Privacy Policy

Introduction

Vobis, Inc., doing business as Vettd (“Vettd”) is committed to protecting your privacy. Using intelligent data science techniques including machine discovery, Vettd provides analytics for companies that have contracted for these services (“Subscriber Companies”) to enable them to make better decisions about their workforce and organization. We have prepared this Privacy Policy to describe to you our practices regarding the personal information we collect from users (“Users”) of our website located atwww.vettd.com (the “ Site”) and services (the “Services”) that enable Users or Subscriber Companies to submit resume(s) for analysis, for employment consideration, and for inclusion in talent pools of Subscriber Companies.

Table of Contents

Privacy Shield Compliance

Inquiries and Complaints

Types of Data We Collect

Information Provided to Us

Information Collected via Technology

Information Collected from Third Parties

Use of Your Personal information

Disclosure of Your Personal information

Email Communications

Changing or Deleting Your Personal Information

Security of Your Personal information

Compliance with Children’s Online Privacy Protection Act

Do Not Track Signals

Links to Other Sites

Inquiries and Complaints

Changes to This Privacy Policy

Questions

Privacy Shield Compliance

Vettd complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Vettd has certified to the Department of Commerce that it adheres to the Privacy Shield Principles for personal data submitted by our Users or Subscriber Companies in participating European countries in order to provide Services. Vettd is responsible for the processing of personal data it receives under the Privacy Shield Framework, including any personal data subsequently transferred to a third party acting as an agent on its behalf. Vettd complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ . We may also process personal data our Subscriber Companies submit relating to individuals in the EU via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.

The Federal Trade Commission has investigatory and enforcement jurisdiction over Vettd’s compliance with the Privacy Shield.

Types of Data We Collect

Information You or Subscriber Companies Provide to Us

We may collect personal information from you, such as your first and last name, e-mail, username and password when you create an account to log in to our network (“Account”).

When you upload or when a Subscriber Company sends us your resume or curriculum vitae or other personal background or qualification information (each, a “Resume”), we will collect your Resume to provide the Services.

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, to send you a reply.

When you participate in one of our surveys, we may collect additional profile information.

We may also collect personal information at other points in our Service that state that personal information is being collected.

Information Collected via Technology

Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP ”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends and User movement around the Site, administer the Site, gather demographic information about our User base, and better tailor our Services to our Users’ needs.

Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Service. This type of information is collected to make the Service more useful to you and to tailor the experience with us to meet your special interests and needs.

Collection of Data by Advertisers. We may also use third parties to serve ads on the Site. Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Site (but not your name, address, e-mail address or telephone number). They do this by using Cookies, Pixel Tags or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Site and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.aboutads.info/choices .

Traffic Analytics. We use a limited number of third-party service providers to help analyze how users use the Service (“ Analytics Companies”). These Analytics Companies use Cookies to collect information such as how often users visit the Service, and what other sites they used prior to coming to the Site. We use the information we get from these Analytics Companies only to improve our Site and Services. These Analytics Companies collect only the IP address assigned to you on the date you visit the Service, rather than your name or other personally identifying information. We may combine the information generated through the use of our Analytics Companies with your personal information. Although these Analytics Companies may plant a persistent Cookie on your web browser or mobile device to identify you as a unique user the next time you visit the Service, the Cookie cannot be used by anyone but the Analytics Company that placed the applicable Cookie. This Policy does not apply to and we are not responsible for the Cookies used by these Analytics Companies.

Information Collected from Third Parties

We collect information about you and other individuals from the following third-party sources: (i) third parties who license, sell or otherwise provide data they have collected; or (ii) information from publicly available sources, such as via the Internet and social networks.

Use of Your Personal information

Vettd processes data submitted by Users and Subscriber Companies for the purpose of providing Vettd’s Services to them and to Subscriber Companies. We use your personal information in the following ways:

· facilitate the creation of and secure your Account on our network;

· identify you as a user in our system;

· provide improved administration of our Services;

  • provide the Services;

· improve the quality of experience when you interact with our Services;

· send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

· send you administrative e-mail notifications, such as security or support and maintenance advisories;

· respond to your inquiries related to employment opportunities or other requests;

· send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Vettd.

