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WAVELY PRIVACY POLICY

Last Updated: March 30, 2020

This Privacy Policy explains how Face Hired, Inc. and its subsidiaries and affiliated companies (“Wavely” , “we” or “us”) collects, uses, and discloses personal information about you when you use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), shop in our stores, contact our customer service team, engage with us on social media, or otherwise interact with us. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

COLLECTION OF INFORMATION

Information You Provide to Us

We collect personal information you provide directly to us. For example, you share information directly with us when you create an account, submit or post content through our Services, fill out a form, (e.g., with demographic data or salary), respond to a survey, or submit a resume or fill out a job application on our Services, communicate with us via third party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, city or area, phone number, education background, work experience, skills, photo, the information in your chats with other users, and any other information you choose to provide. If you create an employer account us, the information we collect includes name and title, employer name and location, available jobs, the information in your chats with other users and other information you choose to provide to or through the Services.

Other Information We Collect When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect information about you, including:

  • Activity Information: We collect information about your activity on our Services, including our sites, app and platform technology, such as your content views or ad clicks, searches, pages visited, or communications with other users through our Services.
  • Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version.
  • Location Information: In accordance with your device permissions, we may also collect information about the precise location of your device. You may stop the collection of precise location information at any time (see Your Choices below for details).
  • Information Collected by Cookies and Similar Tracking Technologies:We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.

Information We Collect from Other Sources

We may also obtain information about you from other sources. For example, we may collect information, including personal data (e.g., your job title and work email address) about you from third parties, such as when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us with job application data, or identity verification services, credit bureaus, social media, and publicly available sources. Additionally, if you create or log into your Wavely account through a third-party platform, we will have access to certain information from that site, such as your name, email address, birthday and profile picture, in accordance with the authorization procedures determined by such third-party platform.

Information We Derive

We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address or infer that you are looking for certain types of job positions or candidates based on your browsing behavior.

USE OF INFORMATION

We use the information we collect to authorize access to our Services. We also use the information we collect to:

  • Provide, maintain and improve our products and services to you (whether as a job seeker or an employer), such as facilitating communications between you and other users of the Services, for example enabling the Services’ chat feature between an employer and job seeker;
  • Process transactions and send you related information, including confirmations, receipts, invoices, customers experience surveys, and recall notices;
  • Send you technical notices, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
  • Communicate with you about products, services, and events offered by Wavely and others, and provide news and information we think will interest you (see Your Choices below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Conduct research and development for our Services to personalize your online experience and the advertisements you see when you use our Services or third-party platforms based on your preferences, interests, and browsing and (if applicable) purchasing behavior and your interactions with our online ads, including by counting ad impressions and verifying positioning and quality of ad impressions, for providing you and others with a better, more intuitive and personalized experience while driving membership growth and engagement on our Services;
  • Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
  • Detect, investigate and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Wavely and others;
  • Debug to identify and repair errors in our Services;
  • Comply with our legal and financial obligations;
  • For reasonable internal uses that are aligned with your relationship with us and the context in which we collected the information; and
  • Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

  • With vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising;
  • With other users of our Services, such as if you submit a product review or post content in a public area of our Services;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
  • If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Wavely or others;
  • With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Wavely and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
  • With your consent, at your direction or as otherwise permitted by law.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

SOCIAL SHARING FEATURES

Our Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Wavely and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. For these analytics purposes we use Google Analytics, which is a Google service that collects aggregate information about use of the Services and reports website trends. Google Analytics does not directly identify individual users.

We also work with third parties to serve ads to you as part of customized campaigns on third party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or third party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interest. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

Wavely is headquartered in the United States and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may update and correct certain account information you provide to us at any time by logging into your account, emailing us at  support@wavely.com. If you wish to deactivate your account, please email us at support@wavely.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you.

Location Information

When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, some of our Services may no longer function properly. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of some of our Services. For more information about cookies and how to disable them, see our  Cookie Policy.

Advertising and Analytics Services

You can learn about Google’s practices and opt out by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at  https://tools.google.com/dlpage/gaoptout. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. For more information about interest-based ads, please visit www.aboutads.info/choices. In addition, if you are located in the European Economic Area, the United Kingdom or Switzerland, please visit http://www.youronlinechoices.eu/ for more information on ways to opt out.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Wavely by following the instructions in those communications or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

We do not sell your personal information. In the preceding 12 months, we have collected the following categories of personal information:

CCPA Personal Information CategorySources of this Information
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)Information you provide directly or through your interactions with our Services or partners (each as defined or described in our Privacy Policy) Vendors that provide information to help us serve members relevant ads and understand the ads’ effectiveness

Information from other Wavely members or customers
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”)Information you provide to us directly and inferences we make based on that information

Information from our customers
Commercial information (e.g., information regarding products or services purchased, obtained, or considered)Information you provide to us directly, such as to buy a premium service

Your interactions with our Services

Information from our partners and customers
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)Your interactions with our Services

Your visits to third party sites that offer our autofill, follow or other functionality, as needed for fraud prevention and security purposes.
Geolocation DataInformation you provide to us directly or through your interactions with our Services, as explained in the Privacy Policy
Professional or Employment-Related InformationInformation you provide to us directly

Information from our customers or partners
InferencesInformation you provide to us directly or through your interactions with our Services

Information from our customers and partners
Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number)Information you provide directly or through your interactions with our Services

Information from our customers or partners
Audio, Electronic, Visual or Similar InformationInformation you provide directly or through your interactions with our Services, customers or partners

For examples of the precise data points we collect and the sources of such collection, please see Collection of Information  above. We collect personal information for the business and commercial purposes described in Use of Information  above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal InformationCategories of Recipients
Professional or Employment-Related InformationService Providers
Internet or Other Electronic Network Activity InformationService Providers
InferencesService Providers
Geolocation DataService Providers
Audio, Electronic, Visual or Similar InformationService Providers

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not to be discriminated against for exercising these rights. As we do not sell personal information, there is no opting out of “sales”, but you may make the other requests by calling (650)260-4688 or emailing us at support@wavely.com. We will verify your request by asking you to provide information related to your recent interactions with us, such as information regarding a recent job posting view or interaction with another user through Wavely. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

Shine the Light

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request certain details about how their information is shared with third parties for direct marketing purposes.We do not share any personal information of our customers with third parties for their direct marketing purposes.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area, the United Kingdom or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

  • To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products you have ordered).
  • When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain and improve our products and services, conduct data analytics, and communicate with you).
  • When we find such processing is necessary to comply with a legal obligation to which we are subject (e.g., to maintain a record of your consents and track those who have opted-out of marketing communications).
  • When we have your consent to do so (e.g., when you agree to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data for as long as is necessary for the purpose(s) for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

You have the right to request access to the personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, email us at  support@wavely.com.

Questions or Complaints

you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. Contact details of your Data Protection Authority can be found using the links below:

For individuals in the EEA: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

For individuals in the UK: https://ico.org.uk/global/contact-us/.

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: support@wavely.com.