Privacy Statement
Last Updated: 03/22/2021
Your privacy is important to us. This privacy statement explains our collection, use, and disclosure of personal data. This privacy statement applies to ProvenBase, Inc. and to our controlled affiliates and subsidiaries (“ProvenBase”). References to our “products” in this statement include our websites, apps, software, and services (“Services”). This statement applies to our products that display or reference this statement, but it does not apply to any products that display or reference a different privacy statement.
Your privacy is important to us. This privacy statement explains our collection, use, and disclosure of personal data. This privacy statement applies to ProvenBase, Inc. and to our controlled affiliates and subsidiaries (“ProvenBase”). References to our “products” in this statement include our websites, apps, software, and services (“Services”). This statement applies to our products that display or reference this statement, but it does not apply to any products that display or reference a different privacy statement.
Personal data we collect
We collect information about users of our services and visitors to our website (“users”) and job prospects from different sources and in various ways when you use our products, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.
Users
Information users provide directly. We collect personal data you provide to us. For example:
Contact information. We collect name, username or alias, email address, postal address, phone number, company, job title, and work email and phone number. Additionally, you can choose to provide addresses to your social media accounts and information about individuals that referred you to our Services.
Demographic data. ProvenBase assists recruiters and hiring managers with hiring diverse talent. Therefore, in some cases, we request that you provide some demographic details, such as employment-related data.
Payment information. If you make a purchase or other financial transaction, we collect payment type, truncated credit card numbers, and other payment details.
Content and files. We collect the photos, documents, or other files you upload to our services; and if you send us email messages or other communications, we will collect and retain those communications.
Demographic data. ProvenBase assists recruiters and hiring managers with hiring diverse talent. Therefore, in some cases, we request that you provide some demographic details, such as employment-related data.
Payment information. If you make a purchase or other financial transaction, we collect payment type, truncated credit card numbers, and other payment details.
Content and files. We collect the photos, documents, or other files you upload to our services; and if you send us email messages or other communications, we will collect and retain those communications.
Information we collect about users automatically. When you use our products or visit our website, we collect some information automatically. For example:
Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies, Mobile IDs, and Similar Technologies section below, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
Geolocation data. Depending on your device and app settings, we collect geolocation data when you use our apps or online services.
Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.
Geolocation data. Depending on your device and app settings, we collect geolocation data when you use our apps or online services.
Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.
Information we create or generate users of our services. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.
Information we obtain about users from third-party sources. We also obtain information from third parties. These third-party sources include, for example:
Information we obtain about users from third-party sources. We also obtain information from third parties. These third-party sources include, for example:
Data brokers. Data brokers and aggregators from which we obtain user data to supplement the data we collect. We may obtain contact information, employment information, and other demographic data from third party data brokers.
Third party partners. Third party applications and services, including social networks you choose to connect with or interact with through our services may collect and share information with us, such as your contact information, usage data, device identifiers, and demographic data.
Co-Branding/Joint Partners. Partners with which we offer co-branded services or engage in joint marketing activities may share information such as contact information with us.
Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
Publicly available sources. We may collect any of the categories of information described above from public sources of information such as open government databases.
Third party partners. Third party applications and services, including social networks you choose to connect with or interact with through our services may collect and share information with us, such as your contact information, usage data, device identifiers, and demographic data.
Co-Branding/Joint Partners. Partners with which we offer co-branded services or engage in joint marketing activities may share information such as contact information with us.
Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
Publicly available sources. We may collect any of the categories of information described above from public sources of information such as open government databases.
Job prospects
Information job prospects provide directly.
Content and files
If you send us email messages or other communications, we will collect and retain those communications and any attachments.
Information we infer about job prospects.
Information we infer about job prospects.
Inferences
To assist managers in hiring diverse talent, we also infer some demographic data, such as gender, race/ethnicity, and age.
Information we obtain about job prospects from third-party sources.
Information we obtain about job prospects from third-party sources.
Data brokers. We may obtain contact information, geolocation data (such as city, state, and country), employment information, and other demographic data from third party data brokers.
