This Privacy Policy (“Privacy Policy”) sets forth the general rules and policies of PeopleCaddie (“PeopleCaddie”, “we”, “us”, and “our”) regarding the collection, use, and disclosure of certain information arising out of your access and use of the PeopleCaddie website www.peoplecaddie.com (the “Site”), or mobile applications (each, an “App” or collectively “Apps”), (Apps and Site, collectively, the “Sites”), and any other websites, features, applications, widgets or online services that are owned or controlled by PeopleCaddie (collectively with the Sites, the “Services”), as well as any information PeopleCaddie collects offline in connection with the Services. PeopleCaddie matches employers with skilled, professional contractors. Please read this Privacy Policy carefully to understand how we treat your information and how you can control your preferences.

1. INFORMATION COLLECTION

Users of the Services may be “Clients” (anyone utilizing the Sites to request services to be performed by a Contractor) or “Contractors” (any company, individual user, or groups of associated individual users or companies utilizing the Sites to offer services to Clients). Contractors may also operate as an “Agency” (a legally recognized entity with the ability to hire and/or contract) with other Contractors.

You may choose whether or not to disclose Personal Information in connection with your use of the Services. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Services, but you may be unable to access or use certain features, options, programs, products, and services. “Personal Information” includes both Personally Identifiable Information (defined below) and Non-Identifying Information (defined below) collected by our Services or provided by you through our Services.

(a) Information You Provide to Us

• Personally Identifiable Information: In the course of using the Services (whether as a Client or Contractor), we, our Clients, and third-party service providers may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you as defined by applicable laws (“Personally Identifiable Information”). Examples of Personally Identifiable Information include your name, email address, physical address, billing address, phone number, date of birth, driver’s license information, personal photo, educational and employment history, job history, credit card or other financial account information, taxpayer identification number, and communications you send to us (including all information submitted through your resume or CV).

• Non-Identifying Information: We may collect other information that does not identify you, including demographic data, web browser type, device type, operating system version, information regarding your use of the Services, general project-related data, and, if applicable, mobile device carrier (“Non-Identifying Information”). We may aggregate information collected from registered and non-registered users (“Users”).

• User Profile: In the course of using the Services, you may create or PeopleCaddie may create a profile for you which may contain information about you, including Personal Information, photographs, examples of your work, information on work previously performed through and outside the Services, skills, Rating (defined in the Terms of Use) and other information, including your username (“Profile”). The information in your Profile may be visible to certain other Users. You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. However, Contractors are unable to remove the Rating allocated to them by Clients. Clients and Agencies of associated individual Users or companies may also have the opportunity to create an organization Profile.

(b) Information Received from Third Parties

We may use third-party service providers to provide us information, analyses, and reports about the use of our Services and to enable you to interact with us or other Users of our Services.

(c) Information Collected from Users Automatically

We and/or our third-party service providers, such as analytics companies and third-party content providers, may automatically collect certain information which may include, but is not limited to search terms you entered into a search engine that led you to the Services, the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Services. We do this to improve our Services, and for other internal business purposes.

2. WHEN PERSONAL INFORMATION IS COLLECTED

(a) Contact Information

In various areas of our Services, we provide you the opportunity to submit contact information such as your name, email, address, and phone number. We process this Personal Information only as necessary to provide our Services, to further our legitimate interests in protecting our Services and content, and in accordance with our relationship with our Clients. When you submit this Personal Information, you may also be given the opportunity to subscribe to newsletters or consent to receive marketing materials and other communications from us. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to [email protected]. Please note that even if you opt out of receiving the foregoing emails, you cannot opt out of receiving transactional emails related to our Services.

(b) User Submissions

Our Services allow Users to upload Personal Information, and related information, in connection with submitting their resume to our Clients for consideration of employment. If you submit Personal Information in connection with your resume or CV, you may disclose certain Personal Information to us and our Clients as a product of your submission. We use commercially reasonable efforts to ensure the appropriate administrative, physical, and technical safeguards are in place as it relates to the Personal Information you provide through our Services as part of any submission.

(c) Personal Information You Disclose Relating to Others

Our Services may allow you to disclose Personal Information relating to another person (for example, an employment reference). If you disclose any Personal Information relating to other people in connection with our Services, you represent to us that you have the right and authority to (i) submit that information to us, and (ii) permit us and our third-party service providers to manage, process, use, and disclose that information in accordance with this Privacy Policy.

