Last Updated and Effective as of: January 1, 2022
- We collect Personally Identifiable Information (as defined below) from users of our Website, Platform and Services when it is voluntarily provided to us by you or by our customers and use it for the purposes for which it was provided (see Information We Collect Directly).
- In order to provide our Services to our customers, we may obtain information about you from public sources such as posts or other content publicly available on social networks, blogs or other websites. Our customers may also provide us information about their hiring practices which may contain some Personally Identifiable Information and information about your employment or job applicant history with them (“Service Data”). We will only use such Service Data on behalf of our customer that provided us that information in order to provide them our Services. (see Information We Receive To Provide Our Services To Our Customers).
- We automatically collect information from users of our Website, Platform and Services for analytical or advertising purposes [DG2] (see Information We Collect Automatically).
Depending on the jurisdiction in which you reside, you may have certain rights over your access to or our processing of your information (see Jurisdiction Specific Notices and Rights).
Information We Collect Directly: [DG3]
We may collect information, including Personally Identifiable Information, from you when you provide such information to us directly, such as when you register an account with us, send us an email, sign up to receive marketing communications from us or you otherwise interact with us on the Website, Platform or through the Services. Our customers may also provide your information to us when they upload such information to our Platform or Services. “Personally Identifiable Information” is information that specifically identifies you. Categories of Personally Identifiable Information we collect directly from you include:
o Identity data, which includes name or other similar identifiers, such as your social media user handle
o Contact data, which includes work address, email and telephone number.
o Marketing and Communications data, which includes your preferences in receiving marketing from us.
o Profile data, which includes your job title and company name.
o Login credentials of authorized users of the Platform.
Information We Collect/Receive To Provide Our Services To Our Customers[DG4]
As described above, we may process certain information about you, including Service Data, on behalf of our customers in order to provide them our Platform and Services. Such information includes:
- Publicly Sourced Data that we collect from social networks, blogs or other websites: We may scan and analyze content and information from publicly available sources such as social media accounts, blogs and other websites in order to obtain information about potential job candidates for our customers. Such information may include the potential candidates’ contact information, job history, current employment information, educational background, interests, location and other profile information.
- Service Data that our customers provide us about your employment or job applicant history: In order to use our Platform and Services, our customers may provide us information about their current employment opportunities and qualifications or descriptions of such opportunities, their hiring histories, and the application information of any prospective candidates for such opportunities including, the candidates’ contact information, job history, current employment information, and educational background.
Information We Collect Automatically:[DG5]
Sinecure and our service providers may also automatically collect information from you when you visit our Website and use our Platform or Services through cookies and other tracking technologies. Such information does not directly identify you as an individual and may include:
- Cookies and Similar Technology
In addition to the tracking technologies described below under “Clickstream” and “Site and Platform Analytics”, we also use the following cookies, tags and trackers:
first & third party
Used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect certain information, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Click here for more information on Google Analytics:
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website, how visitors navigate throughout the Website and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Website, Platform and our Services.
- Site and Platform Analytics
How We Use Your Information
We use your information as described herein including for the following purposes:
- to contact you about and provide you with our Services, and, with respect to Service Data, solely to process on behalf of our customer that provided us that information in order to provide them with our Services,
- to personalize your experience with us including by presenting products or offers tailored to you,
- to help maintain the safety, security, and integrity of our Website, Platform, Services, databases and other technology assets, and business,
- for internal research for technological development and demonstration and to improve, upgrade or enhance our Website, Platform and Services,
- for detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity,
- to respond to your direct inquiries,
- to add you to our mailing lists and send you emails from time to time,
- for any additional purposes that you specifically consent to [DG8]
How We Share Your Information[DG9]
Besides using your information ourselves, we may send your information to other companies, affiliates and third parties in the following instances:
- Customers. We may share your information with our customers to whom we provide our Services, including our recruitment and hiring analysis tools available on our Platform. In addition, we may share Service Data as directed by our customers to enable their use of our Services.
- Service Providers. We may share your information with third parties who may use your information to provide us services such as website hosting, data analysis, infrastructure provision, information technology services, customer service, e-mail delivery services, auditing, and anti-fraud monitoring. These third parties may have access to Personally Identifiable Information or other information that is necessary to perform their functions.
