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People Element Privacy Statement
Effective Date: May 1, 2021

SUMMARY OF PRIVACY STATEMENT

At People Element, we care about privacy and believe in providing transparency to consumers about our information handling practices. This Privacy Statement applies to personal information – information that identifies you or reasonably can be linked to information that identifies you – that People Element collects through your use or interaction with our websites, applications, social media, software, and other services provided by or on behalf of People Element (collectively, the “Services”). We will continue to share your information as described in this notice, even after the end of your relationship with us.

Information We Collect

The information we collect through our Services may include:

How We Collect Information

We collect information about you from a variety of sources, including:

How We Use Your Information

We may use the information we collect to:

Information Sharing

We may share the information we collect:

INTRODUCTION

At People Element, we care about privacy, and we believe in providing transparency to consumers about our personal information practices. This Privacy Statement explains how People Element collects, uses, discloses, and protects your personal information.

This Privacy Statement applies to the personal information People Element collects about you through websites, applications, social media, software, and other services provided by or on behalf of People Element. When you use or interact with the Services, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Statement.

If your use of the Services is pursuant to your employment or other relationship with a People Element business customer or your use of the Services are linked to another party, such other party’s privacy statement may apply in addition to or in lieu of this Privacy Statement.

If you have any questions about our privacy practices, please contact us as set out in the “Contacting People Element section below. If you are a California resident or Nevada resident, please see the “Your California Privacy Rights and “Your Nevada Privacy Rights” sections below.

INFORMATION WE COLLECT

Information About You. The information that you provide directly to us and that we obtain from others is what we need to serve you and our business customers. This information may include your contact details (such as name, postal and email addresses, phone number, social media handles and other online aliases); information specific to the Services you request; contact information of individuals with whom you would like to share People Element content; social media information; demographic and household information; your responses and engagement with our Services; and other information you may choose to share with us by interacting with our Services or with our business customers, suppliers or other businesses that share information with us.

Information About Your Device. The information we collect by automated means also helps us and our business customers to provide and tailor various products and services. Examples of information we collect by automated means include the following:

Usage Information. We and our suppliers may automatically collect your usage activity, preferences, and browser details (such as your IP address and browser type), as well the ID and type of the device you use to connect or interact with our Services, and other details about your use or interaction with our Services. This may also include the collection of information about your online activities over time and across third-party websites or online services and across devices that you use.

Location Data. Some of our Services may collect geo-location data to provide or improve our Services and location-related functionality. We may link location data to other information we have collected about you.

HOW WE COLLECT INFORMATION

Information You Provide. We collect the information you voluntarily provide to us in connection with using our Services through product inquiries (including phone calls, chat transcripts, and other details), your interaction with the Services, and other inquiries and transactions.

Information We Obtain from Business Customers and Others. We may obtain information about you from outside sources. For example, our business customers that deploy People Element Services may share with us certain information you provided to them or collected from you by them. We also may obtain demographic, user preferences, geo-location and other information about you from other parties. If you engage via social media with us or our business customers, the social media platforms also may share certain information with People Element. You may be able to adjust your social media privacy settings to limit the sharing of your social media data.

Information We Obtain by Automated Means. We may collect information about your use or interaction with our Services or about the devices you use to connect or interact with the Services by automated means, including tracking technologies. These tracking technologies may include “cookies,” which are small lines of text/data that are written onto your device by a website. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

Browser cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. You can also choose to limit the information shared with social media, advertising, and analytics partners.

Mobile advertising ID controls. Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID.

DATA COLLECTION AND USE BY THIRD PARTIES

Google Analytics. Google may use cookies to track your browsing on our website(s) and to supply us with analytics and other information about your usage of our Services. We use this data for no other purposes. In addition to collecting information directly from you, Google may use tracking technology to measure the effectiveness of their ads and personalize or optimize advertising content. You can read Google’s Privacy Policy to learn more about their use of data collected via the Analytics program.

Amazon Web Services. We are hosted on Amazon Web Services (“AWS”). You can learn more about AWS privacy here: https://aws.amazon.com/privacy/.

HOW WE USE YOUR INFORMATION

A primary use of your information is to serve you and our business customers. The following are examples of the types of general purposes for which we may use your information.

Provide Services. We may use your information to complete a transaction you have asked us to do or to send you communications regarding services. We may also, for example, use your information to provide you with an improved experience when interacting with us.

Operate our Business and Develop and Improve Our Products and Services. Examples include using information collected through cookies and similar technology to better understand how our Services are used, develop new offerings, or personalize your experience when using the Services.

Customer Service. If you request support or other information, we may use your information to respond to your request. We may follow up with you to notify you periodically about important topics, like Services updates or changes to our Privacy Statement.

