Privacy Policy
Last Updated: November 7, 2023
1.Introduction
Scalis is committed to explaining how we gather and use your information, keeping it secure and handling it in accordance with our legal obligations. This Privacy Policy (“Policy”) is designed to help you understand how we use your data. It also explains your rights and choices.
This Policy applies to these services (which we call the “Platform” in this Policy):
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our mobile apps; and
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anywhere else we gather information about you and refer to this Policy.
How we handle your information depends on which Platform services you use, and how you use them. This Policy is grouped into these sections:
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We encourage you to read this Policy carefully. If you have questions, please contact us.
2.About us and this Policy
(a)
Who we are
Scalis LLC operates the Platform and is referred to in this Policy as “Scalis”, “we”, “our” or “us”. This Policy supplements and is governed by our Terms of Service (“Terms”). The Terms define capitalized terms that aren't defined in this Policy, describe how the Platform works in general and establish the contract between you and us governing your use of the Platform.
(b)
How to Contact Us
If you have any questions or feedback about this Policy, email us at contact@scalis.ai with “Privacy” in the subject line or write to us at: Scalis LLC, 1000 Brickell Ave., Suite 71, M iami, FL 33131.
(c)
When this Policy applies
This Policy applies to you when you use the Platform, effective as of the Last Updated date above.
Because the Platform changes often, this Policy may change over time. Anytime we modify the Policy, we will post a revised version on the Platform and update the Last Updated date above. If Scalis is going to use your personal information in a manner materially different from that stated at the time of collection, we will notify you before the material changes take effect, so you have time to review them. We will notify you via email (if you have given us your email), by posting a notice on the Platform and/or by any other means to the extent required by law.
We encourage you to review the Last Updated date periodically to ensure you're aware of the current Policy. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy and the Terms.
Finally, some collection and use of information falls outside this Policy:
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Third-party services: Outside Materials (as defined in our Terms) are not part of the Platform, so this Policy doesn't apply to any information you may exchange with providers of Outside Materials or other third parties. If you follow a link to a third-party website, your use of that website is governed by that website's privacy policy and is not covered by this Policy.
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Our personnel: If you are a current or former employee or contractor of ours, this Policy does not apply to you. Reach out to your human-resources partner or supervisor with any inquiries about your personal information. We will also route your request if you contact us.
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When we don't control your information: If we receive or process your information in our role as a Processor to another business acting as a Controller (such as an Employer), our agreement with the Controller governs our use of your information. Where Scalis acts as Processor of your personal information, we store such data until instructed to delete it by the Controller. We will refer your questions, requests or concerns to the Controller.
(d)
Location-specific sections
The Platform operates from the United States, but this Policy applies worldwide. Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live. For example, you may have rights under: (1) “GDPR”: implementations of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679; or (2) “CCPA”: the California Consumer Privacy Act, as amended.
As a result, certain sections of this Policy apply to you only if you reside in a particular location:
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Residents of California and other states with data privacy laws should consult theRights under U.S. state laws section. If you reside in a U.S. jurisdiction that has enacted a data privacy law similar to CCPA or GDPR, we extend the same rights CCPA grants to California residents to you, except where we specify otherwise.
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Residents of jurisdictions where GDPR applies - such as U.K., EU and Swiss residents - should consult the Rights under GDPR and International Data Transfers sections.
If those location-specific sections apply to you, those sections override any contrary descriptions elsewhere in the Policy as they relate to you. If you have questions about your rights under other data privacy laws, please Contact Us.
3.Terminology
We use the following defined terms in this Policy. If not defined in this Terminology section, capitalized terms are defined in our Terms or in bold elsewhere in the Policy (like “This”).