Publicly available sources. We obtain data about job prospects, from sources of information such as open government databases and public-facing websites, including, for example, contact information, geolocation data (such as city, state, and country), content and files (such as social media profile pictures), employment-related information, and other demographic data.
Other third parties. Users of our services may upload contact information, geolocation data (such as city, state, and country), demographic data, and other employment-related information, such as a resume, about job prospects to our services.
Publicly available sources. We obtain data about job prospects, from sources of information such as open government databases and public-facing websites, including, for example, contact information, geolocation data (such as city, state, and country), content and files (such as social media profile pictures), employment-related information, and other demographic data.
Other third parties. Users of our services may upload contact information, geolocation data (such as city, state, and country), demographic data, and other employment-related information, such as a resume, about job prospects to our services.
When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain products or features, those products or features may not be available or function correctly.
We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including other identifiers and device information and usage data.
Cookies are small text files placed on your device that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.
Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables our third-party analytics and advertising partners to access the mobile IDs.
We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use our app). We and our partners also use these technologies to collect personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.
The third-party analytics and advertising providers we use on our websites include
Cookies are small text files placed on your device that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.
Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables our third-party analytics and advertising partners to access the mobile IDs.
We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use our app). We and our partners also use these technologies to collect personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.
The third-party analytics and advertising providers we use on our websites include
| Company/Service | Purpose(s) | Privacy Notices | Manage Settings (opt-out) |
|---|---|---|---|
| Google Analytics | Analytics | www.google.com/policies/privacy/partners | https://tools.google.com/dlpage/gaoptout |
Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
Email web beacons. Most email clients have settings which allow you prevent the automatic downloading of images, which will disable web beacons in the email messages you read.
Do Not Track. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
Email web beacons. Most email clients have settings which allow you prevent the automatic downloading of images, which will disable web beacons in the email messages you read.
Do Not Track. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
Our use of personal data
We use the personal data we collect for purposes described in this privacy statement or otherwise disclosed to you. For example, we use personal data for the following purposes:
| Purpose of use | Categories of User Personal Data | Categories of Prospect Personal Data |
|---|---|---|
| Product and Service Delivery. To provide and deliver our products, including securing, troubleshooting, improving, and personalizing those products. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, user inferences, and user information provided by third parties. | Contact information, demographic data, including employment-related information, content and files, prospect inferences, geolocation data, and any other category of information provided by third parties. |
| Business Operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, user inferences, and user information provided by third parties, including employment-related information. | Contact information, demographic data, geolocation data, content and files, and prospect inferences, and prospect provided by third parties, including employment-related information. |
| Product Improvement, Development, and Research. To improve our products, develop new products or features, and conduct research. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, prospect and user inferences, and prospect and user information provided by third parties, including employment-related information. | Contact information, demographic data, including employment-related information, content and files, prospect inferences, geolocation data, and any other category of information provided by third parties. |
| Personalization. To understand you and your preferences to enhance your experience and enjoyment using our products. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, and user inferences. | |
| Customer Support. To provide customer support and respond to your questions. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, and user inferences. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, and inferences. |
| Communications. To send you information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, and user inferences. | |
| Marketing. To communicate with you about new products, offers, promotions, rewards, contests, upcoming events, and other information about our products and those of our selected partners (see the Choice and Control section of this privacy statement for how to change your preferences for promotional communications). | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, and user inferences. | |
| Advertising. To display advertising to you (see the Cookies section of this privacy statement for information about personalized advertising and your advertising choices). | Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, and user inferences. |
We combine data we collect from different sources to achieve these purposes and to give you a more seamless, consistent, and personalized experience.
Our sharing of personal data
We share personal data with your consent or as necessary to complete your transactions or provide the products you have requested or authorized. For example, when you provide payment data to make a purchase, we will share that data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.
Additionally, we may share prospect data with recruiters using our Services.
In addition, we share each of the categories of personal data described above for the following business purposes:
Additionally, we may share prospect data with recruiters using our Services.
