Privacy Policy
Last updated: March 26, 2020
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE.
INTRODUCTION
Gun.io (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. You may obtain an accessible version of this Policy by contacting us via the “Contact Us” details at the end of this Policy.
What processing activities are covered?
This Policy provides you with a description of our online and offline practices regarding your personal information when we are acting as a data controller and the rights you have regarding your personal information. Our online processing activities occur when you interact with us via the online platform available at app.gun.io (the “Developer Portal”) and our public website gun.io (the “Website”). The Platform and the Website are referred to together in this Policy as the “Site.” We may also collect information from you offline when you attend one of our events, for instance at a business conferences and/or a trade show, or communicate with us via telephone.
Gun.io is used by professional freelancers (“Freelancers”) who wish to offer their development, engineering and other services (“Services”) and clients who need the Services (“Clients”). Freelancers that have passed our screening process and are admitted to our community of professional Freelancers (“Community”) are referred to as “Talent.” For purposes of this Policy the term “Freelancers” is broader in scope and includes both Talent and Freelancers who are not yet Talent.
Who is responsible for your personal information?
If you are a user in the European Union (the “EU”) or European Economic Area (“EEA”), for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), Gun.io acts as a data controller with respect to the personal information described in this Policy. In this role, Gun.io is responsible for implementing the applicable data protection principles and for safeguarding personal information.
HOW DO WE PROCESS PERSONAL INFORMATION?
Personal Information We Collect
As a data controller, we collect and process the following personal information from you for the purposes set forth below and for the purposes listed in the “Other Processing Activities” section of this Policy. Please do not provide another person’s personal information to us.
Freelancer Account Information
In order to become a Freelancer or to access and use the Developer Portal, you must first complete a registration. When you create an account and complete your profile, we collect your email address, password, name, skills, physical address, time zone, work/employment history, years of experience, telephone
number, referral source, typical rate and availability, general work hours, photo, resume, work sample, professional profile links (e.g. LinkedIn, GitHub, Bitbucket), an audio cover letter, and any additional information you choose to provide. You will also complete a coding test via the Developer Portal to demonstrate your professional skills.
We may supplement the information that we collect from you as a Freelancer with additional information from publicly available and third-party databases or services that provide information about business people (including an individual’s name, job title, business contact information, and company information).
To the extent permitted by applicable law, we also collect background check and identity verification information for Freelancers. Our provider of background check services may collect additional data about you (including information about criminal convictions or offences) if/when we undertake background checks. If applicable to you, your consent to the collection of such additional data will be solicited at such time, pursuant to applicable laws.
Once you are admitted to the Community, are matched with a Client, and begin work, we may receive from our Clients regarding the performance of your services to that Client, as necessary for maintaining standards of integrity and excellence in our Community.
We process Freelancer Account Information to operate the Site, to provide our services, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, to keep records of our communications with you, to send you our notifications and newsletters, to promote your services, to promote our services, and to process your request to become a Freelancer and administer our contract with you once you become a member of the Community. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our Client relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Cookies and Similar Technologies
When you visit the Site, we collect cookies and use similar technologies as described in the “Personal Information Collected Via Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.
We use Cookies and Similar Technologies to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and to improve our marketing efforts. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business.
Usage Information
When you visit the Site, we automatically collect information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address or unique device identifier, domain server, browser type, access time, and data about which pages you visit.
We process Usage Information to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and to improve our marketing efforts. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
Your Communications and Feedback
When you communicate with us or provide feedback, we will receive and retain your communications and the information included in those messages. We use a chatbot to facilitate certain communications on the Site. If you receive email communications from us, we use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts.
We process Your Communications and Feedback in order to communicate with you, to keep records of our communications with you, to enhance your experience, and to send you our notifications and newsletters. The legal basis for this processing is our legitimate interests in the proper administration of our Site and business and communications with our users.
Client Data
When we receive a request for hiring our Freelancers or if you complete a Client form on the Site, we collect the name and contact information of the prospective Client’s representative(s) and any information relating to the Client’s needs. We may supplement the information with additional information about you and your company obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information).
We process Client Data to operate the Site, to provide our services, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, to keep records of our communications with you, to send you our notifications and newsletters, to promote your services, to promote our services, and to process your request to become a Freelancer and administer our contract with you once you become a member of the Community. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our Freelancer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Financial and Payment Information
If you are a Client or a Freelancer, you will be asked to provide your bank account number, bank routing information, and other data necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information. This information is passed directly to our payment processors and is not accessed by us. By submitting your payment card information, you expressly consent to the sharing of your information with third-party payment processors and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties). Please note that credit card numbers and account information are not stored on our servers.