| Defined term | Meaning |
|---|---|
| Job Seeker | An individual searching for employment openings, services, or information related to their personal employment or job search |
| Employer | A business or individual using the Platform to find Job Seekers, seek information related to hiring or human resources or post information about employment opportunities, on their behalf or other's behalf (such as employment agencies) |
| personal information | Any information that relates to an identified or identifiable individual, which can include information about your visits to the Platform such as device information or IP address |
| special category data | Any personal information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, sex, or sexual orientation, including any protected classifications under applicable law. |
| Controller | The entity which decides how and why your data is processed |
| Processor | An entity which processes data at the direction of a Controller |
| Listings | Employment openings on Scalis listed by Employers |
| Profile | All application and contact information stored on your Account, including resume information, assessment results, and answers to screener questions. |
| Resume | A resume or similar document (such as a CV) that you provide through the Platform |
| ATS | An applicant tracking system, whether connected through the Platform by an Employer or through the Platform's native system |
4.Information we collect & why we use it
As an AI-driven matching platform, data is essential to providing our services through the Platform. This section describes, comprehensively, how the Platform collects and uses your information, and our legal basis for that processing. Please note that Scalis does not provide your information to any third-party AI models, just our own Matching Engine.
This information will vary depending on whether you use the Platform as an Employer or Job Seeker, so be sure to read the parts of this section that apply to your role.
For clarity, much of the data collection and processing described in this section is carried out by automated means. This activity data includes which areas of the Platform you visit (including URLs), which content you view, which information you input, whether and where you click, scroll, hover-over, mouseover, or otherwise interact with or communicate with or through the Platform, the timing of each activity, and time spent on each activity. We collect this data from everyone using the Platform, including users of private browsing mode, “incognito mode,” or similar modes. As described under Our Exchanges of Information, we leverage third-party vendors to collect, record, process, analyze, and store some of this data.
Because it's critical to how the Platform operates, if you do not want your data to be collected, recorded, processed, analyzed, or shared in the manner described in this section, you should adjust your use of the Platform with respect to data collection that is within your control. Don't use the Platform at all if you object to any collection or processing that is necessary to use the Platform.
(a)
Information we collect from all users
| What we collect | How we use it | Why we process it | Legal basis | Retention |
|---|---|---|---|---|
| Account management data - login credentials, permissions, and account actions (such as when your account is created, when you log in, add information, request a service, and any changes to your account). | We collect, analyze, process, and store your account management data. | To create and maintain an account at your direction. | Account management data is processed as part of performance of a contract. | Account lifetime, or as applicable law requires |
| Activity data - areas of the Platform you visit, where you click, scroll, hover over or otherwise interact with the Platform, and when and for how long the activity occurred. | We collect, analyze, process, and store activity data including via automated means For Employers, this may also include actions taken with regard to a Listing or to Job Seeker's resume or application. | For fraud prevention. To improve our Platform. | Our legitimate interests in understanding how users interact with and use our Platform; and keeping our Platform safe and secure. Activity data is monitored to prevent malicious and fraudulent activity and unauthorized use on our Platform as part of performance of a contract. | Account lifetime |
| Communication data - interactions with or through Scalis, via email or notifications | We collect, analyze, process, profile and store your communication data. | To make it easier to apply to jobs and for employers to find candidates. To send Job Seekers relevant Listings, and applications to Employers. To send you relevant marketing emails. To improve our Platform and services. | Our legitimate interests in providing a valid and relevant service to our users and to continue to improve our products and services. We provide an opt out so you can object to marketing messages. Under the limited circumstances where we call you and where the call is recorded, we may rely on your consent. | Account lifetime |
| Contact information - name, phone number, email and address | We collect, process and store your contact information. | To send you marketing and transactional emails, and to send you reminders. To create an account at your direction. To coordinate interviews if you ask us to do so. To contact you and provide services related to campaigns sponsored by Scalis, including posting you materials or prizes. | Transactional emails are sent as part of performance of a contract. Marketing communications and Listing alerts are sent if you consent. | Account lifetime |
