Last updated: January 1, 2020
The Suite is a private career management & networking platform for executives.
-We collect information related to your use of the Site.
-Such information is used to provide you the services on the Site.
1. Please Read the Entire Policy.
Please read the entire policy and make sure you fully understand our practices before using our services. If you do not agree with our practices you must immediately leave the Site. If you have any questions after fully reading the policy, please contact us at: firstname.lastname@example.org.
2. Information We Collect
We collect two types of information from visitors. The first, unidentified and non-identifiable information (“Anonymous Information”) does not enable The Suite to identify the visitor from whom it was collected. The Anonymous Information that The Suite may collect consists of: (1) the date, time and length of your visit, including how much content you viewed (in the aggregate); (2) your Internet browser, operating system or Internet service provider; (3) what parts of the website or app you used and for how long; and (4) the referring site, advertisement or email linking to and from the Site. The Suite may, from time to time, also collect information regarding your wireless device (if any). We may collect information about your wireless device and your wireless communications carrier. The Suite may aggregate, use and share Anonymous Information with third parties for marketing and advertising purposes.
Our Site does not require any personal information to be accessed. However, you have the option to submit your information to apply to be a member of The Suite, which we use to screen new applicants and may use to send infrequent announcements about major updates. You will also need to provide this information in order to access and use our platform. Your first and last name, email address, specific career history, and Linkedin Profile, is individually identifiable information, meaning information that can identify an individual or may, with reasonable efforts, lead to the identification of an individual (“PII”). PII may also be collected in creating a profile on the The Suite App. If any Anonymous Information is linked to PII, it is treated as PII as long as the connection exists.
When accessing The Suite’s platform, we will collect another form of data called Business data.
Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.We may receive information about you through The Suite. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, analytics providers, and search information providers) and may receive information about you from them.
When using one of our paid offerings, we may also ask for the following information:
-Credit card information (processed directly by our payments provider in a manner compliant with the Payment Card Industry (PCI) Data Security Standard)
3. How is Information Collected?
The Suite collects information about you only if we have a reason for such collection, such as to provide the services, email updates, or to improve our Site. Information is collected in three ways:
-(c) Information obtained from outside sources. You can learn about these practices in Section 6 below.
4. Information Collected
We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
-to process your application for membership;
-to provide you with our platform’s core features;
-to process any transactional or ongoing payments;
-to contact and communicate with you; and
-for internal record keeping and administrative purposes.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com and we will either delete your data from our systems or move your data to our "unsubscribe list". However, you acknowledge this will limit our ability to provide the best possible service to you.
4.1 Your Rights and Control
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.
Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
Correction: If you believe that any information we hold about you is inaccurate, out of data, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from marketing communications, please contact us using the details below, or opt-out using the opt-out facilities provided in the communication.
4.2 Legal basis for processing
We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
-it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
-it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, and to protect our legal rights and interests;
-you give us consent to do so for a specific purpose (for example, you might consent to us sending you marketing emails, or access member survey information); or
-we need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
4.3 Where is Information Stored?
The Suite uses industry standard technologies and best practices to safeguard your data (both Anonymous Data and PII) from unauthorized use and disclosure and to prohibit security breaches of the Site. Unfortunately, no website, computer system or online communication is completely secure. The Suite cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Site is at your own risk.
Data will be maintained, processed and stored by The Suite in the United States of America or other jurisdictions, as necessary, for proper delivery of the services or as required by law.
5. Users Outside the USA
Our application and database servers are located with Google Cloud Services in the United States. Google Cloud Services has certified with the Department of Commerce that it adheres to the Privacy Shield Principles under the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield framework.
If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including through the use of methods such as Cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations. By submitting your personal information to The Suite and using The Suite, you expressly consent to having your personal data transferred to, processed, and stored in the United States or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.
6. Cookies and Third-Party Providers
The Suite does not display any advertisements, and does not share any data with advertisers.
We may disclose personal information to third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, professional advisors and payment systems operators. All sub-processors that The Suite employs are certified under the EU - US privacy shield.
