers
● Advertising partners
● Data analytics providers
Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
● Service providers
● Other users or third parties you share or interact with
n/a
Professional or employment-related information
Current or past job history or performance evaluations. (Consultants only)
● Service providers
● Other users or third parties you share or interact with
● Advertising partners
● Data analytics providers
n/a
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C.Sec. 1232g, 34 C.F.R. Part 99))
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. (Consultants only)
● Service providers
● Other users or third parties you share or interact with
● Advertising partners
● Data analytics providers
n/a
Inferences drawn from other personal information to create a profile about a consumer
Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
● Service providers
● Advertising partners
● Data analytics providers
● Advertising partners
● Data analytics providers
B. USE OF PERSONAL INFORMATION
We may use or disclose the Personal Information we collect for the purposes outlined in above. These purposes include:
● To provide our Services to you;
● For our Administrative purposes (including security, fraud detection and protection, and improve our Services);
● To process your requests, orders, and transactions (including provide customer service to you);
● To Advertise and Market our products and Services to you;
● With your consent; and,
● To comply with law and enforce our rights and the rights of others.
Where required under applicable law, we will not collect additional categories of Personal Information or use the Personal Information we have collected for materially different, unrelated, or incompatible purposes without first providing you notice.
C. SALES/SHARING OF PERSONAL INFORMATIONSense does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age as the term “sell” is commonly understood. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for cross-context behavioral advertising and targeted advertising. You may limit such sharing by following the instructions found above in the section titled, Your Privacy Choices andRights > Your Privacy Choices > Cookies and Personalized Advertising found in section 5, or by contacting us as set forth in “Contact Us” below.
D. YOUR RIGHTS AND CHOICES
Subject to applicable law, if you are a resident ofCalifornia, Virginia, Connecticut, Utah, or Colorado, you may have the following rights:
● To Know and Access: to obtain a copy of the specific pieces of Personal Information we have collected about you. (Note that this right only applies to Personal Information relating to you, and not to any other user.)
● Deletion: to request that we delete your Personal Information. This right may be limited to the extent that we are permitted or required by applicable law to retain certain information. (Note that if you request deletion of your PersonalInformation, you may no longer be able to use or access the Services. If you decide to use or access the Services again, we may consider this a new account, and may collect Personal Information associated with that account in accordance with this Privacy Policy.)
● Opt-Out of “Sale” and Certain Sharing Practices: you have the right to opt-out of certain information sharing practices with third parties who do not act as our service providers. In some states, like California, this information sharing may qualify as a “share” or a “sale,” while in other states, like Virginia, this information sharing may qualify as “targeted advertising” (collectively,“personalized advertising”). If you wish to opt-out of personalized advertising, you can opt out of said sharing by contacting us as set forth below.
● Correction: to request the correction of inaccurate Personal Information that we may have on file about you.
● Obtain additional details regarding our information practices: You may have the right to request disclosures regarding our information practices. (Note that this information is generally available in this Privacy Policy).
We will not discriminate against you, in terms of price or services that we offer, if you exercise any of the rights listed above.
Verification and Appeal Process: We are required by law to take reasonable steps to verify your identity prior to responding to your request. Please note that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests(e.g., the maintenance of legal privilege). If we are unable to process your request via you authenticating yourself on the Services, we may verify your request by asking for information sufficient to confirm your identity, based on the information we have on file. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.
If you are a resident of Colorado, Virginia, or Connecticut, you have the right to appeal a request we deny when we have verified your identity and still decline to honor your request. The process for that appeal will be sent to you separately if your request is denied.
Authorized Agent: Depending on where you live, you may have the right to use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a user to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the user, and have sufficient access to that user’s laptop, desktop, or mobile device to exercise that user’s right digitally. If you are an authorized agent trying to exercise rights on behalf of one of our users, then you can make a request on the user’s behalf by contacting us as set forth below in the “Contact Us” section: Such requests must include the following information: (1) a written authorization from the consumer that includes the consumer’s full name, address, telephone number and valid email address used by the consumer to interact with us, that is signed by the consumer and clearly bestows upon the agent the proper authority; and (2) a certificate of good standing with your state of organization. Alternatively, an acting agent can provide a valid power of attorney signed by the consumer on the agent’s behalf and a valid email address used by the consumer to interact with us. The email address of the consumer will be used to separately verify the agent’s authority with the consumer.
Refer-a-Friend, Promotions, and Similar Incentive Programs: We may offer referral programs, promotions such as sweepstakes, or other incentivized information collection programs. We may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide PersonalInformation regarding your friends or colleagues (such as their email address)and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) Alternatively, we may ask you to provide your Personal Information in exchange for a reward or participation in a promotion. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your information to us depends on how you ultimately use our Services, whereas the value of the referred party’s information to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program. You may withdraw from the incentives at any time. In order to withdraw from the financial incentive, please "Contact Us" described below.
Shine the Light Disclosure: California residents are entitled to ask us for a notice that identifies the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and provides contact information for such affiliates and/or third parties. If you are a California resident and would like this information, please submit a written request to us using the contact information below.
De-IdentifiedInformation. If we create or receive de-identified information, we will not attempt to re identify such information, except to comply with applicable law.
E. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@sensehq.comwith the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in NevadaRevised Statutes Chapter 603A. If you have any questions, please contact us asset forth in below.
10. CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.If you are a parent or guardian and
believe your child has uploaded personal information to our site without your consent, you may contact us as described in “” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.
11. OTHER PROVISIONS
Third-Party Websites/Applications. TheServices may contain links to other websites/applications and otherwebsites/applications may reference or link to our Services. These third-partyservices are not controlled by us. We encourage our users to read the privacypolicies of each website and application with which they interact. We do notendorse, screen, or approve, and are not responsible for, the privacy practicesor content of such other websites or applications. Providing personalinformation to third-party websites or applications is at your own risk.
Supervisory Authority.
If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.
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EEA Data Protection Authorities (DPAs)●
Swiss Federal Data Protection and Information Commissioner (FDPIC)●
UK Information Commissioner’s Office (ICO)
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Spanish Data Protection Agency (AEPD) 12. CONTACT US Sense is the controller of the personal information we process under this Privacy Notice.
If you have any questions about our privacypractices or this Privacy Notice, or to exercise your rights as detailed inthis Privacy Notice, please contact us at: