Effective Date: April 7, 2023
We always seek to improve our Services to you, and that requires that we process information about you and your usage preferences. As we do so, we are absolutely committed to protecting your privacy and the security of your personal information.
1. DESCRIPTION OF SERVICES
2. LAWFUL BASIS FOR PROCESSING
When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard copy or by clicking “I Accept” or similar language online, or through an app store, we will process your Data for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your Data is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that Data have been fulfilled and after we no longer have a legal obligation to keep that Data.
In all cases, we will comply with applicable law and we will cease processing your Data after the legal right, obligation, or other lawful basis expires.
3. INTENDED USERS
The Services are directed solely to persons 18 years of age or older or of children under 18 who are supervised by a parent, guardian, or other caregiver. Other than for Data processed for the specific purpose of providing the Services to users, we do not knowingly process Data from users who are under 13. If we become aware that we have processed Data from a person under 13, except to provide the Services to such person, and except to the extent allowed or required by law, then we will attempt to delete such Data as soon as possible, subject to our obligations under applicable law. If you believe that we have processed Data from a person under 13 in contravention of this policy, please contact us at Privacy@eddy.com.
4. DATA WE PROCESS AND HOW WE USE IT
Listed below are the categories of Data we process when you use our Services. We never sell your Data, and we always have a lawful basis for processing the Data, but that lawful basis might be different for different categories, and we describe those uses below. Regardless, we never process the Data for any purpose other than the purpose for which we processed the Data in the first place, unless we get your prior explicit consent.
A. Registration Data
- Lawful Basis for Processing: Our lawful basis for processing Registration Data is our contract with you and your consent. We can only provide certain of the Services to you if we have the Registration Data, so we need to process that Registration Data during the term of our contract. Even when the Registration Data is not critically necessary to the provision of the Services, we may still process that Registration Data to facilitate our contractual interactions with you.
- How We Process It and Who We Share It With: Registration Data is accessible generally only to us and to you. We process it only to provide the Services to you. At times, we will share the Registration Data with other third parties at your request or to fulfill requests that you make of us. In limited circumstances, we may share your Registration Data with our service providers, which parties help us provide the Services and are under obligations to protect the confidentiality of your Registration Data. We may also use your Registration Data to offer our own goods or services to you, either directly through emails or through third party platforms, but you may opt out of those communications at any time. We will never share your username or password with any third party. Further, we will never share or sell (as defined in the CPRA) your sensitive personal information without your written consent.
B. Engagement Data
- Data Description: Engagement Data consists of all the information you input or record using the Services, except as otherwise stated in this policy. It also includes all information that is proprietary to you regarding your use of the Services (other than the data that qualifies as “Usage Data” below) that is processed by the Services. For example, Engagement Data includes payroll information, personal information about employees, and internal company communications, among other things. Engagement Data also includes information submitted by users as part of the job posting and application features of our Services, including but not limited to, resume information. Engagement Data may include sensitive personal information as defined in applicable data privacy laws.
- Lawful Basis for Processing: Our lawful basis for processing Engagement Data is (1) our contract with you, (2) our obligation to provide you with the Services and (3) our legitimate interest in improving our Services based on the Engagement Data we receive from you.
- How We Process It and Who We Share It With: Your Engagement Data is accessible generally only to us, to you, and where it relates directly to a party who either provides services to you or receives services from you, to that party, in which case that party will be obligated to protect the confidentiality of your Engagement Data. Such situations may include information that you upload to the Services that are reasonably expected to be seen or shared with our customers or other users of our Services (i.e. user-to-user communications, recruiters, potential employers, etc.). In limited circumstances, we may share your Engagement Data with our service providers, which parties help us provide the Services and are under obligations to protect the confidentiality of your Engagement Data. We do not share Engagement Data with other third parties, except at your specific request. We also do not convert Engagement Data into Anonymized Data for use for any purpose other than to provide the Services to you and to improve our knowledge of how our systems are used.
If you or your employer uses our payroll services, the Data processed through such services is categorized as Engagement Data. We use a third-party service provider to process payroll payments.
C. Usage Data
- Data Description: Usage Data consists of the following and similar information:
- Information about your interactions with the Services, most commonly our website and mobile application, which includes the date and time of any requests you make. This also may include details of your use of Third-Party Applications and any advertising you receive via the Services.
- Adjustments you make to the default state of the Services, such as custom categories or settings.
- The timing of the information you post to the Services including messages you send or receive via the Services and your interactions with our customer service team, but not including the content of those interactions and messages, which would be included as Engagement Data.
- Technical data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, network connection type (e.g. WiFi, 4G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital
- Rights management, operating system, and application version.
- Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope), if any, required for the purposes of providing specific features of the Services to you.
- Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from you.
