Effective Date of Current Policy: 25 Sept 2019
3. Transparency/Notice – Personal Information We Collect and How We Use It
The types of personal information we may collect and our privacy practices depend on the nature of the relationship you have with Teamable and the requirements of applicable law.
Some of the ways that Teamable may collect personal information include:
- You may provide Personal Information directly to Teamable through signing up for Teamable or interacting with and using the Services (for example, connecting your social networks or adding an email address to your Teamable account).
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies (as described in Section 3.3).
- Teamable may also independently collect, process and store information about you from Third-Party sources (such as through lead-generation forms or tools such as Google Adwords).
We endeavor to collect only that information which is relevant for the purposes of Processing.
Below are the ways we collect personal information and how we use it.
3.1 Types of Personal Information We Collect
Teamable collects personal information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as signing up for Teamable, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Signing up for Teamable. When you sign up to use Teamable, we collect basic contact information from you such as your name, email address and job title. You may also share or export your contacts list as described below in “Information Submitted Via the Services.”
- Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Teamable’s newsletter, request to receive customer or technical support, or otherwise communicate with us.
- Posting on the Services. Teamable may offer publicly accessible web pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in or on Teamable’s web pages, blogs, private messages, and community forums, the Services will collect the information you provide in these submissions, including any Personal Information. If you choose to submit content to any public area of the Services, that content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- Information Submitted Via the Services. Teamable allows you to share your contacts and friends lists from various sources with us. We collect and Process this information to help you and your employer assess whether or not these individuals may be a good candidate for any job openings within the organization. You are solely responsible for ensuring that your collection and the Processing of this information does not violate the legal rights of individuals or other third parties. You may be asked by your employer to follow your employer’s instructions to obtain any and all authorizations and lawful bases for Processing (including consent where necessary) prior to uploading this information to Teamable.
- Information from Other Sources. We may collect and receive information about you from other sources, including through Third-Party websites, services, and organizations. In some cases, Teamable collects and stores this information regardless of whether you sign up for our Services or not. We may use this to supplement information provided by you and for our own independent purposes. For example, we may collect information about you from a Third-Party website, application or service that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to Teamable and to enhance our ability to provide our business, products, and Services.
3.2 How Teamable Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Products, Services, or Information Requested. Teamable may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally, manage an Individual’s information and account;
- Help you and your employer match your contacts to job openings and assist you in contacting these candidates
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functions, and features of Teamable’s Services;
- Contact you to answer requests for customer support or technical support; and
- Allow you to register for events (such as webinars).
- Administrative Purposes. Teamable may use Personal Information about you for its administrative purposes, including to:
- Measure interest in Teamable’s Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on Teamable’s Services and systems, and, in Teamable’s discretion, changes to any Teamable policy;
- Send an email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities; and
- Enforce our Terms.
- Expanding The Use of Teamable Products and Services. Teamable may use Personal Information to provide you with materials about offers for products and Services that may be of interest to you, including new content or Services. Teamable may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers for products, and Services that may be of interest to you;
- To provide Services to you and your employer;
- For other purposes disclosed at the time Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for go-forward marketing to third-parties.
- Research and Development. Teamable may use Personal Information alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Teamable’s products and Services, and may also include information about our partner’s products and Services, as well as upcoming special offers/events we believe may be of interest to you. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
- Anonymous and Aggregated Information Use. Teamable may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Teamable’s Services or other analyses we create. Anonymized and aggregated information are used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Teamable may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Teamable and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Sharing Content with Friends or Colleagues. Teamable’s Services may offer various tools and functionalities. For example, Teamable allows you to send communications to colleagues, contacts, and friends which include information about job openings for which your colleagues, contacts, and friends may be a good candidate.
- Other Uses. Teamable may use Personal Information for which we have a legitimate interest, such as direct marketing, research (including marketing research), network and information security, fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Analytics tools (such as Google Analytics which includes Google Analytics Demographics and Interest Reporting) to collect information regarding visitor behavior and visitor demographics on some of our Services and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of these Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party cookies and web beacons to deliver content on our Site or Third-Party sites that may be of interest to you. This content includes using technologies to understand the usefulness to you of the content that has been delivered to you, such as whether you have clicked on a third-party advertisement.
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites and Social Media Platforms
The Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Teamable does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Teamable’s Services may include publicly accessible blogs, community forums, or private messaging features. The Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.
4. Data Transfers to Third Parties
4.1 Information We Share
- Your Employer. When you sign up for Teamable, you may have done so because your employer instructed us to send you an invite. Your employer will have access to the information that you share with Teamable, including any contacts lists. Your employer may require you to follow a procedure to get permission from your contacts to share their Personal Information. Your employer may use this information to search for qualified candidates to fill job openings. Please check separately with your employer about its privacy practices and information handling standards.
- We Use Vendors and Service Providers. We may share any information we receive, with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site.
- Accountability: With regard to the Principle of Accountability for Onward Transfer, Teamable will remain potentially liable in cases of onward transfer if our Vendor or Service Provider processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
- Business Partners. Teamable may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or Service that you have requested (for example, to integrate smoothly with your Applicant Tracking System (ATS) or any of your internal chat tools). Teamable may also provide Personal Information to business partners with whom we may jointly offer products or Services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Teamable. Teamable requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Teamable provided them.
- Displaying to Other Users. The content you post via the Services may be displayed to others. For example, Teamable may allow you to send an email or message to a colleague, contact or friend. The recipient will be able to see publicly available information associated with you when you communicate with them. We are not responsible for privacy practices of the other users who will view and use this information.
- Disclosures to Protect Us or Others (such as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content, if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Teamable policies or contracts; (v) to collect amounts owed to Teamable; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
4.2 International Transfer of Data; EU-U.S. and Swiss-U.S. Privacy Shield
You agree that all Personal Information submitted to, collected via or by Teamable may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers in order to provide the Services.
4.3 Privacy Shield Notice
Teamable, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Teamable, Inc., has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Teamable is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
In compliance with the Privacy Shield Principles, Teamable commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Teamable at:
Data Protection Officer
Teamable has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States and European Union.
If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
4.4 Redress/Compliance and Accountability
4.5 Binding Arbitration
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with us and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. To find out more about the Privacy Shield’s binding arbitration scheme please see www.privacyshield.gov/article?id=My-Rights-under-Privacy-Shield .
5. Opt-Out (Right to Object to Processing)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Teamable’s Processing of your Personal Information you may withdraw that consent at any time and opt out to further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information on Third-Party websites for non-interest based purposes, such as to determine the effectiveness of the advertisements.
5.2 Email and Telephone Communications
5.3 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
You can choose not to be included in Google Analytics here. You can learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.
6. Rights of Access, Rectification, Erasure, and Restriction
Although Teamable makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Teamable is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question, where the request is manifestly unfounded or excessive, or where it is commercially proprietary. If Teamable determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Teamable will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Services 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 the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. Children’s Privacy
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Teamable does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
10. Other Rights and Important Information
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Teamable will endeavor to comply with the law or contract.
10.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third-Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information, disclosed to those parties. Teamable does not share Personal Information with Third-Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, Teamable or to which Teamable discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Teamable or Teamable’s Agents.
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