Advertising and Marketing. If you approve so by opting in, we may use your information to let you know about People Element services and offers, invite you to participate in those offers and manage your participation in them. We also may use information about you, your use or your interaction with our Services to tailor our offers to your preferences or to offer you products and services that we believe may be of interest to you. Among other privacy choices described in this Privacy Statement, you may direct us to not send you email marketing communications by clicking on the unsubscribe link included in the emails you receive from us.

Recruitment and Job Applications. We may use the information submitted on resumes and similar documents through People Element and our suppliers for the purpose of employment consideration. We may keep your information on file for future consideration.

Compliance with Legal Requirements, Rules and Internal Policies. We may be required by law or internal data retention policies to maintain information about you for a certain period of time, or to notify you of a security breach. We also may be required by social media platform rules (such as Facebook) to handle the social media information you or the platform share with us in a certain manner.

INFORMATION SHARING

A primary use of your information is to serve you, which requires certain sharing with our business customers. This section describes the types of organizations with whom we may share your information.

Within People Element. People Element may authorize access to your information within our enterprise, by our employees and other personnel, to fulfill our obligations to you and to operate our business.

Third-Party Suppliers. We share information with Third-Party suppliers solely in connection with our provision of services to, and with prior approval of, our employees and consultants, such as payroll processing, benefits enrollments, and similar services.

Marketing Partners and the Public. We may share aggregate statistics – statistics not linked by us to any specific consumer – about consumer behavior, sales, online activity patterns, and related information with our marketing partners and the public for the purposes of promoting, marketing, advertising, and informing such parties about People Element and the Services.

Your Public Comments. Some portions of our Services may allow you to submit comments, reviews, ratings and other content. This content may be displayed on the Services and may be viewable by other users of the Services or the public generally.

Mergers, Acquisitions or Insolvency. If People Element should ever file for bankruptcy or merge with another company, or if People Element should decide to buy, sell, or reorganize some part or all of its business, People Element reserves the right to disclose your information, including to prospective or actual purchasers in connection with one of these transactions.

As Required by Law and Other Disclosures. People Element may be required to disclose your information if it:

INFORMATION SECURITY

We take reasonable measures to secure our systems and protect your personal information, securely storing and protecting your information from unauthorized access and use with security measures that comply with applicable law. These measures include computer safeguards, testing, and physical controls. However, data transmissions over the Internet and otherwise can never be guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us and you do so at your own risk.

By providing your email address to us or using the Services, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically, as permitted by applicable law. You may have a legal right to receive this notice in writing. To receive a free written notice in the event of a security breach (or to withdraw your consent from receiving electronic notice), or if you want to update the contact information you have previously provided to us, you should contact us by clicking: https://peopleelement.com/opt-out/

ACCESS AND CONTROL OF INFORMATION YOU HAVE PROVIDED TO US

You may request to access, correct, update or delete the personal information you have provided to us by clicking: https://peopleelement.com/opt-out/. We may limit or deny access to information where providing such access is unreasonably burdensome or expensive under the circumstances, or as we otherwise deem appropriate. In addition, please note that we may not be able to edit or delete your information stored with third-party service providers, or we may be required (by law or otherwise) to keep this 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). You may also opt-out of marketing emails or communications by clicking: https://peopleelement.com/opt-out/.

Choices for Cookies. See the section on “How We Collect Information” and “Data Collected and Use by Third Parties for cookies and advertising controls.

OTHER INFORMATION

We may use or share non-personal information, aggregated information, de-identified or pseudonymized information, and statistical information for any lawful purpose. Any obligations or restrictions contained in this Privacy Statement do not apply to such information.

CHILDREN

Our Services are not directed at children or intended to be used by children. Do not send any information about yourself to us if you are under the age of sixteen (16). In addition, if we learn a person under the age of thirteen (13) has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately at privacy@peopleelement.com.

YOUR CALIFORNIA PRIVACY RIGHTS

California Consumer Privacy Act (“CCPA”)
If you are a California resident and the processing of personal information about you is subject to the CCPA, you have certain rights with respect to that information.

Categories of Personal Information. Below please find the categories of personal information we have collected in the past 12 months:

CATEGORY EXAMPLES COLLECTED? DO WE DISCLOSE FOR BUSINESS PURPOSE? DO WE SELL?
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address or other similar identifiers. YES YES NO
Commercial Information Records of personal property, products or services purchased, obtained, or considered or other purchasing or consuming histories or tendencies. NO NO NO
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e) A name, signature, address, or telephone number YES YES NO
Protected classification characteristics under California or federal law Age or sex (gender) information. YES YES NO
Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement. YES YES NO
Sensory data Audio or similar information (from phone calls). NO NO NO
Geolocation data Physical location or movements about an individual or device. YES YES NO
Professional or employment-related information Current People Element employment or performance evaluations. YES YES NO
Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, predispositions, behavior, or attitudes. NO NO NO

 

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section above.