- How We Process It and Who We Share It With: Usage Data is accessible generally to us and to you. We do not share it with third parties, except at your specific request, but we may use Usage Data to make improvements to the Services. In limited circumstances, we may share your Usage Data with our service providers, which parties help us provide the Services and are under obligations to protect the confidentiality of your Usage Data. Both during the term of our agreement with you and thereafter, we may also convert Usage Data to Anonymized Data, and that Anonymized Data belongs solely to us to process in our sole discretion (including to share or sell Anonymized Data, which is not Data). To the extent we are required to delete any Usage Data about you, we may still retain Anonymized Data that may have originated as your Usage Data.
D. Payment Data
1. Data Description: Payment Data is only processed when your use of the Services is subject to the payment of a fee or other charge. Payment Data is the information necessary for us to process your payments for premium Services. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:
- Date of birth;
- Certain credit card information used to reference a credit card;
- Address and postal code; and
- Mobile phone number
Please note that if you use our payroll services, Payment Data typically does not include such payroll information as that is classified as Engagement Data.
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Payment Data we receive from you.
3. How We Process It and Who We Share It With: We only process Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.
E. Supplemental Mobile Data
1. Data Description: Where applicable to the Services, Supplemental Mobile Data consists of the following and similar information:
- Your precise mobile device location – If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Services. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing and other agreements;
- The Company user profile includes age, gender, and other personal characteristics used for the purpose of delivering certain features; and
- Your photos – If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll.
2. Lawful Basis for Processing: Our lawful basis for processing Supplemental Mobile Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Supplemental Mobile Data we receive from you.
3. How We Process It and Who We Share It With: We only process Supplemental Mobile Data when you specifically authorize it, and we only share it with those parties who are strictly necessary for the purpose you have authorized.
5. SHARING YOUR INFORMATION
Except where a specific limitation is noted above, we may share your Data as follows:
- At Your Instruction. If you request us to make your Data available to a third party, and such request furthers the purposes of our Services, we will do so.
- Sharing with Vendors. In certain cases, we use the services of third-party vendors, to assist us in providing the Services. We may share your Data with such vendors solely for that purpose, and we will require those parties to abide by our privacy policies or privacy policies substantially in consonance with ours.
- Service Providers. We may sometimes use a third party to provide specific Services on our behalf, including sending emails to our members, conducting member surveys, processing transactions or performing statistical analysis of our Services. In these cases, we may provide certain personal information, such as your name and email address and other financial information necessary for the service to be provided. However, these third parties are required to maintain the confidentiality of this information and are prohibited from retaining, sharing, storing or using this information for any other purposes.
- Business Transitions. In the event that we go through a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of our assets, the information we have about you will, in most instances, be part of the assets transferred. We reserve the right to transfer that information in connection with such transactions without notice to you. We will not be required to obtain your consent for such a transfer.
- Legal Disclosure. We may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to conform to applicable law, comply with a judicial proceeding, court order or legal process served on us, protect and defend our rights or property, or investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our terms of service.
If we ever plan to process any Data in the future for any other purposes not identified above and we do not have a separate lawful basis for that new purpose for processing, we will only do so after obtaining your specific consent.
Further, we do not sell or share (as defined in the CPRA) your Data for any purpose.
6. TECHNOLOGIES WE USE
The technologies we use for automatic Data collection may include the following:
- Web Beacons. Pages of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Geolocation. We may use GPS (or other similar) technology when you use our Services, and more specifically any mobile application, to determine your current location. If you do not want us to use your location to provide you the Services, you can turn off your location services on your mobile device in your device’s account settings.
- Other Technologies. We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and users who access the Services. Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).
7. YOUR CHOICES REGARDING OUR PROCESSING AND DISCLOSURE OF YOUR DATA
By using our Services, you agree that we may process your Data to market our other Services to you. If, after giving your consent, you wish to opt-out of our using your Data to market Services to you, please follow the instructions below.
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails or other electronic messages from us on a going-forward basis, you may opt-out of receiving these marketing-related messages by sending a request for list removal to Privacy@eddy.com. Further, you may opt-out of SMS or other text messages sent as part of the Services by replying STOP.
- Our sharing of your Data with unaffiliated third parties for their (or their customers’) direct marketing purposes: If you would prefer that we do not share your information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by emailing Privacy@eddy.com from the email that you have signed up or used in receiving the Services.
We will comply with your request(s) as soon as reasonably practicable and as required by applicable law. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages until the lawful basis for our processing of such information expires.
8. PRIVACY FOR EU/UK RESIDENTS
For employees and other authorized users operating in their role as administrators or users of our Services, our lawful basis is the legitimate interest we have in providing the Services to their employer.
We are based in the United States. By accessing or using the Services or otherwise providing information to us, you understand that your information will be subject to processing in and to the United States.
The GDPR also requires us to take appropriate technical and organizational measures to protect the security of Data relating to residents of the EU. We make commercially reasonable efforts to ensure the privacy and security of the Data of our EU visitors, customers, and end users, and we are happy to give you a complete description of our most current efforts, if you will write us at Privacy@eddy.com. You may also write us at that address to communicate with our chief technology officer who will serve as our data protection officer, if necessary, also available at Privacy@eddy.com.