We process Financial and Payment Information in order to operate our business; honor our Terms of Use and contracts; to provide our services; to manage and perform our relationship with you; to process payments; and to comply with your instructions or requests. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Job Applicant Information
We collect your name, address, telephone number, email address, resume, cover letter, and information about your professional experience. It is for you to decide what you include in your resume and cover letter. You may choose to disclose salary history or salary expectations.
We may also collect copies of relevant identification documents from you (such as your passport or driving license, proof of address, a copy of your work permit (where applicable), a photograph and a copy of your signature).
To the extent permitted by applicable law, we also collect background check and identity verification information for job applicants. Our provider of background check services may collect additional data about you (including information about criminal convictions or offences) if/when we undertake background checks. If applicable to you, your consent to the collection of such additional data will be solicited at such time, pursuant to applicable laws.
We process Job Applicant Information in order to operate our business; to verify your eligibility and suitability for employment or other relationships with us; to comply with immigration requirements; to verify your identity; and to comply with your instructions or requests. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, facilitating the interview process and communicating offers of employment to you, making informed recruitment decisions and selecting suitable candidates for roles with us, improving our recruiting and hiring processes, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
CCPA Notice at Collection
For purposes of the California Consumer Privacy Act (“CCPA”), in collecting the information described above, we collect the categories of personal information listed below. Please also see the “California Rights” section of this Policy for additional information. If your information is collected in the context of a business relationship with us, it may not be covered by the CCPA.
Identifiers
When collecting Freelancer Account Information, we will receive your email address, name, telephone number, resume, physical address, and any additional information you choose to provide.
When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier.
When collecting Your Communications and Feedback, we will receive your name, email address, a message number, a tracking URL number, and other information that you may provide.
When collecting Client Data, we will receive the names and contact information of the prospective Client’s representatives.
When collecting Financial and Payment Information, our third-party processor will receive your bank account number, bank routing information, credit card numbers, security codes, expiration dates, and other related billing information.
When collecting Job Applicant Information, we will receive your name, address, telephone number, and email address.
Categories of personal information described in the California Customer Records statute
When collecting Freelancer Account Information, we will receive your name, telephone number, physical address, and any additional information you choose to provide.
When collecting Your Communications and Feedback, we will receive your name and other information that you may provide.
When collecting Client Data, we will receive the names and contact information of the prospective Client’s representatives.
When collecting Financial and Payment Information, our third-party processor will receive your bank account number, bank routing information, credit card numbers, security codes, expiration dates, and other related billing information.
When collecting Job Applicant Information, we will receive your name, address, telephone number, email address, resume, and information about your professional experience.
Characteristics of protected classifications
When collecting Freelancer Account Information, we will receive your photo, which could include characteristics of protected classifications.
Biometric information
In collecting Freelancer Account Information, we will receive your photo and an audio cover letter.
Internet or other electronic network activity information
We collect cookies and use similar technologies as described in the “Personal Information Collected Via Cookies and Similar Technologies” section of this Policy.
When collecting Usage Information, we will automatically receive information from your browser and your device, which includes the date and time of your visit as well as your location, domain server, browser type, access time, and data about which pages you visit.
When collecting Your Communications and Feedback, we will receive data related to if/when you open our message and if/when you click on any links or banners it contains, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page.
Geolocation data
When collecting Freelancer Account Information, we will receive your physical address and time zone.
When collecting Cookies and Similar Technologies and Usage Information we will receive your location while using the Site.
When collecting Job Applicant Information, we will receive your physical address and time zone.
Audio, electronic, visual, thermal, olfactory, or similar information
In collecting Freelancer Account Information, we will receive your photo and an audio cover letter.
When collecting Your Communications and Feedback, we will receive and retain your communications.
Professional or employment-related information
When collecting Freelancer Account Information, we will receive your resume, work sample, skills, work/employment history, years of experience, general work hours, typical rate and availability, referral source, professional profile links (e.g. LinkedIn, GitHub, Bitbucket) and any additional information you choose to provide. We also receive the results of your coding tests. Once you are admitted to the Community, are matched with a Client, and begin work, we may receive from our Clients information regarding the performance of your services to that Client.
