People Data Labs Privacy Policy

Last Updated February 3, 2023

People Data Labs, Inc. (“People Data Labs,” “we,” “us,” and “our”) is committed to protecting your privacy with the utmost standards of data stewardship. We provide a variety of data products, technologies, and services (our “Services) to companies and organizations (our “Customers”) to generate professional opportunity and create a more-personalized, less-fraudulent, and better world.

This Privacy Policy describes how we collect, use, disclose, and protect information through our Services. It applies to the information collected on peopledatalabs.com (the “Website”) and via the Services that we provide to our Customers. When we say “you” we are referring to consumers and visitors to our website, including the person reading this Privacy Policy.

This Privacy Policy contains the following sections:

1. Information we collect

2. How we use your information

3. Legal Basis for use of your information

4. How we share your information

5. Information We Do Not Use or Disclose

6. Cookies and Similar Technologies

7. Online Analytics and Advertising

8. How we protect your information

9. Data Retention

10. Your choices

11. Information for California Residents

12. Information for Nevada Residents

13. Information for International Residents

14. Children's privacy

15. Changes to our policy

16. Our contact information

1. INFORMATION WE COLLECT

We obtain information about you through the means discussed below when we provide the Services to our Customers.

Information Collected via our Data Union. Our “Data Union” is a data sharing group comprised of our Customers that share data for collective benefit, including recruitment, market research, workforce planning, and other purposes. The Customers that participate in our Data Union are the entities that collect information about you. This information could include your email, name, date of birth, age, email address, address, phone number, company, job title, job history, location, education history, and social network handles.

Information Collected from Third Parties. In addition to the information we collect about you from our Customers, we may collect information about you from the following third party sources:

• Publicly available sources, including governmental public records, the public internet and social media.

• Customers who join the Data Union via a customer partnership;

• Third parties who license, sell, or otherwise provide data they have collected; and

We do not collect data from sites that have been designated as private.

Information Provided by Customers to Use the Services. When Customers subscribe to use the Services, we may collect personal contact information regarding users of the Services and financial information for billing purposes (“Customer Information”).

Information Collected from Website Visitors. When you access our Website, we may automatically receive and store certain information about you through your device(s). As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies, to assist in this collection.

• Device Information. We collect technical information associated with the device(s) you use to visit our Website, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.

• Usage Information. We also collect a variety of information to better understand use of our Website. This may include the webpage that you were visiting before accessing our Services, the pages or features of our Website you use, how much time you spend there, date and time of use, and information about your usage preferences.

Information Provided by You. We also may collect information that you directly provide to us on our Website. For example, we may collect information about you when you submit an inquiry about our services. The information we are likely to collect from you includes information such as your name, contact information, and the subject of your inquiry.

2. HOW WE USE YOUR INFORMATION

We use your information to provide, support, and develop our Services. In particular, we may use your information to:

• Provide our Services. We may use your information to provide our Customers with our Services, such as helping hiring companies identify candidates; assisting Clients in the analysis and optimization of their proprietary database or mitigation of potential fraud (e.g., verifying someone is who they say they are when signing up or checking out online); supporting educational institutions personalize learning experiences; and providing Customers with marketing insights and defined audience segments.

• Operate our Services. We also may use your information and Customer Information to analyze use of the Services and improve the content, functionality and usability of the Services; secure the Services and investigate and help prevent fraud, security issues, and abuse; and understand and resolve Services crashes and other issues being reported.

• Other Internal Purposes. We may use your information or Customer Information to comply with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others; and establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our Subscription Agreement, other usage policies, and other legal terms or controls, or to engage in other legal matters.

• Other Purposes. We may use your information or Customer Information for any other purpose with your consent.

• Combine Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

• Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties in our discretion.

3. LEGAL BASES FOR USE OF YOUR INFORMATION

The legal bases for using your information and Customer Information as set out in this Privacy Policy are as follows:

• as necessary for our legitimate interests or the legitimate interests of others where those interests do not override your fundamental rights and freedom related to data privacy;

• with your consent; and

• as necessary to perform our agreement to provide Services.

4. HOW WE SHARE YOUR INFORMATION

We will share the information collected from and about you for the various business purposes described above, both with service providers and with third parties, including our Customers.

• Our Customers. We may share your information with our Customers, including job boards, hiring companies, CRM companies, sales and marketing companies, retailers and retail websites, education companies, anti-fraud companies, and other business-to-business service companies.