Disclosure of Your Personal information

We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

o Subscriber Companies. When you use the Services, the personal information you provide will be shared with the Subscriber Companies that you designate to receive such information. Additionally, personal information provided to Vettd by Subscriber Companies may be analyzed or combined with other information and shared with the same Subscriber Companies as part of the Services.

o Third Party Service Providers. We may share your personal information with third-party service providers to: provide the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Vettd. These third-party service providers are required not to use your personal information other than to provide the services requested by Vettd.

o User Feedback. We often receive comments from Users who have had positive experiences with our Services. We may post User feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting your name with your feedback.

o Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

o Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

o Other Disclosures. Regardless of any choices you make regarding your personal information (as described below), Vettd may disclose personal information if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Vettd; (iii) to protect or defend the rights or property of Vettd or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Email Communications

We may periodically send you free newsletters and e-mails that directly promote the use of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Regardless of your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

Changing or Deleting Your Personal Information

You may change any of your personal information in your Account by editing your profile within your Account, by sending an updated Resume or Resumes, by deleting a Resume or Resumes you have submitted, or by sending an email to us at info@vettd.com. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.

Users within the scope of this Privacy Shield certification have certain legal rights to access certain personal data we hold about them and to obtain its correction, amendment or deletion. Those users may exercise some of those rights through the options described in this section. In some circumstances, Vettd has limited ability to identify and access individual personal data that our Subscriber Companies have submitted to the Services. If you wish to request access, to limit use, or to limit disclosure, we may first refer your request to the Subscriber Company who submitted your personal data, and we will support them as needed in responding to your request.

Security of Your Personal information

Vettd is committed to protecting the security of your personal information. We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Vettd uses reasonable efforts to protect your personal information, Vettd cannot guarantee its absolute security.

Compliance with Children’s Online Privacy Protection Act

Vettd does not target its offerings toward, and does not knowingly collect any personal information from users under 13 years of age. If Vettd learns that the User is a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: info@vettd.com.

Do Not Track Signals

Some web browsers may transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. When a standard is established, we may revise our policy on responding to these signals.

Links to Other Sites

This Privacy Policy applies solely to the information we collect on the Vettd website or via direct email and written communications

Users should be aware that you could be directed to other sites that are beyond our control. Vettd is not responsible for the privacy practices or the content of other websites that may be linked to this site.

There may be links to other sites from Vettd web pages that take you outside our website. These other sites may send their own cookies to users, collect data or solicit personal information. Personally identifying information which you choose to provide to another party or website will not be subject to this Privacy Policy.

Inquiries and Complaints

Vettd is committed to resolving complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints regarding this privacy policy should first contact Vettd at info@vettd.com or in writing at the address below:

Vobis, Inc. d/b/a Vettd Attn: Privacy Office, 11820 Northup Way #200, Bellevue, WA 98005

Vettd has further committed to refer unresolved Privacy Shield complaints to JAMS, an independent alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your Privacy Shield complaint from us, or if we have not resolved your Privacy Shield complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Vettd also commits to cooperate with competent EU data protection authorities (DPAs) with regard to our Subscriber Companies’ human resources data transferred from a European country participating in the Privacy Shield in the context of the employment relationship.

Under certain conditions, you may have the ability to invoke binding arbitration for complaints regarding Privacy Shield compliance that have not resolved by either Vettd or our independent dispute resolution provider. Please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction for additional information.

Changes to This Privacy Policy

This Privacy Policy may be updated to reflect changing business or regulatory conditions. If we make any material changes in the way we use your personal information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. If the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes.

Questions

Any questions about this Privacy Policy should be addressed to info@vettd.com or by postal mail at:

Vettd

Attn: Privacy Office

11820 Northup Way #200, Bellevue, WA 98005

Updated on 17 August 2017.

Vettd

Resources

Contact