When collecting Client Data, we will receive information relating to the Client’s needs.
When collecting Job Applicant Information, we will receive your resume and information about your professional experience. You may choose to disclose salary history or salary expectations.
Personal Information Collected Via Cookies and Similar Technologies
First and Third-Party Cookies
A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the Site, and they can only be read by the Site. Third Party Cookies are set by a party other than us. We use first-party and third-party session, persistent, and/or flash cookies and the information collected by them as set forth below.
Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with the Site:
Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.
Social Widgets: These are buttons or icons provided by third-party social media providers that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a web page) when you move from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
What Cookies and Similar Technologies Are in Use and Why Do We Use Them?
Drift: We use Drift to facilitate the chatbot function on the Site. Drift’s privacy policy is available at: https://www.drift.com/privacy-policy/. Drift uses the following cookies:
| Cookie | Description | Category | Duration |
| DFTT_END_USER_ PREV_BOOTSTRAPPED | This cookie marks when the Drift site visitor ID has been created within the Drift system. This allows subsequent page visits to be faster because you do not have to be registered in Drift’s system again. | Marketing | 2 Years |
| driftt_aid | This is an anonymous identifier token used by Drift. It is used to tie the visitor with the profile within the Drift system. This allows Drift to remember the information that a site visitor has provided through the chat on subsequent site visits. | Marketing | 2 Years |
| driftt_sid | This is a session identifier token used by Drift. It is used to tie a visitor with a current website session within the Drift system. This is enables session-specific features, such as popping up a messaging only once during a 30-minute session as to prevent a disruptive experience. | Marketing | 30 Minutes |
Intercom: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s).
The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties’ privacy notices for further information on their use of your personal data. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visithttps://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found athttps://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.
Facebook Connect and Custom Audiences: We use Facebook’s technologies to find Freelancers and Clients among people who are on Facebook, to serve relevant advertisements, and to track Facebook ad-driven visitor activity on the Site. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook’s policies by visiting https://www.facebook.com/policy.php, and you can also find instructions for opting out of receiving advertisements on this page.
| Cookie | Description | Category | Duration |
| _fbp | Used by Facebook to deliver a series of advertisement products when you are on Facebook or a digital platform powered by Facebook advertising after visiting the Site. This is Facebook’s primary advertising cookie, and it is used to deliver, measure, and improve the relevancy of ads. | Marketing | 90 Days |
| fr | The cookie is set by Facebook to show relevant advertisements to users and to measure and improve advertisements. The cookie also tracks the behavior of users across the web on sites that have Facebook pixel or Facebook social plugin. This cookie identifies browsers for the purposes of providing advertising and site analytics services. | Marketing | 90 Days |
| datr | Browser identifier and time stamp that identifies browsers for purposes of security and site integrity, including for account recovery, and identification of potentially compromised accounts. | Functional | 2 Years |
| Dpr | Allows delivery of optimal experience for user’s screen and includes a numeric value between 1 and 2 indicating device pixel ratio | Functional | 7 Days |
| Wd | Allows delivery of optimal experience for user’s screen and includes screen or window dimensions | Functional | 7 Days |
FullStory: We use FullStory to capture interaction data on the Site. This includes usage patterns (e.g. where you click and how you move your mouse), technical specifications (e.g. browser type, device type, operating system, viewfinder size), and navigation (e.g. pages visited, referring pages). Usage patterns illuminate areas of our Site that may be confusing or underused, allowing us to improve your experience and build better features. Technical specifications help us resolve bugs and errors. Navigation data helps us improve the quality of our content and advertising. The information collected also includes a display name for you and your email address so that we can understand your unique experience and troubleshoot any problems you may be having. To view FullStory’s Privacy Policy please visit: https://www.fullstory.com/legal/privacy/. You may opt-out of FullStory by visiting https://www.fullstory.com/optout/.
| Cookie | Description | Category | Duration |
| fs_uid | Contains an end-user identifier when recording their activities on the Site | Analytics | Persistent |
| OptanonConsent | Cookie consent tracking | Functional | 1 Year |
Google Analytics: We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Site. The information stored in the cookie is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy.