Where permitted by local data laws, The Suite may disclose or otherwise allow others to access your PII pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable law. If we have a good faith belief that the law requires disclosure, we may disclose your PII, with or without notice to you.
7. Children and Privacy
We never collect or maintain information at our website from those we actually know are under 16, and no part of our website is structured to attract anyone under 16. The Suite is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. § 6501, et seq. Our membership is not permitted for children under the age of 16. If you are aware of anyone under the age of 16 having supplied us with personal data, please contact us so that we can take steps to delete such information.
8. Business Transfers
If we or our assets are acquired; or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.
9. California Compliance
Privacy Notice for California Residents
Effective date: December 31, 2019
This Privacy Notice for California Residents (“California Notice”) supplements the The Suite Privacy Notice. It applies solely to The Suite Users, Viewers, and Invitees who live in the State of California (“California Residents”). The Suite adopts this notice to comply with the California Consumer Privacy Act of 2019 and any subsequent amendments (“CCPA”). All terms used in this California Notice have the same meaning as when used in the CCPA.
9.1 Information The Suite May Collect Regarding California Residents
The Suite collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Website may have collected the following categories of personal information from Users, Invitees, and Viewers within the last twelve months, for the purpose of establishing, maintaining, and supporting the services that we provide through our Website:
-A. Identifiers: real name; alias; email address; internet protocol address.
-B. Personal information categories listed in Cal. Civ. Code Sec. 1798.80(e): Real name; phone number.
-C. Commercial information: Purchase records regarding The Suite products.
-D. Internet or other similar network activity: Data on Viewers’ interaction with the The Suite Site and App.
The Suite Obtains the Categories of Personal Information Listed Above from the Following Categories of Sources
-Directly from our Users and Invitees.
-Indirectly from our Users and Invitees.
-Directly and indirectly from activity on our Site and App.
-From third parties that interact with us in connection with the services we perform.
9.2 How California Resident Personal Information May Be Used
We may use or disclose the personal information we collect for one or more of the following business purposes:
-To fulfill or meet the reason for which the information is provided.
-To provide you with information or services that you request from us.
-To provide you with email alerts and other notices concerning our services, or news that may be of interest to you.
-To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
-To improve our Site.
-For testing, research, analysis and service development.
-As necessary or appropriate to protect The Suite and our Users.
-To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.·
-As described to you when your personal information was collected, or as otherwise set forth in the CCPA.
-To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by The Suite is among the assets transferred.
-The Suite will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
9.3 Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing your contract.
We disclose your personal information for a business purpose to the following categories of third parties:
-Third parties to whom you or your agents authorize us to disclose your personal information in connection with the services we provide to you.
-Government representatives as required by law.
In the preceding twelve (12) months, we have not sold any personal information.
9.4 Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
-The categories of personal information we collected about you.
-The categories of sources for the personal information we collected about you.
-Our business or commercial purpose for collecting or selling that personal information.
-The categories of third parties with whom we share that personal information.
-The specific pieces of personal information that we have collected about you.
9.5 Deletion Request Rights
You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
-Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
-Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
-Debug software to identify and repair errors that impair existing intended functionality.
-Comply with the California Electronic Communications Privacy Act.
-Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
-Comply with a legal obligation.
-Otherwise lawfully uses that information in compatibility with the context in which you provided it.
9.6 Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by reaching out to firstname.lastname@example.org.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable California Resident request for access or data portability twice within a 12-month period.
The request must:
-Provide sufficiently detailed information to allow The Suite to reasonably verify that you are the person about whom we collected personal information or their authorized representative.
-Include sufficient detail to allow us to properly understand, evaluate, and respond to it.
-We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
-Making a verifiable consumer request does not require you to create an account with us.
-The Suite will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
9.7 Response Timing and Format
We will attempt to respond to California Resident requests in as timely a fashion as possible. In the event of delays over 60 days, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. Any disclosures we provide will only cover the 12-month period preceding the verifiable receipt of a California Resident’s request. The response we provide will explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before fulfilling your request.
In accordance with the CCPA’s requirements, we will not discriminate against you for exercising any of your CCPA rights.
10. Changes to this policy
11. Contacting Us