• Corporate Transactions. We may share information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

• Service Providers. We may share information collected with select third parties who use the information to provide services on our behalf, such as Services operation, surveys, web hosting, marketing and sales, billing and payments processing, analytics and online advertising, security, fraud prevention, and legal services.

• For Legal Purposes. We reserve the right to disclose information to third parties when we, in good faith, believe that such access or disclosure is reasonably necessary to comply with the law, regulation, legal process or a governmental request. We may also disclose your information to enforce our Subscription Agreement; to detect, prevent, or otherwise address fraud, security, or technical issues; to respond to user support requests; and to protect the rights, property or safety of People Data Labs, our Customers, and the public.

• At Your Direction. We may share information with third parties when you direct us to do so.

5. INFORMATION WE DO NOT USE OR DISCLOSE

In order to ensure compliance with various privacy regulations, we do not use or disclose the following sensitive personal data:

1. Racial or ethnic origin

2. Political opinions (including party affiliation)

3. Religious or philosophical beliefs

4. Trade union membership

5. Citizenship

6. Genetic data (and other health data such as disability or treatment)

7. Biometric data

8. Children under 18 years of age

9. Sexual orientation or sexual preferences

10. Precise location data

11. Contents of private communications such as emails, texts, voice calls, etc.

12. Financial account or payment card information when combined with authentication information

13. Device identifier (e.g. IMEI) depending on jurisdiction

14. Government Identifiers such as SSN, Driver's License or any other unique personal identifier assigned by a government to individuals

15. Inferences based on personal data, alone or in combination with other data, which indicate any of the above types of sensitive personal data

6. COOKIES AND SIMILAR TECHNOLOGIES

To collect the information in the “Information Collected from Website Visitors” section above, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future.

• A web server log is a file where online activity is stored.

• An SDK is a set of tools and/or code that we embed in our applications and software to perform certain functions, such as allowing us or third parties to collect information about how you interact with the Services.

• A cookie is a small text file that is placed on your computer or mobile device when you use the Services, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages you have visited on our Services and elsewhere; (iv), we do not knowingly collect data on anyone under 18. (v)enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (vi) perform searches and analytics; and (vii) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.

• Tags or tracking pixels (sometimes also referred to as web beacons or clear GIFs) are small code (sometimes containing, generating, or detecting a unique identifier) embedded in websites, online ads, and email that can be used for purposes such as generating web server log or reading or writing cookies for the purposes described above.

As we adopt additional technologies, we may also gather information through other methods.

Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

7. ONLINE ANALYTICS AND ADVERTISING

Analytics. We may use third-party analytics services on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to our Customers.

Advertising. When you use the Services or visit our Website, we may display advertising to you about our products, services, and related features that we think may be of interest to you to improve and personalize your use of the Services. We may personalize ads based on various factors such as the features you are using, demographic and geographic data, and other information that we collect about you.

In order to provide this advertising, we may use third party providers who may place cookies or other tracking technologies, on your device to collect information about your use of the Services in order to provide interest-based advertising to you on other websites.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party providers.

8. HOW WE PROTECT YOUR INFORMATION

We have implemented reasonable measures designed to secure information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect information, we cannot absolutely guarantee the security of your information transmitted via our Services. We are not responsible for circumvention of any privacy settings or security measures contained in the Services.

9. DATA RETENTION

We will retain your personal data for no longer than is necessary for the purposes stated in our Privacy Policy, unless otherwise extending the retention period is required or permitted by law. The data storage period may vary with scenario, product or service. The standards People Data Labs uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the website or products; handling possible user queries or complaints and locating problems; whether the user agrees to a larger retention period; and whether the laws, contracts and other equivalencies have special requirements for data retention.

10. YOUR CHOICES

• Opt Out of the Sale of Personal Information: In order to opt out from being included in the People Data Labs database, fill out this “opt-out” form and follow the instructions provided. Opting out will ensure that the provided information and associated data will not be shared or made available via our products and services.

• Request To Access Your Personal Information or Data Portability: In order to obtain a copy of the personal information we may have about you in a structured, commonly used and machine-readable format, fill out this “data request form” and follow the instructions provided.