You may learn more about Google Analytics and the cookies used by Google by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en). Google Analytics has certified compliance with the EU-US Privacy Shield Framework set forth by the U.S. Department of Commerce. Google Analytics relies on the following cookies:
| Cookie | Description | Category | Duration |
| _ga | The cookie is used by Google Analytics to calculate visitor, session, and campaign data and to keep track of site usage for the Site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to identify unique visitors. | Analytics | 2 Years |
| _gat | This cookie is used to throttle request rate | Analytics | 1 Minute |
| _gid | This cookie is used to distinguish users | Analytics | 24 Hours |
Google Marketing Platform: We use the Google Marketing Platform (Google Analytics Advertising Features and DoubleClick) to track user activity on the Site and to serve personalized advertisements. Your browser is assigned a pseudonymous ID used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, visit https://support.google.com/displayvideo/answer/7621162. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922.
| Cookie | Description | Category | Duration |
| 1P_JAR | This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website | Marketing | 30 Days |
| NID | This cookie is used to help customize ads on Google properties, like Google Search. This cookie will remember your most recent searches, your previous interactions with an advertiser’s ads or search results, and your visits to an advertiser’s website | Marketing | 6 Months |
| DV | Used for the purpose of targeted advertising | Marketing | 10 Minutes |
| IDE | This cookie is used by Google DoubleClick and stores information about how end users use the Site and any other advertisement before visiting the Site. This is used to present users with ads that are relevant to them according to the user profile. | Marketing | 2 Years |
| Test_cookie | This cookie is set by DoubleClick (which is owned by Google) to determine if the website visitor’s browser supports cookies | Marketing | 15 Minutes |
| _gcl_au | Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. | Marketing | 3 Months |
| OGPC | This cookie enables the functionality of Google Maps | Functional | 1 Month |
| __Secure-3PAPISID | Used for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalized Google advertising | Marketing | 2 Years |
| __Secure-3PSID | Used for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalized Google advertising | Marketing | 2 Years |
| __Secure-APISID | Used for targeting purposes to build a profile of the website visitor’s interests in order to show relevant & personalized Google advertising | Marketing | 5 Months |
| __Secure-HSID | Used for security purposes to store digitally signed and encrypted records of a user’s Google account ID and most recent sign-in time which allows Google to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized parties. This can also be used for targeting purposes to show relevant & personalized ad content. | Functional/Marketing | 5 Months |
| __Secure-SSID | Used to store information about how you use the website and any advertising that you may have seen before visiting this website, in addition to being used to help customize advertising on Google properties by remembering your most recent searches, your previous interactions with an advertiser’s ads or search results and your visits to an advertiser’s website. | Marketing | 5 Months |
Google Tag Manager: We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) is a cookie-less domain and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.
HotJar: We use HotJar to capture interaction data on the Site. Hotjar tracks user activity and creates heat-maps and visitor activity recordings. Hotjar also assigns visitors a unique user identifier and tracks returning visitors to our Site. HotJar’s privacy policy is available at https://www.hotjar.com/legal/policies/privacy/, and you may opt-out by visiting: https://www.hotjar.com/legal/compliance/opt-out. HotJar uses the following cookies:
| Cookie | Description | Category | Duration |
| _hjCachedUserAttributes | This cookie stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. These attributes will only be saved if the user interacts with a Hotjar Feedback tool. | Analytics | Session |
| _hjIncludedInSample | This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels. | Analytics | 365 Days |
| _hjTLDTest | When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed. | Analytics | Session |
| _hjid | This cookie is set when the user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID. | Analytics | 365 days |
HubSpot: We use HubSpot to track visitors to the Site and to gather demographic information about them. HubSpot keeps track of the Sites and pages you visit. This data is used to deliver customized content and promotions to users whose behavior indicates that they are interested in a particular subject area. For more information about HubSpot’s Privacy Policy, see https://legal.hubspot.com/privacy-policy.