- Legal Compliance and to Defend Our Rights. We may disclose Personally Identifiable Information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- Business Transfers. We may share your Personally Identifiable Information and other information with third parties in connection with a corporate restructuring, acquisition or divestiture.
- Business and Advertising Partners. We may share aggregated information with our business and advertising partners, in a form whereby the shared information will not contain nor be linked to any Personally Identifiable Information, to improve and enhance your experience using the Website, Platform and Services, our market research activities and to serve targeted advertising to you.
Please note that if you specifically consent to additional uses of your Personally Identifiable Information, we may use your Personally Identifiable Information in a manner consistent with that consent.
We may ourselves, or with third party vendors, use information we collect or vendor information to deliver targeted advertising to you when you visit other websites or use our Website, Platform or Services. Cookies, clickstream data, and other similar technologies described above may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “behavioral advertising,” which enables us and our vendors to know your interests in connection with the delivery of that specific ad. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt out of these interest-based advertisements, please follow the opt-out process described below under “Opt-Out.”[DG10]
The security of your information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. [DG11] However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Sinecure, or information stored on the Website, the Platform, our Services or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Website, Platform or Services demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personally Identifiable Information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact section below.
We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website, Platform or Services and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregated data previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
Protection for Children
Our Website, Platform and Services are intended for ages 18 and over. We do not knowingly collect Personally Identifiable Information from minors. When we become aware that Personally Identifiable Information (or other information that is protected under applicable law) from a child under 13 (or such other age as may be restricted under local law) has been collected, we will use all reasonable efforts to delete such information from our database. If you believe we might have any Personally Identifiable Information from or about a child under 13, please contact us at email@example.com.
Other Websites and Social Networking Services
As a convenience to you, we may provide links to third party websites, apps or services from within the Website, Platform or Services. We are not responsible for the privacy practices or content of these third party sites, and by providing a link we are not endorsing or promoting such third party sites. When you navigate away from our Website, Platform or Services, you do so at your own risk. We encourage you to read the policies and terms of every website, app or service you visit.
The Website, Platform or Services may integrate with social networking services. We do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, Platform or Services, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
You should be aware that Personally Identifiable Information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your Personally Identifiable Information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
If you are located in the European Union or the European Economic Area or a resident of California or Nevada, please see “Jurisdiction Specific Notices and Rights” for additional rights you have under applicable law.
To opt-out of any future promotional messages from us, you should send an unsubscribe request to us at firstname.lastname@example.org. We will process your request within a reasonable time after receipt.
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. You can opt-out of targeted advertising from certain providers that participate in the Digital Advertising Alliance (DAA) program at www.aboutads.info/consumers. Other providers are members of the Network Advertising Initiative, and you can opt-out of interest-based advertising by those members by visiting http://optout.networkadvertising.org/. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities.
For targeted advertisements delivered through mobile apps, you can install the DAA’s AppChoices app on your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices or “Opt-out of Interest-based ads” on Android devices).
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or Platform or some of its functionality may be affected.
Please note that, unless required by law, we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
Jurisdiction Specific Notices and Rights:
California Privacy Rights
We collect information (some of which may also constitute Personally Identifiable Information) that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “personal information.” If you are a California consumer, as defined by CCPA, the CCPA provides you with specific rights regarding your personal information. This section describes the rights that California consumers have and explains how to exercise those rights. For the purposes of this section, personal information does not include (i) information that is lawfully made available from federal, state or local government records, (ii) de-identified or aggregated data or (iii) information excluded from the scope of the CCPA.