Purposes for Collecting and Using Personal Information. Generally, People Element may use some or all of the above categories of personal information for its business and commercial purposes. For more information with respect to how we use your information, review the “How We Use Your Information” section above.

Categories of Third Parties with which We Share Personal Information. In the past 12 months, People Element has disclosed the personal information to the following categories of third parties:

Note that the CCPA defines “sell” very broadly, and some of our data sharing described in this Privacy Statement may be considered a “sale” under that definition. To the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in this Privacy Statement, we will comply with applicable law as to such activity.

Categories of Personal Information We Have Sold. In the past 12 months, People Element has sold no personal information to any party.

Access/Right to Know. You have a right to request that we provide you with the following information, the:

Right to Delete. You also have a right to request that we delete your personal information under certain circumstances, subject to a number of exceptions.

Right to Opt-Out. To the extent we sell your data as the term “sell” is defined under CCPA, you also have a right to opt-out from the sales of personal information, which you can exercise by clicking the https://peopleelement.com/opt-out-ccpa/ link on the homepage of our website. In addition to the https://peopleelement.com/opt-out-ccpa/ link, you will need to separately opt out of cookies on our website(s) to stop tracking. For more information see the section on “How We Collect Information” and “Data Collection and Use by Third Parties” for cookies and advertising controls to learn how to opt out of analytics and ad targeting.

How to Exercise Your CCPA Rights. You can exercise your CCPA rights by submitting your request(s) to us using the webform located at https://peopleelement.com/opt-out-ccpa/.

You can also exercise your CCPA rights by calling People Element, toll-free, at 1-800-765-6186, Monday through Friday from 9:00 am until 5:00 pm Mountain Time.

If you want to exercise more than one of your CCPA rights, please submit a separate request for each CCPA right, which will help us handle your requests more effectively. Please be aware that we will process your requests in the order they receive them. We will endeavor to respond to verified and valid requests within 45 calendar days.

Please be aware there might be circumstances where we will not honor your request, as permitted under the CCPA. For example, if we are not able to verify your identity or you are not a California resident, we may not honor your access or deletion request. In addition, we may not delete your personal information if an exception under the CCPA applies.

Verification Process. Whether you use the webform or call, People Element will need information from you to process your request so that we can confirm you are a California resident, determine if we have personal information about you, and, for access and deletion requests, verify your identity. People Element may also need to contact you about your request, and you can choose the contact method you would like them to use.

Authorized Agents. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, People Element will require the agent to provide proof you have authorized he/she to act on your behalf, and they may need you to verify your identity directly with them.

California Minors. People Element does not knowingly collect or sell the personal information of minors under 16 years of age.

Non-Discrimination. People Element will not discriminate against you for exercising your rights under CCPA, including: denying you goods or services; providing a different level of goods or services; or charging you different prices or rates for goods or services.

Disability Notice. If you have a disability and would like to access this Privacy Statement in an alternative format, please contact us at privacy@peopleelement.com.

California “Shine the Light” Law. Under California’s “Shine the Light” law, California residents may also request that we provide to you:

To submit your request, please email privacy@peopleelement.com and reference “Shine the Light” in the subject line or write us at the postal address in the section below entitled “Contacting People Element“. People Element will provide the requested information to you via email or mail.

YOUR NEVADA PRIVACY RIGHTS

If you are a Nevada resident, you have the right to opt-out of the sale of personal information to third parties that is collected by People Element. To submit your request, please click https://peopleelement.com/opt-out-nevada/ (you will be taken to a separate webpage).

NON-U.S. USERS

This is a U.S. website, and this site and our Services are subject to U.S. laws, including those governing the privacy and security of your information. If you use or interact with the Services, you are transferring your information to People Element in the United States. By using the Services or providing your information to us through the Services you consent to the transfer of your personal information to the United States, and our handling of your information in accordance with applicable U.S. requirements.

CHANGES TO THIS PRIVACY STATEMENT

In the future, we may change our Privacy Statement, and we will post the new Privacy Statement on www.peopleelement.com/privacy and provide a link to the previous version of the Privacy Statement. You agree to the new Privacy Statement by continuing to use or interact with the Services unless prohibited by law.

RETENTION OF YOUR INFORMATION

We retain your information for as long as it is necessary and relevant for the purposes described in this Privacy Statement. The information we retain about you will be handled in accordance with this Privacy Statement.

CONTACTING PEOPLE ELEMENT

If you have any questions, comments, or concerns about our information practices or this Privacy Statement, please email us at privacy@peopleelement.com or write to us at:

People Element Legal and Compliance Department
Attn: Data Privacy
People Element
650 S Cherry St #115
Glendale, CO 80246

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