| Cookie | Description | Category | Duration |
| __hssc | This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. | Marketing | 30 Minutes |
| __hssrc | Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. | Marketing | Session |
| __hstc | This cookie tracks visitors, and it contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). | Marketing | 13 Months |
| hubspotutk | This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. | Marketing | 13 Months |
| __cfduid | This cookie is set by HubSpot’s content delivery network provider, Cloudflare. It helps Cloudflare detect malicious visitors to the website and minimizes blocking legitimate users. It may be placed on your devices to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare’s security features. According to CloudFlare it is used to speed up page load times and to override any security restrictions based on the IP address the visitor is coming from. It does not contain any user identification information. | Marketing | 1 Month |
| __cfruid | This cookie is set by HubSpot’s content delivery network provider (Cloudflare) because of their rate limiting policies. It is used to identify trusted web traffic. | Marketing | Session |
| __d_hsutk | Used to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts. | Marketing | 30 minutes |
| hs_ab_test | This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before. | Marketing | Session |
| MessagesUtk | This cookie is used to recognize visitors who chat with us. If the visitor leaves the Site before they’re added as a contact, they will have this cookie associated with their browser. If you chat with us again in the same browser, this cookie allows us to see the conversation history. | Marketing | 13 Months |
| __hs_opt_out | This cookie is used to remember not to ask the visitor to accept cookies again | Functional | 13 Months |
LinkedIn Marketing Solutions: We use LinkedIn Marketing Solutions to serve your relevant advertisements and to understand how our ads are driving business results, like generating leads, purchases, and registrations. Analytic features also allow us to compare metrics, like clicks, impressions, and social actions, to learn which campaigns and ad creatives are most effective. LinkedIn’s privacy policy is available at: https://www.linkedin.com/legal/privacy-policy and you can opt-out by visiting: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out?trk=microsites-frontend_legal_cookie-policy.
| Cookie | Description | Category | Duration |
| UserMatchHistory | LinkedIn Ads ID syncing | Marketing | 30 Days |
| bcookie | Browser ID cookie | Marketing | 2 Years |
| lang | Sets default locale/language | Marketing | Session |
| li_oatml | Member indirect identifier for conversion tracking, retargeting, analytics | Marketing | 1 Month |
| li_sugr | Browser Identifier | Marketing | 3 Months |
| liap | Cookie used for Sign-in with LinkedIn and/or for LinkedIn follow feature | Marketing | 3 Months |
| lidc | Used for routing | Marketing | 1 Day |
| lissc | Used to deliver a series of advertisement products such as real time bidding from third party advertisers | Marketing | 1 Year |
| lang | Sets default locale/language | Marketing | Session |
| U | Browser Identifier associated with Drawbridge (adsymptotic.com) | Marketing | 3 Months |
Microsoft Advertising: We use Microsoft Advertising to serve advertisements in response to keywords entered into search engines like Bing, AOL, or Yahoo. To opt out of the Microsoft Advertising optimization program, please visit: https://about.ads.microsoft.com/en-us/resources/policies/opt-out-of-the-microsoft-advertising-optimization-program. To opt out of personalize ads, please visit: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads. The Bing Ads privacy policy is available at: https://about.ads.microsoft.com/en-us/resources/policies/microsoft-advertising-privacy-policy. This platform relies on the following cookies:
| Cookie | Description | Category | Duration |
| MUID | This cookie tracks sessions related to Bing Ads, and it is used to help count valid clicks | Marketing | 13 Months |
| MR | This cookie tracks sessions related to Bing Ads, and it is used to collect information for analytics purposes | Marketing | 1 Week |
| MR2 | This cookie tracks sessions related to Bing Ads | Marketing | 1 Week |
| MUIDB | This cookie carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website | Marketing | 13 Months |
| SRCHD | Supports the mapping service from Bing | Functional/Marketing | Persistent |
| SRCHUID | Supports the mapping service from Bing | Functional/Marketing | Persistent |
| SRCHUSR | Supports the mapping service from Bing | Functional/Marketing | Persistent |
| _EDGE_S | Supports the mapping service from Bing | Functional/Marketing | Session |
| _SS | Supports the mapping service from Bing | Functional/Marketing | Session |
Typekit by Adobe: We use Typekit by Adobe to enhance the Site’s typography. Adobe uses cookies within Typekit to track usage statistics, and they collect usage information about the fonts being served on the Site.
Other Cookies: We also use the following cookies to provide functionality on the Site:
| Cookie | Description | Category | Duration |
| csrftoken | Prevents cross-site request forgery | Functional | 365 Days |
| sessionid | Identifies your session | Functional | 30 years |
| dc | Under review | Session | |
| AMCVS**AdobeOrg | This cookie serves as a flag indicating that the session has been initialized | Marketing | Session |
| AMCV**AdobeOrg | This cookie contains the Experience Cloud visitor ID or MID. This cookie lets the ID service track visitors across different domains and enables data sharing among different Experience Cloud solutions. | Marketing | 2 Years |
| __stripe_mid | Stripe uses this cookie to process payments and prevent fraud | Functional | 1 year |
Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
Choices About Cookies
We provide you with choices regarding the personal information you provide to us, and we have created ways to give you control over your information. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow marketing and analytics cookies via the cookies consent banner or set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.
Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the cookie settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your Cookie Settings on the Site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browser providers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html.
For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
Other Processing Activities
We may process any of personal information identified in this Policy when necessary for:
- The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
- Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
- Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
- Because it is necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us;
- To comply with our legal obligations as well as to keep records of our compliance processes;
- Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- Because you have chosen to publish or display your personal information on a public area of the Site, such as a comment area;
- Because it is necessary to protect your vital interests;
- Because it is necessary in the public interest; or
- Because you have expressly given us your consent to process your personal information in a particular manner.
We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above.
As permitted by applicable law, under the California Consumer Privacy Act, we may use and disclose any of the personal information that we collect in order to:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate federal, state, or local law;
- Exercise or defend legal claims; and
- Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.
SHARING AND DISCLOSING OF YOUR PERSONAL INFORMATION
We may share your personal information in the following contexts.
| Category | Disclosure Contexts |
| Corporate Affiliates | We may share your personal information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. |
| Acquisitions and Similar Transactions | We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. |
| Disclosures with Your Consent | We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent. |
| Legal Obligations and Rights | We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contract. We may also disclose personal information as needed to protect vital interests. |
| Public | Some areas of our Site may offer forums or provide the opportunity for users to post comments or reviews in a public forum. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly-available. |
| Service Providers | We may share your personal information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site; support our provision of services/products requested by you; provide technical support; send marketing, promotions and communications to you about our services/products; provide payment processing; and assist with other legitimate purposes permitted by law. |
| Professional Advisors | We may share your personal information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf. |
| Deidentified Aggregated Data | We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development. |
| Third Parties | We may provide personal information about you to third parties that may offer products and services specifically requested by you. The third party will act as the controller for purposes of the GDPR. |
HOW LONG DO WE STORE AND USE YOUR PERSONAL INFORMATION?
We will retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.
We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives.
To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete personal information, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technology and methods.
While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you do so at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.
If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.
RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
Please use the “Contact Us” details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the “Contact Us” details at the end of this Policy. If you are exercising a right that is the responsibility of our data controller Clients, we will direct you to contact the appropriate data controller who is responsible for responding to your request.
Email Opt-Out
If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link available at the bottom of our email communications or by contacting us at [email protected] and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Note, however, that as a user of our services, you cannot opt-out of some administrative communications that are reasonably necessary to the Services, such as billing or service notifications.
Cookies
You may choose to not allow marketing and analytic cookies via the cookies consent banner or set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
Online Tracking Signals
We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.
Accuracy and Updating Your Personal Information
Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Preferences
If you wish to change your communication preferences or ask that we restrict how we use your personal information, please contact us via the “Contact Us” details at the end of this Policy. You may follow opt-out links on any marketing communications sent to you.
Complaints
If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.
California Residents
Data Practices During the Last 12 Months
Personal Information Collected
We have collected the categories of personal information listed below during the preceding 12 months.
- Identifiers
- Categories of personal information described in the California Customer Records statute
- Characteristics of protected classifications
- Biometric information
- Internet or other electronic network activity information
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
Categories of Sources
We have collected the personal information listed above from you, reference sources identified by you, our Clients, and our background check vendors.
Business and Commercial Purposes for Collecting
We have collected the categories of personal information listed above for the following purposes:
- Operate the Site;
- Provide our services;
- Ensure the privacy and security of our Site and services;
- Maintain our databases and back-ups;
- Manage our relationships with you;
- Communicate with you;
- Keep records of our communications with you;
- Send you our notifications and newsletters;
- Promote our services;
- Process your request to become a Freelancer and administer our contract with you once you become a member of the Community.
- Verify your eligibility and suitability for employment or other relationships with us;
- Comply with your instructions or requests
- Comply with immigration requirements;
- Verify your identity;
- Promote your services;
- Analyze use of the Site and our services;
- Serve you the content and functionality you request;
- Develop new services;
- Enhance your experience;
- Track visits to the Site;
- Provide you with a more personal and interactive experience on the Site;
- Improve our marketing efforts;
- Communicate with you;
- Keep records of our communications with you;
- Enhance your experience; and
- Send you our notifications and newsletters.