Due to the nature of our Services, we typically act as a “Processor” as defined under the GDPR, which may limit our ability and legal obligation to respond to your request. If you believe that this role should be defined differently, please contact us at Privacy@eddy.com.
Further, if you are a resident of the United Kingdom (“UK”), to the extent the GDPR as incorporated into UK law pursuant to s.3 of the European Union (Withdrawal Act) 2018 (as amended, the “UK GDPR”) is different than the GDPR, we will follow all supplemental requirements under the UK GDPR and you have all rights as a UK citizen under the UK GDPR. Our DPA also contains provisions related to the proper international transfer mechanisms under the UK GDPR.
To make any request related to your rights under the GDPR or UK GDPR, please contact us at email@example.com. To process any such request, we will use the process described in Section 9 for requests made pursuant to the CCPA to the extent such procedures comply with the GDPR and UK GDPR.
9. PRIVACY FOR CALIFORNIA RESIDENTS
California has adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020 and also adopted the California Privacy Rights Act (“CPRA”), which took effect January 1, 2023. We comply with the requirements of the CCPA and CPRA to the extent they apply to us.
If you are a California resident and we qualify as a “business” related to our processing of your Data under the terms of applicable law, you have rights under the CCPA and CPRA, including the following rights:
- You have the right to request that we disclose the categories and the specific items of Data about you that we process, share, or sell and that Data about you that we have processed, shared, or sold during the 12 months prior to your request.
- You have the right to limit or restrict our processing of Sensitive Data (as defined in the CPRA).
- You have the right to opt-out of our selling or sharing (as defined in the CPRA) of your Data, including for direct marketing purposes, or processing of automated decision-making technology.
- You have the right to access and correct your Data that we process.
- You have the right to request portability of your Data.
- You also have the right to have the Data we process about you deleted. We use a two-step process to verify your identity and to have the information deleted. Your rights to have Data deleted are subject to several exceptions, specifically the Data that is necessary for us to:
- complete your transaction;
- provide you a good or service;
- perform a contract between us and you;
- protect your security and prosecute those responsible for breaching it;
- fix our system in the case of a bug;
- protect the free speech rights of you or other users;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- comply with a legal obligation; or
- make other internal and lawful uses of the information that are compatible with the context in which you provided it.
- To make any request under the CCPA and CPRA, you must complete the Data Request Form found at https://eddy.com/california-consumer-privacy-request-form/. You will be asked to give us your name, email address, telephone number, and any other information we request to reasonably verify your identity. We will respond to your request within 10 days after receipt of your request, and we will then take action to verify your identity and fulfill your request, as required by the CCPA and CPRA.
- We will provide you with a CSV copy of your processed data within 45 days of your request, assuming we are able to verify your identity in that period and so long as you provide a correct email address for successful correspondence.
- You have the right not to receive discriminatory treatment by us for the exercise of any privacy rights conferred by the CCPA and CPRA, which means that we will not take any action to hurt or punish you for exercising your rights under either law.
- You may designate an authorized agent to make a request under the CCPA and CPRA on your behalf by writing us at Privacy@eddy.com. Upon receipt of your request, we will provide you with the information you will need to designate that agent.
We have listed the specific and general categories of information we have processed, shared, or sold in the last 12 months in the section above entitled “Data We Process and How We Use It.” That section also lists the specific and general categories of Data we have disclosed to third parties for our business purposes.
We do not share or sell your Data. However, we do disclose certain categories of Data to the merchants whose businesses you visit using the Services, all as described in the section entitled “Data We Process and How We Use It” above.
Please note that exercising any of the above rights may limit or eliminate our ability to provide you the Services. If so, we may terminate the Services due to such requests. However, you can exercise any of your rights free of discrimination, for example, we cannot increase the price of the Services or decrease the quality of the Services because you exercise your rights.
Due to the nature of our Services, we typically act as a “service provider” as defined under the CCPA and CPRA, which may limit our ability and legal obligation to respond to your request. If you believe that this role should be defined differently, please contact us at the information below.
For more information, please direct your questions to us at Privacy@eddy.com. You can also direct questions to our toll-free number at 877-750-3339.
10. PRIVACY FOR OTHER JURISDICTIONS
The security of your Data is important to us. We use commercially reasonable efforts to process your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
12. THIRD-PARTY POLICIES
13. DATA RETENTION
15. “Do Not Track” Options
Your web browser(s) may offer a “Do Not Track” option, which allows the individual to signal to operators of websites and web applications and services (including behavioral advertising services) that he or she does not wish such operators to track certain of his or her online activities over time and across different websites. We do our best to support Do Not Track requests but cannot guarantee full support based on the variety of internet browsers and technologies which means that we may collect information about your online activity both while you are using the Services and after your use of the Services.
16. CONTACT US
You can help by keeping us informed of any changes such as a change of your personal contact information. If you would like to access your information, if you have any questions, comments or suggestions or if you find any errors in our information about you, please contact us at Privacy@eddy.com. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.