(d) Third-Party Providers

Please note that we may use certain third-party service providers on our Services to enhance your experience or deliver certain features, functionality, products, and services to you. These third-party service providers may collect Personal Information about you when they are performing services on our behalf and/or when you are using certain functions on our Services that are operated by these third parties. Any information, including Personal Information, collected by such third-party service providers will be subject to those third parties’ privacy notices or privacy policies, rather than this Privacy Policy.

3. HOW PEOPLECADDIE USES INFORMATION

If you submit or we collect Personal Information through our Services, then such Personal Information may be used to:

• Provide, analyze, administer, and improve our Services and related services;

• Contact you in connection with our Services and in connection with certain other services;

• Send you recommendations, updates, and other materials that you have requested;

• Obtain additional information about you from third parties;

• Provide customer service;

• Investigate and address fraud;

• Contact you through email;

• Fulfill our responsibilities to our Clients;

• Protect our rights, our property, or the rights of third parties including our Clients; and

• Ensure the technical functionality and security of our Services.

4. COOKIES AND SIMILAR TECHNOLOGIES

Our Sites may collect certain kinds of information through the use of cookies or other various tracking methods. A cookie is a small piece of data that is stored by your web browser on your computer or mobile device. Cookies may be used for many purposes, including, but not limited to, remembering you and your preferences and tracking your usage in order to improve our Services. Cookies themselves do not typically contain any Personal Information. Most web browsers automatically accept cookies; however, you can usually change your browser settings to refuse all cookies or indicate when a cookie is being sent. Please note that if you choose to disable cookies, some parts of the Sites may not function properly or may be considerably slower, or there may be some features that will not be available to you.

(a) Google Analytics

Google Analytics is a Google tool that we use for web analysis and allows us to understand how Users engage with our Website and other Sites. Google Analytics may use cookies to collect Non-Personally Identifiable Information. For more information on Google Analytics, please visit www.google.com/policies/privacy/partners/.

(b) Other Types of Cookies

• Strictly Necessary Cookies: These cookies may be used to make sure our Sites work and that you can use them effectively, such as remembering certain information on a form when you go to another page before the form has been completed. These cookies are not used to gather information that could be used to advertise products or services to you, or to remember any preferences you have set beyond the current visit. If you prevent these cookies you may not be able to use certain features on our Sites.

• Performance Cookies: These cookies may be used to measure the performance of our Sites, improve how our Sites work, and measure our marketing activity. Information that is collected using these cookies is aggregated and anonymous and we are not able to identify individual users. We do not use these cookies to target you with advertising on other websites, or to remember any preferences you have set beyond the current visit.

• Functionality Cookies: These cookies allow websites to remember choices you make (for example, your username, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services on the Sites such as watching a video. We use these cookies to remember settings you've applied such as layout and text size and remember if you have already completed an online survey. We do not use these cookies to target you with advertising or track your browsing activity on other websites.

• Advertising Cookies: These cookies may be used to deliver relevant advertising messages to you, limit the number of times you see an advertisement and help measure the effectiveness of an advertising campaign. These cookies are used to identify that you have visited our Sites, so that we can show you relevant advertisements and provide advertising networks with information on your visit so that they can present you with advertisements that you may be interested in.

(b) Other Tracking Methods

• Location Data: We may collect and use location information provided by your mobile device, which can be either precise or imprecise. Precise location data includes Global Position System (GPS) data as well as geolocation data identifying nearby cell towers and Wi-Fi hotspots that we collect when you enable location-based products or features. Imprecise location data includes locations derived from your IP address or other less precise location data, such as at a city, state, or postal code. If we collect location information, we may use the location information to continue to enhance and provide you with our Services and to improve the functionality of our Sites and our service centers.

• Web Beacons: We, our marketing partners, affiliates, analytics, and service providers may employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Services is effective and to provide you with relevant advertising. Web beacons are small graphics with a unique identifier that may be invisible to you used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Sites, monitor how Users navigate our Sites, track the number of sent emails that were actually opened, or to track how many particular articles or links were viewed.

5. OUR COMMITMENT TO CHILDREN’S PRIVACY

The Services are not directed to persons under 18 years of age, and as such, PeopleCaddie does not collect information from children under 13 years of age. If you are under the age of 13, please DO NOT USE the Sites. We do not accept registration from children under 13 years of age and no one under the age of 13 may provide any information to or through our Sites. No personally identifiable information (as defined in the COPPA, 15 U.S.C. Section 6501) is purposefully or knowingly collected from children under the age of 13 by our Services without verifiable parental consent. If you are a parent or guardian of a child under 13 years of age, and believe that your child has disclosed Personal Information to us, please contact us at the address below. If we learn that we have collected or received Personal Information of persons under 13 years of age without verification of parental consent, we will exercise commercially reasonable efforts to promptly delete this information.

6. DATA FROM USERS OUTSIDE OF THE UNITED STATES

Personal Information collected through or on our Services may be stored and processed in the United States or any other country in which PeopleCaddie or its affiliates, subsidiaries, or agents maintain facilities, and by using the Sites you consent to any such transfer of information outside of your country. Individuals outside the United States who disclose any data, including Personal Information, through any of our Services hereby acknowledge and consent to such data being stored in the United States or any other country, and transferred outside your country. While these countries may not offer the same level of privacy protection as your own country, we commit to uphold the privacy protections as described in this Privacy Policy.

7. SECURITY OF YOUR INFORMATION

The security of your Personal Information is very important to us, and PeopleCaddie takes reasonable steps to protect the information you provide us from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We follow generally accepted industry standards to safeguard your information, however, no data or email transmission is ever fully secure or error free. Additionally, alerts and reminders sent to your mobile device are also not encrypted. Therefore, please take special care in deciding what information to send us. While we have reasonable safeguards in place to protect your information, we cannot guarantee the absolute security of Personal Information on our Services.

8. WHEN PEOPLECADDIE DISCLOSES INFORMATION

We do not sell, lease, rent or otherwise disclose Personal Information with third parties unless stated in this Privacy Policy or unless you have otherwise provided your consent. However, there are certain circumstances in which we may share your Personal Information such as:

• Use by Third-Party Providers: Personal Information may be transferred to a third party (such as an agent, consultant, or service provider) acting for or on behalf of PeopleCaddie, or in connection with PeopleCaddie’s business. These third parties perform tasks on our behalf and assist us in providing our Services and a high-quality user experience. We use commercially reasonable efforts to only engage with third-party service providers that post a publicly available privacy notice or privacy policy.

• Use by Affiliates: We may share your Personal Information with our parent, affiliates and subsidiaries for purposes consistent with this Privacy Policy.

• Use by Clients and Agencies: Where a Client has engaged us, we may share Personal Information collected in accordance with your use of the Services, including your expression of interest in a position with a Client, including work and educational history, in accordance with a separate agreement. Note that if a Contractor is suspended from the Services, we may share that information with Clients for whom that Contractor has worked or applied for work. We may also share information with Agencies to whom Contractor is associated for a particular work project. If you choose to apply for work as a Contractor via the Services, we will share information relevant to your application with the applicable Client(s), including, but not limited to, the information contained in your Contractor Profile. Further, if you choose to opt in for your information to be marketed directly to Clients and Agencies, without first applying for a specific job posting, we will share your Personal Information with Clients and Agencies. You may opt out of being marketed to Clients and Agencies at any time.

• Use by Advertisers: From time-to-time, we may engage third parties to provide advertising services to assist us in advertising our brand and our Services. Those advertising services may target advertisements on third-party websites based on cookies or other information indicating previous interaction with our Services.

• Compliance with Law: We may disclose User information if required to do so by law or in the good-faith belief that such action is necessary to comply with state or federal laws. We may access and use your Personal Information to contact you if necessary, and we may access, use and/or disclose your Personal Information in response to a valid court order, subpoena, government investigation, or if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the requirements of the law or comply with legal process served on us; (b) protect and defend our rights or property, including our affiliates, as well as the rights and properties of our users; or (c) act under exigent circumstances to protect the personal safety of PeopleCaddie, our Users, or others.

• In the Event of Merger or Sale: In the event that PeopleCaddie is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information, including Personal Information, that we have collected from Users as part of such merger, acquisition, sale, or other change of control.

9. YOUR CHOICES

You may decline to provide any Personal Information to us while visiting and using our Services. If you choose not to provide any Personal Information, you may not be able to use a Site or App or certain aspects of a Site or App, and we will not be able to provide you some of the features and functionality found on a Site or available through an App.