Personal Information Sold
We do not sell personal information, and we have not sold personal information during the preceding 12 months.
Personal Information Disclosed for a Business Purpose
We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months:
- Identifiers
- Categories of personal information described in the California Customer Records statute
- Characteristics of protected classifications
- Biometric information
- Internet or other electronic network activity information
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
We have shared these categories of personal information with the following categories of third parties: (1) service providers (e.g. accounts, attorneys, advisors, mailing, marketing, shipping fulfillment, payment processing, Site administration, technical support, modeling, analytics; and (2) our Clients with whom we may place Freelancers.
No Financial Incentive
We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.
Do Not Sell My Personal Information
Under the California Consumer Privacy Act (CCPA), you have the right to direct us to stop selling your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell personal information as defined under applicable law.
CCPA Requests to Know and Requests to Delete
The CCPA gives consumers the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.
However, by way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold. In addition, de-identified information is not subject to these rights.
If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.
You have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request.
Request to Know
Submission Instructions: You may submit a request to know via [email protected]. If you maintain an account with us, we may require you to submit the request through that account.
Verification Process: We are required by law to verify the identities of those who submit requests to know, and our verification process is described in detail below. We will inform you if we cannot verify your identity.
- If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
- If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
- If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.
Request to Delete
You have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described below, we will delete your personal information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records.
Submission Instructions: You may submit a request to delete via [email protected]. We may present you with the choice to delete select portions of your personal information, but a global option to delete all personal information will be offered and more prominently presented.
Verification Process: We are required by law to verify the identities of those who submit requests to delete, and our verification process is described in detail below. We will inform you if we cannot verify your identity.
- If we cannot verify the identity of the person making a request to delete, we may deny the request.
- If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.
Verification Procedures
To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, address, telephone number, and last placement with one of our Clients. If you only use the Website (and not the Developer Platform) we may not be able to verify your identity.
If we cannot verify your identity based on the information already maintained, we may request additional information from you. We will try to limit the information collected, and we will only use this information to verify your identity and for security or fraud-prevention purposes. Except as required by law, we will delete any new personal information collected for the purposes of verification as soon as practical after processing the request.
Password-Protected Account: If you have a password-protected account with us, we may verify your identity through our existing authentication practices for the account. We will require you to re-authenticate yourself before disclosing or deleting your data. If we suspect fraudulent or malicious activity on or from the password-protected account, we will not comply with the request until further verification procedures determine that the request is authentic and that the consumer making the request is the person about whom we have collected information.
We require different levels of authentication based upon the nature of the personal information requested. A more stringent verification process is applied when (1) sensitive or valuable personal information is involved, (2) there is a greater risk of harm to the consumer, and/or (3) there is a higher likelihood that fraudulent or malicious actors would request the information
Authorized Agents
Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
California Shine the Light
Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected].
Nevada Residents
You may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.
EU/EEA Residents
If you are located in the EU or EEA, you have the following rights under the GDPR. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
Right of Access: To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
Right of Rectification: Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Erasure: In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Restrict Processing: You have the right to restrict when (1) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.
Right to Object: In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.
Right to Withdraw Consent: If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Right to Complain: If you believe we have not processed your personal information in accordance with applicable provisions of the GDPR, we encourage you to contact us at [email protected]. You also have the right to make a GDPR complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We are located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using the Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
When storing, hosting, or otherwise processing your information (including personal data), we may send such data outside of the EU and the EEA. When we transfer information to the United States or other countries, we do so for the purposes set forth in this Privacy Policy and in accordance with applicable law. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU and EEA, such as your express informed consent to do so, when transfer is necessary for us to deliver services pursuant to an agreement between us and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.
THIRD-PARTY SITES
This Policy is applicable only to the Site, and it does not apply to any third-party websites.
The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we may have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third-party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.
We cannot and do not (1) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your personal information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site.
Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 16 or younger, nor is information knowingly collected from children under the age of 16. No one under the age of 16 may access, browse, or use the Site or provide any information to or on the Site. If you are under 16, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 16 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 16, please contact us using the contact information provided below.
For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
UPDATES AND CHANGES TO THIS POLICY
We reserve the right, at any time, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.
CONTACT US
For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.
In writing: Gun.io Incorporated
Attention: Privacy Policy Query
1200 Clinton St., Suite 225
Nashville, TN 37203
By telephone: (615) 541-8095
By email: [email protected]