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Privacy Policy

Effective Date:
September 30, 2020

The Who Company, Inc. (“WhoCo,” “us,” “we”) provides hiring tools to individuals and companies. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and share personal information and to assist you in exercising your privacy rights.

This Privacy Policy applies to personal information processed by us in our business, including on our websites, mobile applications, and other online or offline offerings (collectively, the “Services”). All other terms not defined in herein will have the meanings set forth in our Terms of Service.


1. Personal Information We Collect

The categories of personal information we collect depend on whether you are a Company, a person who uses our Services either as a Company User or an individual user, or a visitor to our website, and the requirements of applicable law.

Information You Provide to Us

Account Creation. When you create a user account, we collect your name, email address and password. We may also collect demographic information, phone number, social media profile information (e.g., Linkedin, Facebook, Twitter, Instagram), relevant online community profiles (e.g., GitHub, HackerRank), resume information such as work experience, educational background, credentials or certifications, personal interests, desired job specifications including location, and salary and benefits information.

Payment Information. We may collect personal information from Users, including name, billing address and credit card number. Any payments made via our Services are processed by third-party payment processors.We do not directly collect or store any payment card information entered through our Services, but it may receive information associated with your payment card information (e.g., your billing details).

Your Communications with Us.
We collect personal information from Users such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job or otherwise communicate with us.

Surveys / Assessments. We may contact you to participate in surveys and assessments. If you decide to participate, you may be asked to provide certain information which may include personal information.

Social Media Content. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

Information Collected Automatically or From Others

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit here. You can opt out of Google’s collection and processing of data generated by your use of the Services by going here.

Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

2. How We Use Your Information

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Communicating with you about your account, activities on our Services and policy changes;
  • Undertaking activities to verify or maintain the quality or safety of a service or device;
  • Processing your financial information and other payment methods for products or Services purchased;
  • Providing advertising, analytics and marketing services;
  • Providing Services on behalf of our customers, such as maintaining or servicing accounts, providing customer service, and verifying customer information;
  • Processing applications and transactions; and
  • Allowing you to register for events.

Analyze and improve our Services pursuant to our legitimate interest, such as:

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
  • Undertaking research for technological development and demonstration;
  • Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
  • Improving, upgrading or enhancing our Services or device;
  • Developing new products and Services;
  • Ensuring internal quality control;
  • Verifying your identity and preventing fraud;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Enforcing our terms and policies; and
  • Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

  • Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
  • Auditing relating to interactions, transactions and other compliance activities; and
  • Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

Automated profiling. We may use technologies that help a Company make decisions about Users.  While these technologies may be considered automated decision making or profiling, they are  based on Company requirements and we do not determine the criteria. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.

Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

Process Information on Behalf of Our Customers (as processors). Our customers may choose to use our Services to process certain data of their own, which may contain personal information of users. The data that we process through our Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers, not this Privacy Policy.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to process this data. We will, however, provide assistance to Companies to address any concerns you may have, in accordance with the terms of our contract with them. For a list of our sub-processors, contact us as described below.

How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

3. How We Share and Disclose Your Information

Except as provided below, we do not share your personal information.

Recruiters. We may share your personal information to better connect you with recruiters or hiring companies which may have a mutual benefit for all parties involved.

Service Providers. We may share any personal information we collect about you with our third- party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.

Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

Affiliates. We may share personal information with our affiliated companies.

Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you about our Services when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

4. Your Choices

General. You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes as described above.

Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at networkadvertising.org, youronlinechoices.eu, youradchoices.ca, and aboutads.info. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

  • Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
  • Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
  • Request deletion of your personal information, subject to certain exceptions prescribed by law.
  • Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
  • Withdraw your consent to our processing of your personal information.

If you would like to exercise any of these rights, please email privacy@whoco.com or contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

5. International Data Transfers

You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

6. Data Retention

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. California Privacy Rights

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information WhoCo has collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find  information on categories of personal information we collected below and the 3rd parties to whom we disclose information for a business purpose:

Identifiers. Name, address or location, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Advertising networks
  • Internet service providers
  • Data analytics providers
  • Service providers

Personal information categories listed in the California Customer Records statute. Name, physical characteristics or description, address, telephone number, education, employment, employment history. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories. (California Civil Code § 1798.80e). 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Service providers

Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status. 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Service providers

Commercial information. Records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 3rd-parties disclosed to for a business purpose:

  • Advertising networks
  • Data analytics provides
  • Service providers

Internet or other electronic network activity. Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement. 3rd-parties disclosed to for a business purpose:

  • Advertising networks
  • Data analytics provides
  • Service providers

Geolocation data. Physical location or movements. 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Advertising networks
  • Internet service providers
  • Data analytics provides
  • Service providers

Sensory data. Audio, electronic, visual, or similar information. 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Service providers

Professional or employment-related information. Current or past job history or performance evaluations. 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Service providers

Non-public education information. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.(per the Family Educational Rights and Privacy Act - 20 U.S.C. Section 1232g, 34 C.F.R. Part 99). 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Service providers

Inferences drawn from other personal information to create a profile about a consumer. Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 3rd-parties disclosed to for a business purpose:

  • Companies using our platform
  • Advertising networks
  • Data analytics provides
  • Service providers

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, The Who Company does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized 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. To designate an authorized agent, please contact us as set forth below.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include providing the name and email you used to register for an account with WhoCo or sending you an email to your verified identity.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

8. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

9. Age Limitations

The Services are not directed to children under 17 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

10. Other Provisions

Supervisory Authority

If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

11. Contacting WhoCo

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

The Who Company, Inc.
2210 Main Street, 2nd Floor
Santa Monica, CA 90405
privacy@whoco.com