| Device information - IP address, device identifiers, user agent. | We collect, process and store your device information. | For fraud prevention. To administer your account and to help you find more relevant Listings. For example, while using a mobile device to access Scalis, Scalis may provide a Job Seeker with relevant Listings that are located within the same zip code as where this activity is taking place. | Our legitimate interests in keeping our Platform safe and secure and to provide a valid and relevant service to our users. We only collect imprecise location data, and only when you have not indicated that you do not wish to share it. | Account lifetime |
| Messaging data (if applicable) - messages that you send through the Platform, including ATS connected to the Platform | We process, monitor, review, store, and analyze such content, including via automated means. | For data analysis, quality control, enforcement of our Terms and other Scalis policies, content moderation, and to improve the Platform and our services. For example, optimizing our search results and Matching Engine, improving Listings, permitting Application management through our ATS, providing personally relevant product features and communications. | Our legitimate interest in keeping our Platform safe and secure. Messaging data cannot be malicious, spam, or fraudulent and is monitored as part of performance of a contract. Depending on the applicable law, we may rely on your consent. | 10 years |
| Payment information (if applicable) - last four digits of your payment card and other verification data | When you use chargeable services, we collect information to facilitate payment and verify your account. Scalis never stores your full card number. | To effect payment for a chargeable service. To facilitate due process and provide information in response to a valid legal process, such as subpoenas, search warrants, and court orders, or to establish or exercise its legal rights or defend against legal claims. | To comply with our legal obligations with respect to financial reporting and valid legal information requests. In our legitimate interest to ensure we are in contact with the correct person. | Per applicable legal requirements |
| Calendar information (if applicable) - your availability and responses to calendar invitations for interviews, including from third-party calendar providers like Google Calendar, if you choose to link them to your account. | We receive and push calendar data through third-party providers you connect, loke Google Calendar, via API. We collect, process, and store calendar information, but we do not provide it to our Matching Engine or any third-party AI model. | To facilitate interviews scheduled through or held on the Platform's interview services. | We collect this information so that Job Seekers are able to interview with Employers as part of performance of a contract. | Account lifetime |
| Social Login data (if applicable) - when you use a Social Login to log into your Scalis account we collect name, profile picture, public profile information, and email address | We store the information collected from your Social Login account to authenticate you as a user of both Scalis and the third party, and to populate your Profile as you instruct | To make signing into and using the Platform easier and more secure. | Consent - If you no longer wish to share data with Scalis from your SSO account, you can adjust your SSO account settings. | Account lifetime, or until you unlink your accounts |
| User feedback and satisfaction data (if applicable) - including ratings and plain text feedback on how we can improve our services. | We process, monitor, review, store, and analyze such content, including via automated means. | To improve our Platform and services. | Our legitimate interest in operating, managing, and improving our Platform and services. | Account lifetime |
(a)
Information we collect from Job Seekers
| What we collect | How we use it | Why we process it | Legal basis | Retention Period |
|---|---|---|---|---|
| Application data - your resume and other materials shared when you apply to a job through Scalis, your activity in relation to that application, as well as scheduling of / participation in an interview | When you apply to a job through Scalis, we process your application data and provide a copy to the chosen Employer(s). | To facilitate your application to a Listing. To help Employers maintain and review Job Seeker applications | With your consent or at your request Performance of a contract with Job Seekers and Employers | Account lifetime, but deidentified application data may be maintained in Employer ATS. |
| Application screening data - answers to Employer screening questions you complete as part of an application process | We pass your screening data to the relevant Employer and may analyze responses. | To improve our ability to help Employers design appropriate, helpful and meaningful screening methods. To facilitate your application process to a Listing. | Performance of a contract between Scalis and an Employer. Our legitimate interest in improving our services. | Account lifetime |
| Assessment data - results of Scalis questionnaires or assessments | We collect, analyze, process, profile, and, in applicable markets, store your assessment data. | To help you find more relevant Listings. To facilitate your application process to a Listing. | Performance of a contract between Scalis and an Employer. Our legitimate interest for analytical purposes in providing a valuable and relevant service to the Job Seeker. | Account lifetime |
| Demographic data - age, race & ethnicity, gender, disability, arrest or conviction history, and protected-class membership | Under limited circumstances, we collect and process special category data. We only collect and process this data in certain markets where permissible by law, such as when such information is required for particular position. We analyze it for specific purposes in line with applicable data protection regulations. The provision of this information is entirely voluntary and will not be used in any determination of your job application. | For evaluating our algorithmic fairness, in line with responsible AI principle. To help Employers hire more inclusively. | Consent, and only in markets where such collection is permitted. | Account lifetime, or until you remove the data |
