Last updated: July 27, 2019
2. INFORMATION THAT WE COLLECT ABOUT YOU
Information Provided by You Upon Creating an Account
When you create and register a user account (“Account”) on the Site, you may be asked to provide or confirm certain pieces of Personal Information, which may include one or more of the following:
First and last name
Current occupation and title
You may also be asked to provide your demographic information. However, providing such information will always be voluntary.
We may supplement the Personal Information you provide with additional Personal Information we gather from public sources or from third-parties (e.g., consumer reporting agencies) that may lawfully provide such information to us.
You are under no obligation to provide your Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the Site’s features and services.
Information Provided When You Contact Us
We may collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Site. We collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our products and services:
Passively Collected Information
When you access and use our Site, we may automatically collect and retain certain types of information, including your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, such as your browser type and version, time zone setting, and operating system and platform.
When you use our open ended personality platform channel (the “Channel”) on the Site, we also collect and retain your “Channel Data,” which is defined as information and data collected from your behavior and actions in the course of using the Channel, including metadata about your real-time user interaction with the Channel. After your completion of the Channel, the Site will review your Channel Data and generate your specific “Trait Profile,” which contains the Site’s assessment and description of your cognitive, social, and personality traits.
We may collect certain additional information when you access our Site with a mobile device or with MeaningBot IOS and Android mobile apps. This information may include location, device type, unique device identifier, operation system, and other app-specific user data. This data is analyzed to help us create a more user-friendly mobile experience. You may restrict collection of certain data, like location by changing the setting preferences on your mobile device.
3. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE
Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Site and typically work in conjunction with cookies to assist our site with the automated collection data on user behavior. MeaningBot will not be able to personally identify you in connection with these practices.
An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site and is deactivated or deleted thereafter.
Local Shared Objects. Local shared objects (or Flash cookies) are pieces of data that websites which use Adobe Flash may store on a user’s computer or device. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity use local shared objects. Various browsers may offer their own management tools for removing local shared objects. In addition, you may manage Flash cookies by clicking here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
4. WHAT WE DO WITH THE INFORMATION WE COLLECT
General Uses. We also use the information we collect to manage, analyze, develop, customize, and improve our Site as well as our products and services (including our Channel).
Information Provided When You Register an Account and Use Our Channel. We may use this information to authorize and administer your access to the Site, verify your identity, authenticate your visits, and provide our products and services to you. We may also use your information to improve and personalize your experience with us (including showing you relevant information such as your job matches), and, with your consent where necessary, notify you when you match a new open role on the Site, notify you when a recruiter or another user contacts you, remind you to finish any incomplete questions, send you information about us, and keep you informed of our products and services that may be of interest to you. We may combine your Personal Information with other Personal Information lawfully collected from third parties in order to better market and provide our products and services.
Information Provided When You Contact Us. We may use this information to understand and respond to your question or comment.
Passively Collected Information. We use passively collected information to monitor and maintain the performance of our Sites; analyze trends, usage, and activities in connection with our services; validate users and ensure their technological compatibility with users; optimize our marketing efforts; and to provide our products and services to you, including analyzing your Channel Data and developing your Trait Profile.
Aggregate Data. We may use the aggregated data of our user’s Personal Information and passively-collected information to create aggregate data which cannot be used to identify you (“Aggregate Data”). For example, Aggregate Data may include data that describes the general demographics, usage, Channely Data, or other characteristics of a Site’s users. We reserve the right to use, transfer, and/or sell Aggregate Data about the Site’s users for any lawful purposes. We also reserve the right to use such aggregate information in collaboration with outside researchers to measure and quantify the effectiveness of our products and services.
Public Profile. If you select Public in your Privacy Settings tab on your Account Profile, we may use your information to match you with potential employers or job openings.
Incumbent Employees. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and use the Channel by your current employer, then we may use your information to create a talent assessment model for a specific role at your current employer. In such a scenario, you would be deemed an “Incumbent Employee.”
Job Candidates. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and use the Channels as part of the job application process for a specific employer, then we may use your information to assess your fit to a specific role(s) at this employer. In such a scenario, you would be deemed an “Job Candidate.”
Other Purpose. We may use your information for any additional purpose which you separately authorize in the course of accessing and using our Site.
5. WITH WHOM WE SHARE THE INFORMATION WE COLLECT
Personal Information of our users is an integral part of our business. We reserve the right to share your Personal Information with third parties as described below. We also reserve the right to transfer and/or sell other types of data, including aggregate or de-identified data derived from Personal Information, for lawful purposes in our discretion. Note that we do not share Personal Information with third parties for their direct marketing purposes.
Service Providers. We, like many businesses, sometimes hire other companies (“Service Providers”) to perform certain business-related functions. Examples include customer service, maintaining databases, data storage, cloud services, and hosting services. When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include Personal Information and other information that you provide to us via the Site. These Service Providers are authorized to use your information only as necessary to provide these services to us.
Legal Requirements. We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of users of the Site or the public; (d) protect against legal liability; or (e) or as otherwise required or permitted by law.
Public Profile. If you select Public under the “Recruiting Visibility” section of the Privacy Settings tab on your Account profile, then we may share your Personal Information and Trait Profile with a potential employer when our Site determines that you might be a good match for this employer.
Limited Profile. If you select Limited under the “Recruiting Visibility” section of the Privacy Settings tab on your Account profile, then we may share your Personal Information and Trait Profile with potential employers that you have actively expressed interest in.
Job Candidates. If you were directed to visit the Site, create an Account, and play the Games as part of the job application process for a specific employer, then we share your Personal Information and Trait Profile with this employer and any third party that is pertinent to the employment application process.
Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, total or partial sale of assets in bankruptcy or similar event, your Personal Information and other information may be part of the transferred assets.
Other Third Parties. We may disclose your information to other third parties with your prior express consent.
You hereby consent to our sharing of your Personal Information and other information for the above purposes.
6. EU-U.S. AND SWISS-U.S. PRIVACY SHIELD NOTICE
Effective: October 19, 2018
Information Processed. See Sections 2 and 3 of this Policy.
Purposes of Information Processing. See Section 4 of this Policy.
Third Parties with Whom We May Share Information. See Section 5 of this Policy.
Questions or Complaints. If you are a resident of a European country participating in the Privacy Shield and you believe we maintain your Personal Information within the scope of this Privacy Shield certification, then you may direct any questions or complaints concerning our Privacy Shield compliance via the contact information in Section 8 of this Policy below. We will work with you to resolve your issue.
Dispute Resolution. If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from JAMS (www.jamsadr.com ), which is an independent dispute resolution body in the United States.
Arbitration. You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.
U.S. Federal Trade Commission Enforcement. Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Right of Access. See Section 7 of this Policy.
Requirement to Disclose. We may disclose Personal Information when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.
Liability. If a third-party service provider providing services on MeaningBot’s behalf processes Personal Information from the EEA or Switzerland in a manner inconsistent with the applicable Privacy Shield Principles, MeaningBot will be liable unless we can prove that we are not responsible for the event giving rise to the damages.
Human Resources Data. MeaningBot commits to cooperating with EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and will comply with the advice provided by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of MeaningBot’ employment relationship with our employees.
7. YOUR CHOICES REGARDING YOUR INFORMATION
Our Opt-out Policy
We may send you notifications and communications using the email address you provided to us when you registered your Account. To stop receiving some or all email communications from us, you can use the “Email Settings” tab of your Account profile to edit your email preferences. Alternatively, you can use the “unsubscribe” mechanism provided in the email communication
We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your account.
Accessing, Correcting, and Updating Your Information
You may access, correct, and update most of your Personal Information under the Account Settings tab of your Account profile. You may also email us at privacy@MeaningBot.com with information necessary for us to process your request. We will respond to your request within a reasonable timeframe. We may need to verify your identity before granting access to Personal Information in our custody or control.
Note that because some of our Site is designed to test memory and instinctive behavior (which can be skewed through subsequent use), once you start or complete a open ended survey, your Channel Data and Trait Profile cannot be reset, amended, deleted, or overridden for a period of 12 months after you have completed the Channel.
Deactivating Your Account
You may deactivate your Account using the Deactivate Account button under the Account Settings tab on your Account profile. When you deactivate your Account, you will no longer be able to log into the Account. You will also no longer be able to create any new Accounts with the email address associated with the deactivated Account. If you wish to reactivate your deactivated Account, please email us at privacy@MeaningBot.com with the email address.
A deactivated Account does not mean that all of the information associated with your Account is expunged from our systems, although such information will now no longer be readily available to you.
Deleting Your Information
You may request to delete your Personal Information by emailing us at privacy@MeaningBot.com with information necessary for us to process your request. Note that any deletion request will be subject to our Retention Policy below.
Note that because some of our Site is designed to test memory and instinctive behavior (which can be skewed through subsequent gameplay), once you start or once you start or complete an open ended survey, your Channel Data and Trait Profile cannot be reset, amended, deleted, or overridden for a period of 12 months after you have completed the survey.
Our Retention Policy
We may retain your information for as long as your Account is active or as long as necessary to provide you with our services, comply with our legal obligations and regulatory requirements, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our End User Agreement).
In accordance with our obligations and requirements under local law, we must retain your information for a period of 2 years following the date of your last recorded assessment. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the 2-year period has passed, after which we will process your deletion request. If you do not have any recorded assessments during the last 2 years, then we will process your request within 10 business days of receipt.
Even if we are obligated to retain certain information, once you delete your Account or request deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site, regardless of whether you selected Public or Limited through the Privacy Settings tab of your Account profile.
As discussed above, we may aggregate our user’s Personal Information and other information to create de-personalized Aggregate Data which cannot be used to identify you. We will retain such Aggregate Data even after any Personal Information deletion requests have been processed.
Other Websites. Our Site may contain links to third-party owned and/or operated websites or mobile applications. We do not own nor control these third-party websites or mobile applications, and accordingly assume no responsibility for the information practices of those sites or apps. We suggest that you review their privacy, security, and data collection and distribution policies, if any, prior to providing such websites or apps with any information.
Blogs and Public Features of the Sites. Our Site may contain features, e.g. blogs, chat rooms, community forums, sharing functions, etc., that permit you to upload, post, transmit, display, perform, or distribute content and information, including your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.
Single Sign-On. You can create an Account using sign-in services such as Facebook or LinkedIn. This service will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form. Please note that your relationship with Facebook, LinkedIn, or any other third-party website is governed solely by your agreement with such third-party website.
Security. The security of your Personal Information is important to us. We take commercially reasonable steps to help protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. For example, we use one or more of secure socket layer (SSL) encryption, firewalls, and self-updating anti-virus software. Your Personal Information will be stored in the United States and will be subject to laws applicable in that country. While we take all steps, we consider appropriate, to protect your data, unfortunately, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. Please create a unique password for your Account and do not share your password with anyone else.
Minors. Visitors under 18 years are permitted to use and/or submit their Personal Information at the Site. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children related to our Site.
ATT: Data Protection Officer
Meaning Bot Inc.
2875 Route 35
Katonah, New York, NY 10536
United States of America