In addition, we share each of the categories of personal data described above for the following business purposes:
- Our subsidiaries, affiliates, and related companies share common data systems and process personal data as needed to provide our products and operate our business.
- We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to process payments or assist in protecting and securing our systems and services may need access to personal data to provide those functions.
- We may also disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
We will also access, transfer, disclose, and preserve personal data when we believe that doing so is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
- Protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
- Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks; or
- Protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.
Third-party vendors, including analytics, advertising, and Application Programming Interface (API) companies, also collect personal data through our website and apps including, transaction details, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement.
Finally, we may share de-identified information in accordance with applicable law.
Please note that some of our products include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy statements. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.
Finally, we may share de-identified information in accordance with applicable law.
Please note that some of our products include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy statements. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.
CHOICE AND CONTROL OF PERSONAL DATA
Access, correction, and deletion. If you wish to request access to, or correction or deletion of, personal data about you that we hold, you may contact us as described at the bottom of this privacy statement. However, to the extent permitted by applicable law, we reserve the right to charge a fee or decline requests that are unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, or where we are unable to authenticate you as the person to whom the data relates.
Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, physical mail, communications applications, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain of our products, or to surveys or other informational communications that may have their own unsubscribe method.
Choices for Cookies and Similar Technologies. See the Cookies section for choices about cookies and other analytics and advertising controls.
Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, physical mail, communications applications, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message. These choices do not apply to mandatory service communications that are part of certain of our products, or to surveys or other informational communications that may have their own unsubscribe method.
Choices for Cookies and Similar Technologies. See the Cookies section for choices about cookies and other analytics and advertising controls.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal data;
- If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
- If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
California rights
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.
Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by contacting us at privacypolicy@provenbase.com.
Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, email us at privacypolicy@provenbase.com or write us with your request at the mailing address below.
Right to Opt-Out. You have a right to opt-out from future “sales” of personal information. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” under those definitions. In the past 12 months, we may have sold any of the categories of personal information listed above. To opt-out from “sales” of personal information, please visit our “Do Not Sell My Personal Information” page. We do not knowingly sell the personal information of minors under 16 years of age.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, for example, we may ask you to provide your first and last name and an email address.
Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by contacting us at privacypolicy@provenbase.com.
Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, email us at privacypolicy@provenbase.com or write us with your request at the mailing address below.
Right to Opt-Out. You have a right to opt-out from future “sales” of personal information. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” under those definitions. In the past 12 months, we may have sold any of the categories of personal information listed above. To opt-out from “sales” of personal information, please visit our “Do Not Sell My Personal Information” page. We do not knowingly sell the personal information of minors under 16 years of age.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, for example, we may ask you to provide your first and last name and an email address.
Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Retention of personal data
We retain personal data for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.
Location of personal data
The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this statement is processed according to the provisions of this statement and applicable law wherever the data is located. Location of Processing European Personal Data. We transfer personal data from the European Economic Area (EEA), UK, and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Security of personal data
We take reasonable and appropriate steps to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction.
To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
Changes to this privacy statement
We will update this privacy statement when necessary to reflect changes in our products, how we use personal data, or the applicable law. When we post changes to the statement, we will revise the "Last Updated" date at the top of the statement. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.
How to contact us
If you have a privacy concern, complaint, or a question for ProvenBase, Inc., or to contact our Data Protection Officer, please contact us at privacypolicy@provenbase.com
Our address is 4000 Legato Road, Suite 1100, Fairfax, Virginia 22033, United States. Telephone: 1-(877)-213-7413.
Our address is 4000 Legato Road, Suite 1100, Fairfax, Virginia 22033, United States. Telephone: 1-(877)-213-7413.
- Personal data we collect
- Cookies, Mobile ID’s and similar technologies
- Our use of personal data
- Our sharing of personal data
- Choice and control of personal data
- European data protection rights
- California privacy rights
- Retention of personal data
- Location of personal data
- Security of personal data
- Changes to this privacy statement
- How to contact us
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