| Disposition data - the status of your job application and decisions made by the Employer or by you, such as whether you were contacted, interviewed, hired, withdrew your application or rejected an offer | We collect, store, process, and analyze this information. | To further understand the effectiveness of our Platform and their features. | Our legitimate interest in operating, managing, and improving our Platform. | Account lifetime |
| Profile data - including your resume, photo (where applicable), preferences, when you are online or recently active on Scalis, qualifications and assessments information, and any other data included in your Profile. | We collect, store, process, and analyze your profile data. | To help you find more relevant Listings. To send you invitations to apply to certain jobs. To offer suggestions to you when you apply for jobs on third-party websites in our mobile software. To show when you are online or recently active on Scalis. | Performance of a contract as these data are essential to help you find jobs. | Account lifetime, or until you remove your profile information |
| Resume data - resume information you upload, supplement or modify through the Platform. Employers will be presented with your Resume and certain profile information if the Platform determines you are a good match for a Listing. See our Terms under 'Additional Terms for Job Seekers' at Overview to learn more. Resume data can include your work history, education history, certifications, licenses, patents, summary information, and any other data you provide. | We collect, store, process, profile and analyze your Resume data on an ongoing basis, including upon modification or update, as well as make it available for third parties to view if the Platform matches a Resume to a Listing | To enable Employers to invite you to apply to their jobs. To enable our Matching Engine to provide quality matches. | Performance of a contract as these data are essential to help you find jobs. Our legitimate interest for analytical purposes in providing a valuable and relevant service to Employers. You may change the visibility of your resume at any time by accessing your account settings. | Account lifetime, or until you remove your resume |
(c)
Personal information we collect from Employers:
| What we collect | How we use it | Why we process it | Legal basis | Retention period |
|---|---|---|---|---|
| Business information - verification documentation about your business, employee contact details and physical location of business. For example, this may include a Federal Employer Identification Number (EIN), registration information, or other verifiers. It can also include employer screening information. | We collect, process, store and analyze such data to verify that Employers on our Platform are legitimate. This information will be used for internal purposes only, subject to any request by law enforcement or a court order. | To prevent fraud and spam, and to protect Job Seekers. To enhance our service. To improve the accuracy of market analysis and sales strategy. | Our legitimate interest in detecting and preventing fraudulent activities on our Platform, to enhance our services and to focus our sales strategy. Where we are required to comply with a legal obligation. | For data provided for verification purposes, we delete such information after your account has been verified. For information used for billing, we retain in line with legal requirements. |
| Business personnel information - personal information about Employer personnel provided to us to facilitate communication with Job Seekers | We make it available in the manner chosen by the Employer | To facilitate communication between Job Seekers and Employers | Performance of a contract | Until removed by the Employer but no longer than Account lifetime |
| Hiring data - personal information about jobseekers provided to us (including through Employer use of our ATS) | To facilitate the provision of the Employer ATS and aid the Matching Engine in providing quality matches to the Employer and potential Jobseekers | To facilitate the functionality of the ATS by the Employer and to enhance our service. | Performance of a contract | Until removed by the Employer but no longer than Account lifetime |
Any personal information that Scalis obtains from other third-party sources will be processed by Scalis in accordance with this Policy, any applicable third-party terms or policies and all applicable laws. For example, Scalis' use and transfer of information received from Google APIs will adhere to Google API Services User Data Policy, including its Limited Use requirements.
(d)
Feature Purposes
In addition, using these features on the Platform involves additional processing for the purposes described here:
(i)
Resume data
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As a Job Seeker, by uploading your Resume, you are requesting and authorizing Scalis to make your Resume and its data visible through the Matching Engine, in accordance with our Terms. The Platform allows you to supplement and modify Resume data, and we will use any updated Resume data in the same way. Like all other information about you, Resume data is not provided to any third-party AI models. This means that Employers will view your up-to-date Resume data as you make updates and changes, except where otherwise noted while using the Platform.
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Employers and Employer representatives who access your Resume data through the Platform or to whom you apply with a Resume, may choose to share your Resume or Resume data with additional parties. Scalis is not responsible for such sharing. Similarly, when you share your searchable resume directly with a personalized link, we cannot control who sees your resume when you share that link.
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If you do not want the Platform to use your Resume data in this way, you must delete your Account.