You may change your mind regarding a prior authorization for use or disclosure of your Personal Information and notify us of such revocation, in writing, by sending an email to [email protected]. Such notice will be effective upon receipt by PeopleCaddie but will not change or affect any actions that PeopleCaddie took, in reliance upon the prior authorization, before the revocation was received.

If you wish to access, amend, update, or delete your Personal Information, please contact us at the address shown below. We will use commercially reasonable efforts to honor your request; however, certain information will actively persist on the Services even if you close your account. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Services. Please note that neither you nor PeopleCaddie can delete all copies of information that has been previously shared with others on the Services.

10. RETENTION OF PERSONAL INFORMATION

We reserve the right to retain any Personal Information provided by you or collected through the Services as long as the Personal Information is necessary to: (i) fulfill the purposes described in this Privacy Policy; (ii) satisfy any legal, regulatory, accounting or reporting requirements; and (iii) comply with applicable law. In some circumstances, we may de-identify, aggregate, or otherwise anonymize your Personal Information consistent with applicable laws and industry standards so that it can no longer be associated with you, in which case it is no longer treated as Personal Information.

11. OTHER SITES AND SENDING INFORMATION TO THIRD PARTIES

This Privacy Policy covers only the Sites and does not apply to any other third-party website. The Sites may contain links or references to other websites. We encourage you to read the terms and conditions and privacy policy of any third-party website that you visit or use. We encourage you to exercise caution when providing Personal Information to third-parties. We have no control over the security of any information that you transmit to a third-party outside of the Sites. PeopleCaddie has no control over the privacy practices employed by any third-party website, products or services and cannot be responsible for the protection and privacy of any information that you provide while visiting such websites or outside of the Sites.

12. CALIFORNIA PRIVACY RIGHTS AND ONLINE TRACKING

This section applies to our collection and use of “Personal Information”, as defined under California law, if you are a resident of California.

(a) Categories of Personal Information Collected, Used, and Disclosed

In accordance with California law, we collected the following categories of Personal Information within the preceding 12 months:

• Identifiers such as your name, alias, email address, mailing address, IP address, and online identifiers;

• Certain categories of Personal Information described in subdivision (e) of California Civil Code Section 1798.80;

• Internet or other electronic network activity information, including information on your usage of our Services;

• Information used to create a profile about a consumer reflecting the consumer’s preferences or behavior;

• Professional or employment-related information;

• Geolocation data; and

• Commercial information.

We do not sell Personal Information. We may disclose each of these categories of Personal Information with our service providers, but only to the extent necessary for them to facilitate our business purposes (including any purpose specified in Section 8, above).

(b) Your California Privacy Rights

If you are a resident of California, you have the following rights:

• Right to Know: You may have the right to request information on the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request information on the categories of Personal Information that were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.

• Right to Delete: You may have a right to request us to delete Personal Information that we collected from you. Please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your Personal Information for certain purposes, including without limitation, to comply with applicable law or legal obligations, or to exercise rights under the law.

• Right to Opt Out: You may have a right to opt-out of certain disclosures of Personal Information to third parties, if such disclosures constitute a “sale” under California law. As noted above, we enable advertisers to collect certain information from our Services, which the advertisers may use to improve their interest-based advertising networks. Regardless of whether this is a “sale,” you may opt-out of interest-based advertising by visiting the Network Advertising Initiative’s Opt-out page or YourAdChoices, provided by the Digital Advertising Alliance.

(c) Exercising Your California Privacy Rights

If you would like to exercise your rights listed above, please contact us at [email protected]. When doing so, please tell us which right you are exercising and provide us with contact information to direct our response.

We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.

You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

13. DO NOT TRACK

PeopleCaddie does not interpret or respond to “Do Not Track” signals. Consequently, PeopleCaddie will not store or use information about any other websites you visit, other than our Sites.

14. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be revised periodically, and this will be reflected by a “last modified” date below. Please revisit this page to stay aware of any changes. In general, we only use your Personal Information in the manner described in the Privacy Policy in effect when we received such information. Your continued use of the Services constitutes your agreement to this Privacy Policy and to later revisions.

For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of Personal Information you have provided to us, we will make reasonable efforts to notify you and obtain your consent before implementing such revisions with respect to such information.

15. CONTACT US

Please contact us with any questions or comments about this Privacy Policy at:

PeopleCaddie
c/o Privacy Officer
5600 River Road, Suite 800
Rosemont, Illinois 60018