Personal Information We Collect
In the past 12 months, we have collected the following categories of personal information for the purposes described in How We Use Your Information above:
o Personal identifiers, which includes name or other similar identifiers, such as your social media user handle or account login credentials and contact information, which includes address, email or telephone number. We obtain this information from you directly or from our customers when they upload such information to the Platform or Services.
o Marketing and communications data, which includes your preferences in receiving marketing from us and the content of your communications to us that you provide us directly.
o Professional or employment-related information, which includes your job title, company name, work address, work email and work telephone number, resume and job experience and history which our customers or authorized users may upload to the Platform.
o Internet activity information such as technical data including IP address, your internet service provider, browser type, operating system or language settings and usage data such as information about how you use our Services, your access times, pages you viewed, routes by which you access our Services and your use of hyperlinks within our Service. This information may be collected through cookies and other tracking technologies we may use on our Website, Platform or Services as described above in Information We Collect Automatically.
o Publicly available content, such as your public blog posts or social media content. We may collect such information from publicly available sources as described above in Information We Collect/Receive To Provide Our Services To Our Customers.
o Inferences drawn from other personal information such as job skills and qualifications for certain career opportunities and career interests which we may make based on the personal information we may collect or receive as described above.
Personal Information We Share
In the past 12 months, we have disclosed the following categories of personal information for a business purpose to the third parties for the purposes described in the section How We Share Your Information above:
- Personal Identifiers, with our customers and service providers.
- Professional or employment-related information, with our customers and service providers.
- Internet activity information, with our service providers and business and advertising partners.
- Publicly available content, with our customers, service providers and business and advertising partners.
- Inferences drawn from other personal information with our customers.
Personal Information We Sell
We do not sell your personal information for monetary consideration. However, in the preceding twelve (12) months, we have made disclosures of certain personal information to third parties that may be considered a “sale” (as that term is defined in the CCPA) for the purposes described in the section How We Share Your Information above, including the following:
- Personal Identifiers, to our customers.
- Professional or employment-related information, to our customers.
- Internet activity information, to our business and advertising partners.
- Publicly available content, to our customers and business and advertising partners.
- Inferences drawn from other personal information, to our customers.
Rights to Your Information
- Right to Know: As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:
o The categories of personal information we collected about you.
o The categories of sources from which the personal information is collected.
o Our business or commercial purpose for collecting or selling that personal information.
o The categories of third parties with whom we share that personal information.
o The specific pieces of personal information we collected about you (also called a data portability request).
- Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we maybe retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
- Exercising Access and Deletion Rights: To exercise the access and deletion rights described above, please submit a request to us by contacting us at email@example.com or by visiting explorator.sinecure.com.
Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above.
The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative of that person.
For more information about verification, see Response Timing and Format immediately below.
- Response Timing and Format: We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.
- Personal Information Sales Opt-Out and Opt-In Rights: The CCPA provides California consumers the right to direct businesses to not sell their personal information at any time (the “right to opt-out”). Please note that we do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization.
You have the right to direct us to not sell your personal information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page:
[https://www.sinecure.ai with the title “Do Not Sell My Personal Information”]
Alternatively, you may submit an opt-out (or an opt-in) request by firstname.lastname@example.org.
- Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
California “Shine the Light”
We do not disclose your personal information, as defined under California Civil Code Section 1798.83 (“Shine the Light”), to third parties for their direct marketing purposes.
Nevada Privacy Rights
If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at email@example.com.
European Union / European Economic Area
To contact us, please see the section titled “Contact Us”.
If you have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance. If you have a complaint, please contact us here: firstname.lastname@example.org .
Legal Basis: We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have consented to a certain use of your personal data.
- Where we need to comply with a legal or regulatory obligation.
To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.
Provision of personal data and failure to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.
Data Transfer: We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR. Please contact us for more information about our data transfer methods.
Use of your personal data for marketing purposes: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your personal data for marketing purposes.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
Data Subject Rights: If you are a situated in the EU/EEA, under the GDPR, as a data subject, you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”).
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data in certain situations.
- Request the transfer of your personal data to you or to a third party in certain situations.
- Withdraw consent at any time where we are relying on consent to process your personal data.
- To object to decisions based on automatic decision making
To exercise your rights under the GDPR, please contact us at email@example.com. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
Changes to policy:
For questions or concerns relating to privacy, we can be contacted at: firstname.lastname@example.org
Our Website is maintained in the United States of America. If you are located outside the U.S., by using the Website, you authorize the export of your information to the USA and its storage and use as specified in this policy.