(e)
Security
Scalis has implemented technical, administrative and physical security measures to protect your information from unauthorized access, use or disclosure. Still, no data transmission online is 100% secure, so we cannot guarantee or warrant the security of any information you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.
5.Our exchanges of information with others
Since our goal is to make hiring faster and easier for everyone, the primary reason we exchange your information with others is to improve our ability to match talent with opportunities and ensure our Platform works well for Job Seekers and Employers.
This section describes how and why we exchange personal information between users and to contractors and third parties. It also describes exchanges made for certain purposes, like advertising, legal reasons and consensual direct marketing. We may also disclose deidentified and/or anonymized data for these purposes.
(a)
To Employers
Scalis sends Job Seeker personal information to Employers, including, on the instruction of Job Seekers and Employers. Such transfers are performed in the course of the job search, application, and interview process. Job Seeker personal information transferred to Employers in this way is processed in accordance with Scalis's Terms and those of the relevant Employer. This transfer may include sending your application and/or additional candidate information, such as your contact details, to other platforms that process Job Seeker personal information for the Employer, such as the Employer's preferred Applicant Tracking System (ATS) or scheduling platform.
Employers agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing, and storage of personal information, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.
(b)
To Job Seekers
Scalis sends certain Employer-related information to Job Seekers. This includes Listings, Application status (if using the Platform ATS) and may also include certain Employer-related information, such as information about an Employer's activity and responsiveness on the Platform. This can include the Employer representative's name, the Employer's city/state location, whether the Employer has taken or has chosen not to take an action with regard to the Job Seeker's resume or application, whether the Employer has engaged with other Job Seekers or viewed other Job Seekers' Resumes, and whether the Employer has taken an action in regard to a Listing such as pausing or closing it. We do this in order to help Job Seekers evaluate employment opportunities. As an Employer, when you use the Platform (for example by posting a Listing or contacting a Job Seeker), you agree that Scalis may provide this information to Job Seekers.
(c)
To our contractors
In addition to the use of trackers described above, we contract with companies or individuals to provide certain services related to the functionality and features of the Platform, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions. We refer to them as “contractors.”
We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to contractors as necessary for them to perform their services. Contractors are not permitted to use information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:
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Analytics providers, Google Analytics, to tell us how the Platform is doing, such as which parts interest visitors and how long they visit before leaving. Among other data, they may receive your IP address.
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Various hosting services and data processors to provide the infrastructure of the Platform, such as HubSpot, AWS, and Auth0. Among other data, they may receive your IP address.
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Payment providers, namely Stripe , to process payments between you and us, such as for subscriptions or products. These providers receive informati on about your order in order to tie your payment process to your order. We don't receive all of the information you may provide to them as part of that process (for instance, we don't receive full payment-account numbers).
(d)
For personalized ads
We share information from website visitors with advertising partners to make the advertising presented to you more relevant to you. We do not associate the information we share about website visitors with your user account information (if any). We also market the Platform to you through ads facilitated by marketing vendors.
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For example, we use Google to serve ads on the Platform and we may market the Platform to you on third party services through Google. Google uses cookies or unique device identifiers, in combination with their own data, to show you ads based on your visit to morningbrew.com and other sites. You can opt out of the use of the Google cookie by visiting the related Google privacy policy.
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We try to limit how our third-party advertising technology vendors use information they collect from you. Most providers require us to enter contracts that allow them to optimize their ad services and products. Essentially, they combine any information they may gather about you through our Platform with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us.
In the past twelve months, we have shared these categories of personal information with third parties to personalize advertising
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Device Information (including Personal Identifiers)
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Commercial Information
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Internet Activity
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Geolocation
(e)
With your consent or at your request
We may periodically ask for your consent to disclose your information to third parties. Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure. For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications.
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In those cases, the Platform will display a tickbox near an email-entry field explaining that by submitting your information, you agree to share your email with the content provider.
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To be clear, we only exchange information about you with third parties for direct marketing purposes if you opt in, and will only do so until you opt out.
(f)
For legal reasons
Finally, we may disclose personal information:
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In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
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When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements; or
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In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
6.How long we retain your information
We retain your information only as long as we need it for the purposes described under How we use information, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.
