Effective Date: June 8, 2021
1. Personal Information We Collect
Information You Provide to Us. We collect personal information when you use our Services, contact us, use our products, create an account, or interact with us for any other purpose.
We may collect the following personal information that you provide through our Services or otherwise:
- Contact information such as name, email address, mailing address, phone number, professional title, and organization affiliation;
- Billing information such as payment card number and billing address;
- Profile information, such as user name, account number, and password;
- Preference information such as marketing preferences;
- Account information including information entered in website forms or when creating or using accounts;
- Communications, including information associated with your inquiries to us and any feedback you provide when you communicate with us;
- Transaction data, including information associated with your transactions with us or our affiliates, information needed to complete your orders and registrations, and information about services you have purchased from us.
Information Collected Automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on the Services and other online sites and services, such as:
Online activity data, such as the website you visited before browsing to the Site or downloading the App, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and basic data passed during text message transmission (including, but not limited to, data about the message content, photos, and files that you send or receive, and the message count/volume). When you use our browser extension
- Device data, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state or geographic area.
- Precise geolocation data, such as your real-time location (when you allow our Application to access your location).
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of our marketing campaigns. We may use web beacons to collect information about your interactions with our email messages, such as the links you click on and whether you open or forward a message, the date and time of these interactions and the device you use to read emails.
- Software development kits, or SDKs, which are used to incorporate third party computer code into our Application that allows our third party service providers or advertising partners to collect data directly from our Application for a variety of purposes, including to provide us with analytics regarding the use of our Application, to integrate with social media, add features or functionality to our Application, or to facilitate online advertising.
Information from Third Parties. We may receive personal information about you from other sources, such as our customers; companies that help provide our Services; data providers; business partners, such as joint marketing partners; and publicly-available sources, such as social media platforms. We may combine such personal information with information we have already collected about you.
When you connect with any of our integration partners through the Services, we may also receive information about you from the integration partner such as account information and your content.
Information About Others. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
Sensitive Personal Information. Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
2. How We Use Your Personal Information
Services Delivery. We may use your personal information:
- To provide, operate, and improve the Services and our business;
- To create and maintain your account;
- To process and fulfill your orders, including to send you emails to confirm your order status, and to provide other related communications;
- To respond to your inquiries or support tickets;
- To provide products and services you request, including to provide publications to which you subscribe;
- To operate, personalize, and improve the Services, including for analytics purposes;
- To contact you for phone number verification, enrollment/activation activities, encouraging or enabling your use of the Services including, but not limited to, specific features, to address possible inappropriate use, to send you announcements, updates, and administrative notices, or at our discretion;
- To enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in; and
- For our other business purposes, such as payment processing and operational purposes.
Research and Development. We may use your information for research and development purposes, including to improve the Services, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
Marketing and Advertising. We, our business partners and our third party advertising partners may collect and use your personal information for direct marketing and interest-based advertising purposes.
- Direct marketing. We may send you Staffing Engine-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices Regarding Your Information” section below.
- Compliance and Protection. We may use your personal to: comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; maintain the safety, security, and integrity of our Services, products and services, business, databases and other technology assets; protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern the Services; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
- With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
3. How We Share Your Personal Information
- Service Providers. With our vendors, consultants, agents, contractors, and other service providers that we use to help us operate the Services or support our business (such as payment processors, customer service providers, shipment vendors, email service providers, SMS service providers, IT, hosting, data management, marketing, analytics providers, event management services, order fulfillment, and surveys).
- Third Parties Designated by You. When you use the Services, the personal information you provide will be shared with the third parties that you designate to receive it (for example, the person you are texting).
- Business Transferees. Relevant participants in business transactions (or potential transactions) involving a corporate sale, merger, acquisition, reorganization, consolidation, or other transfer or disposition of all or part of our assets (including in connection with a bankruptcy or similar proceedings).
- Authorities, Law Enforcement and Others. Law enforcement, government authorities, and privacy parties, as we believe necessary for the compliance and protection purpose described above, such as pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of us, our users, or third parties.
- Professional Advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- Our Customers. The organization you work for or that otherwise maintains and administers your account on the Services.
- Advertising Partners. We work with third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
4. Third-Party Links and Tools
Our Services may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Services, those third parties may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third parties and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.
5. Your Choices Regarding Your Information
You have several choices regarding use of information on our Services:
- Email Communications. You may indicate a preference to stop receiving further marketing e-mail from us and may “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service-related communications.
Changing Your Personal Information. You may change certain elements of personal information in your Account by logging into the Services. You may request deletion of your personal information by us by contacting us at the email address below, and at our discretion, we may use commercially reasonable efforts to honor your request; but, please note that we may be required to retain such information for legal or compliance purposes. We may also retain your information for fraud prevention or similar purposes.
- Customer Contacts. Our customers control the information they collect and process when using the Services, including the contact information and message content of individuals they communicate with. Staffing Engine has no direct relationship with these individuals, who should direct any requests related to their information to our customer.
- Location Data. Users of our App can disable our access to their device’s precise geolocation in their mobile device settings.
- Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Staffing Engine uses Google Analytics and other third-party services to improve the performance of the Site and Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site and Services, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the European Interactive Digital Advertising Alliance (for European users – http://www.youronlinechoices.eu/), and the Digital Advertising Alliance (optout.aboutads.info). Application users can also download the Digital Advertising Alliance’s AppChoices mobile app, available at https://www.youradchoices.com/appchoices.
Some of the advertising we work with also offer their own opt-out options that you can use to limit their use of your information for interest-based advertising purposes. You can learn more about how Google uses data at https://policies.google.com/technologies/partner-sites and about how Facebook uses data at https://www.facebook.com/privacy/explanation. You can opt out-out of personalized ads from Google by visiting https://adssettings.google.com, or from Facebook by visiting https://www.facebook.com/about/ads and following the instructions to manage your ad preferences.
The opt-out preferences described above must be set on each device and/or browser for which you want them to apply. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to Provide Your Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
6. Security of Your Personal Information
Your security matters to us. We use a variety of security technologies and procedures designed to help protect your personal information from unauthorized access, use, or disclosure. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
7. International Data Use
Staffing Engine is headquartered in the United States and has service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Individuals in the European Economic Area and the United Kingdom should read the important information provided below about transfer of personal information outside of those areas.
The Services are not directed at, and Staffing Engine does not knowingly acquire or receive personal information from, children under the age of 16. If we learn that any user of the Services is under the age of 16, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Services.
9. Your California Privacy Rights
Under California Civil Code Section 1798.83, also known as the “Shine The Light” law, if you live in California and have an established business relationship with us, you may request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the address in the “Contact” section below and include “Shine the Light Request” in the subject line. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Staffing Engine, Inc.
Attn: Privacy Agent
2401 Broadway St
Boulder, CO 80304
12. Additional Information for European Users
The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”).
Processing is necessary to perform the contract governing our operation of the Site or the provision of the Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.
Research and Development
Marketing and Advertising
Processing is based on your consent where that consent is required by applicable law.
Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business and showing you tailored relevant content.
Compliance and Protection
Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety or property.
With Your Consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.
Retention. We will retain your personal data for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us at support@StaffingEngine.ai or at the mailing address listed above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at support@StaffingEngine.ai for further information about any such transfers or the specific safeguards applied.