• Opt Out Of Marketing Communications. You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using our contact information below. In many commercial email messages, you can also opt out by following instructions located at the bottom of such emails. Removing your name from the email list may take a reasonable amount of time.

  Depending on the laws of your local jurisdiction, you may also be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney which must be presented to us. We may also follow up with you to verify your identity before processing the authorized agent's request.

  Please note that, regardless of any of your requests, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

• Other Requests Regarding Your Information. Please contact us at privacy@peopledatalabs.com. We will take reasonable steps to act upon your requests.

• Validation of Consumer Identity. Please note that depending on the laws of your local jurisdiction, we may take reasonable steps to verify your identity and the authenticity of any request to opt-out, delete, or change your data.

11. INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. If you are not a California resident, this does not apply to you and you should not rely on it.

Categories of Personal Information We Collect and Disclose. The chart below sets forth the categories of information we may collect about you; whom we share or disclose personal information; and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

As described in the “Information We Collect” section of this Privacy Policy, we may collect personal information about you from job boards, hiring companies, CRM companies, sales and marketing companies, consumer goods retailers, retail websites, education companies, anti-fraud companies, other business to business service companies, and publicly available sources (e.g., social media sites), as well as personal information about you if you visit our Website, such as device and usage information.

In addition to the categories of third parties set forth in the above chart, we may also share any of the categories of personal information we collect as set forth in the “How We Share Information” section, including with:

• Governmental entities for legal purposes;

• Affiliates and subsidiaries in event of a corporate transaction; and

• Our vendors to perform business purposes on our behalf, such as analytics, hosting, fraud prevention, and other services.

How We Use These Categories of Information. Generally speaking, we use the above categories of information: to provide and manage the Services; for bug detection and error reporting; to audit consumer interactions on the Services; to protect the rights of the Services; and with your consent. For more detail regarding the purposes for which we use information, please see How We Use Your Information above.

Your California Rights and Choices. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information;

• Provide access to and/or a copy of certain personal information we hold about you;

• Correct certain personal information we have about you; and

• Delete certain personal information we have about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, for access requests, we may withhold some personal information where the risk to you or our business is too great to disclose the information. Where we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing, or other data management services), requests must be made through that client. We will forward your requests to a named client, as feasible. In addition, following a deletion request, we may retain certain information subject to exemptions under the law such as for our legal compliance.

For the fastest response to requests to exercise any of these rights, please send your request via online web form. Alternatively, you can call us at +1 877-489-1058.

Right to Opt Out of the Sale of Your Personal Information. California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” — including in the definition making available a wide variety of information in exchange for “valuable consideration.”

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the “Categories of Personal Information We Collect and Disclose” section above.

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information.

CCPA Metrics. You may review information about the number of requests we have received, complied with in whole or in part, or denied, and the median length of our response time by visiting our CCPA metrics page: CCPA Metrics.

California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. If you would like to opt out of such sharing, please use the sale opt out form noted above.

12. INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law). If you are a Nevada resident, you may submit a request to opt out of sales under Nevada law by filling out this “opt-out” form. Please note that depending on the laws of your local jurisdiction, we may take reasonable steps to verify your identity and the authenticity of the request.

13. INFORMATION FOR INTERNATIONAL RESIDENTS

Individual Rights. Local laws in jurisdictions outside of the United States of America may permit you to:

• obtain confirmation of whether we hold personal information about them, and receive information about how it is used and disclosed;

• obtain a copy of the personal information in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;

• update, correct or delete the information;

• object to the use or disclosure of the information;

• withdraw consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information);

• obtain a restriction on the use of the information;

• opt out of our handling of their personal information for direct marketing purposes; and

• file a complaint with the relevant supervisory authority, but we invite you to kindly first give us an opportunity to address your concern.

Data Transfers. We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as those of your country of residence. Per applicable law, we will ensure that transfers of personal information to such recipients are subject to appropriate safeguards

14. CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under the age of 18 years old. If you believe that we might have any such information, please contact us as described at the end of this Privacy Policy. If we discover that personal information of a child under the age of 18 has been submitted, we will take reasonable steps to delete it as soon as possible.

15. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through use of the Services. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, we will provide you with notice in accordance with legal requirements. Your use of the Services following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy.

16. OUR CONTACT INFORMATION

To ask questions or comment on this Privacy Policy and our privacy practices, a person may contact People Data Labs at privacy@peopledatalabs.com.