How long we need information for those purposes varies by category, and even within categories. These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.
For example, we delete some Internet Activity at some soon as you exit the Platform, whereas we may retain records of your orders for services and products for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.
7.Your rights
(a)
In General
As a user of the Platform, you have rights and choices about your personal information. We want you to be in control of your information, so we want to remind you of the following options and tools available to you:
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Content opt-outs: you may opt-out of any newsletters or promotional communications from us by following the unsubscribe instructions in the communication you receive. You may also opt-out of receiving newsletters and/or promotional communications through our Opt-Out Request Form. We may continue to send you communications regarding the Platform, such as notices about administrative updates, transaction reports, and changes to the Platform, this Policy or the Terms.
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Exercising rights: If any of the location-specific rights listed below apply to you, see Requesting information.
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Disallowing Location Data Collection: When you access certain Platform services, like some of our apps, through a mobile device, you may consent to share your location with us so we can customize your experience. You may change your location sharing settings at the browser or device level at any time.
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Exercising rights: If any of the location-specific rights listed below apply to you, see Requesting information. These rights are provided only to human accountholders, and are not available to Employers or other legal entities, except as required by law.
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Personalized ads: For more about targeted advertising, and how to opt out with your specific browser and device, go to theDAA Webchoices Browser Checkand NAI Opt Out of Interest-Based Advertising . You can download the AppChoices app to opt out in mobile apps
(b)
Rights under GDPR
This section applies to you only if you reside in a jurisdiction where GDPR applies.
For GDPR purposes, the data controller is Sca lis LLC , 1000 Brickell Ave. Suite 71, Miami, FL 33131.
(i)
Lawful bases
If we are aware that you reside in a GDPR jurisdiction, we only collect, use or share information about you when we have a valid reason. This is called a 'lawful basis.' Our lawful bases are described in the tables presented underInformation we collect & why we use it.
(ii)
GDPR rights
Depending on your jurisdiction's enactment of GDPR, you may have these rights:
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Request access (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal data we hold about you.
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Request correction . This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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Request erasure . This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised objected to processing (see below), where we may have processed your personal data unlawfully, or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons. If so, we will notify you at the time of your request.
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Object to processing where we are relying on a legitimate interest (or those of a third party) and you object to particular processing due to a perceived impact on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
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Request restriction of processing during the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
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Request the transfer of your personal data to you or a third party . We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
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Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. For clarity, withdrawal is not retroactive.
We do not charge for access to your personal data or to exercise any of the other rights. However, we may refuse to comply with your request or charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.
(c)
International Data Transfers
If you reside outside the United States, we transfer information about you for processing in the United States . By providing your information to us, you consent to the processing of the information in the United States. The transfer of this information to the United States is necessary for the performance of our contract for use of the Platform.
When we transfer personal data subject to GDPR outside of Scalis , we use standard contract clauses approved by the EU for this purpose, or another appropriate transfer mechanism.
Note that U.S. law is not equivalent to GDPR. As of the Last Updated date, the U.S. has not been deemed an 'adequate ' jurisdiction under GDPR for the purposes of international data transfers. However, the EU and the U.S. are negotiating the terms of an adequacy determination that may go into effect in the years to come.
(d)
Rights under U.S. state laws
This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights, or substantially similar rights . Except as noted in this section, we extend these California rights to residents of those states regardless of whether applicable law in those states includes all of these rights. Please contact us if you feel that you are not able to exercise your rights under your state's law.
(i)
Rights under CCPA
The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA). When we use terminology defined in CCPA in the California-specific sections of this Policy, that terminology has its meanings under CCPA.
The categories of personal information we collect depend on how you use the Platform. They're generally described under Information we collect & why we use it. Those lawful bases map to these CCPA purposes:
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Commercial purposes : At times, the reason we process your information to advance your economic interests or our economic interests. These purposes include performing the contract that you have with us, as embodied by our Terms, which advance our economic interests and yours. For instance, if you order products from us, we use your information to complete your payment and provide your product to you.
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Business purposes : Most often, we process your information for operational reasons, in a reasonably necessary and proportionate manner (i.e., for business purposes under CCPA). For instance, we analyze behavior on our services to continuously improve our offerings, suggest Listings or Job Seekers that may interest you and promote our own services, we process information to help keep our accountholders safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
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Comply with applicable laws and regulations : We also process your information as described above where necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement.
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Consent : From time to time, we may ask for your consent to collect specific information, such as your precise geolocation, or use your information for specific reasons, like messaging your email address or phone number for direct marketing purposes. In general, you may withdraw your consent by changing your settings (such as browser or device settings) or following instructions provided with information we send you on a consent basis (such as clicking 'unsubscribe' in any email or replying 'STOP' to any text we send you). You may always withdraw your consent at any time - just contact us.
For clarity, we have collected personal information for these CCPA categories of business and commercial purposes in the last twelve months:
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Advertising and Marketing
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Error Management
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Internal Research
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Provide Products or Platform
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Quality Assurance
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Security
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Short-Term Transient Use
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We also "share" and "sell" (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.
The categories of third parties to whom we disclose and sell or share personal information are under for personalized ads and with your consent or at your request above.
Under CCPA, California consumers have the following rights:
(1)
Rights to Know, Access, Correct and Delete.
You have the right to request that we disclose, correct and delete personal information about you that we have collected. Your right to know includes the personal information we have sold or shared or disclosed for a business purpose or a commercial purpose.
Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:
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comply with legal obligations;
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allow you, other consumers, or us to exercise free-speech rights or other legal rights;
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complete an obligation that you have requested (for instance, if a product you purchased carries a warranty or could reasonably be subject to recall under applicable law); or
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if we use the information only for internal purposes reasonably aligned with consumer expectations.
(2)
Rights to Limit and Opt-Out of Sharing/Sale
You also have the right to direct us (1) not to share or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Platform to you.
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To opt out of the sharing of your information, please use our Data Request Form or the 'Do Not / Share My Personal Information' link on our homepage
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To exercise your right to limit our disclosure and use of your sensitive Personal Information, please use our Data Request Form or the 'Limit Use of my Sensitive Info' link on our homepage.
As of the Last Updated date, we have no knowledge of any use of personal information we collect from individuals under the age of 16 for 'sale' or 'sharing' purposes.
(3)
Right of No Retaliation
CCPA prohibits us from discriminating against you if you exercise rights under CCPA, except when you opted in to a financial incentive involving certain of your personal information, and subsequently restrict our use of that personal information through a CCPA rights request.
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For example, if we offer you a discount code for consenting to receive marketing emails, and you then require us to delete your email address, we may not honor that discount code.
Your right of no retaliation doesn't need to be exercised. We never retaliate against anyone exercising their rights under this Policy or CCPA.
(4)
Preference signals
Our goal is for the Platform to automatically respond to compliant signals by opting California residents out of any sharing or sale of their personal information in a frictionless manner. At this time, we are evaluating how to configure the Platform to automatically honor Global Privacy Control signals in a frictionless manner.
Please contact us if you believe the Platform collected or processed your information in a manner inconsistent with your opt-out preference signal.
(5)
Request process for CCPA rights
To submit a CCPA request relating to the foregoing rights, please use our Data Request Form or contact us with 'California Privacy Rights Request' in the subject line of your email or the beginning of your letter. The process described under Requesting information generally applies to requests to exercise CCPA rights. However, in addition:
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A California resident's authorized agent may submit CCPA rights request.
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Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described below. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.
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An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.
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We will acknowledge your request within 10 days, and our goal is to fulfill your request within 45 days. However, we may you that we will require up to 45 further days to fulfill your request, along with an explanation of why our response is delayed.
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We provide responses in the manner we receive your request (i.e., with an email response to an email request).
(ii)
Other California law
Because we only give your information to third parties for direct marketing purposes with your consent, and always allow you to opt out of direct marketing communications after opting in, we believe we are not currently required to comply with California Civil Code Section 1798.83.
(d)
Requesting information
(i)
Submitting requests
To exercise any rights described in this Policy, please use our Data Request Form or contact us. Your request must:
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provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.
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not include social security numbers, driver's license numbers, third-party account numbers, credit or debit card numbers, or health information.
(ii)
Verifying requests
We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain. If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you.
If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.
(iii)
Responses to requests
We will respond to your request as quickly as we can, considering the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.
Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers' account with us, or the security of our systems or networks. We do not disclose account passwords or any other non-personal information that enables access to an account.
With respect to deletion requests:
all personal information in your Application Data is removed from our Platform, but nonidentifiable information derived from Application Data remains accessible to the Employers who received your application.
W e also reserve the right to retain an archive of any deleted information, to the extent permitted by law.
We may also retain deidentified or aggregate data derived from information about you.
8.Use by minors
The Platform is intended for adults and minors over the age of 16 who are legally able to work. We do not knowingly collect information from anyone under the age of 16, and we do not share or sell information about anyone under 16 without affirmative authorization. If we learn that we have collected information from a child under age 16, we will delete that information as quickly as possible.
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If you are under 16: sorry, but please leave the Platform. If you've already sent us information, please contact us first so we can delete it.
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If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with information, please contact us.
Cookie Policy
Last Updated: November 7, 2023
This Cookie Policy helps to explain the occasions when and why Cookies are used in connection with visits to the Platform. By using or accessing our Platform (as defined in our Privacy Policy), you agree to Scalis 's use of Cookies as outlined below.
We encourage you to review the Last Updated date above to determine when it was last amended. Any changes to the Cookie Policy become effective on the Last Updated date indicated below. By using the Platform or providing information to us following such changes, you will have accepted the amended Cookie Policy.
In short, our Platform responds to browser and device settings and location-based rules that may block or restrict Cookies. Cookie usage will also reflect any opt-outs you provide through the Platform.
9.What is a Cookie?
We use cookies, web beacons, pixel tags, and similar technologies (collectively “ Cookies ”) to collect information about your browsing activities and to distinguish you from other users of our Platform. To be precise:
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Cookies are small files of letters and numbers that we store on your browser or device. We may also employ cookies so that we remember your computer when it is used to return to the Platform to help customize your experience. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Certain cookies will be used on the Platform regardless of whether you are logged in to your account or not. We may associate personal information with a cookie file in those instances.
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Session cookies are temporary cookies that remain in the cookie file of your browser until you leave the Platform. We use session cookies to track the total number of visitors to our Platform.
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Persistent Cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
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Pixel tags and web beacons are tiny graphic images placed on web pages or in emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our Platform.
10.Why we use Cookies
Cookies improve your experience when you use our Platform and aid our improvement of the functionality of our Platform. In many cases, the information we collect using Cookies and other tools is used in a non-identifiable way, without any reference to personal data. We may use Cookies to make our Platform usage more efficient and to tailor your browsing preferences and improve the functionality of our Platform. Cookies can be used for performance management, collecting information on how our Platform is being used for analytics purposes. They can also be used for functionality management, enabling us to make the user's visit more efficient by, for example, remembering language preferences, passwords and log-in details.
11.Types of Cookies
Below is an overview of the types of Cookies that we and third parties may use to collect Personal Information.
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Strictly necessary cookies. Some Cookies are strictly necessary to make our Platform available to you. We cannot provide you with our Platform without this type of cookie. For example, these cookies allow us to provide the login functionality.
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Functional cookies. These Cookies are used to recognize you when you return to our Platform. This enables us to optimize your login experience, and remember your preferences (for example, your choice of language or region).
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Analytical or Performance cookies. We also use Cookies for Platform analytics purposes in order to operate, maintain and improve our Platform. We may use our own analytics Cookies or use third party analytics providers such as Google tag manager, to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, apps, and online resources. You can opt out of Google tag manager without affecting how you visit our Platform by going to google.com/dlpage/gaoptout or via Google's Ads settings.
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Advertising cookies. These Cookies help us and our advertising partners to serve more relevant advertising to you.
12.How to block Cookies
You can block Cookies by setting your internet browser to block some or all the Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Platform. By using our Platform, you consent to our use of Cookies and our processing of information collected through such cookies, in accordance with this Cookie Policy and our Privacy Policy. You can withdraw your consent at any time by deleting placed cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Platform using your browser's anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Platform may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before our Platform stores or places them on your computer or other device.
