Privacy Policy

Shortlist Project, Inc. (the “Company,” “we,” “us” or “our” or “Shortlist Project Inc”) runs www.shortlist.co (the “Site”).

This privacy policy (“Privacy Policy” or “Policy”) informs you of our policies regarding the types of Personal Data (as defined below) the Company gathers or handles, how we collect, use and disclose Personal Data and the choices affected individuals have regarding our use of, and their ability to correct, the Personal Data relating to them.

This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

This privacy policy applies to all personal data received by the Company whether in electronic, paper or verbal format.

We use your Personal Data only for providing information to you and improving the Site.

By using the Site, you agree to the collection and use of information in accordance with this Policy.

The Company adheres to the Privacy Shield Framework concerning the transfer of personal data from the European Union (“EU”) to the United States of America. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

The Company complies and commits to cooperate with the EU Data Protection Authorities under the EU-U.S. Privacy Shield Framework, in conformity with the Supplemental Principles on Human Resources Data Authorities within the HR relationship

The Company complies with the EU-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  The Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

In compliance with the Privacy Shield Framework,Shortlist Project, Inc. commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Principles should first contactShortlist Project, Inc.:

Shortlist Project, Inc., HQ
ATTN: Joey Fraiser
650 California St
CA 94108
United States
info@shortlist.co
+1 (646) 712-9306

We also have other data mechanisms in place that legitimize data flows, such as Model Clauses.

Shortlist Project, Inc. has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Shortlist Project, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Definitions

For the purposes of this Statement,  “Personal Data” or “ Information” means information as defined by EEA Data Protection Laws (defined below) that (1) is transferred from the EU to the United States in reliance on the Privacy Shield Framework; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked either directly or indirectly to that individual. “Sensitive Personal Data” means Personal Data that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Principles

Notice

We notify individuals about the personal data we collect from them, how we use it and how to contact us with privacy concerns. We notify individuals of the purpose for which the Company or its affiliates or representatives collect and use individuals’ respective Personal Data and the types of non-agent third parties to which the Company discloses or may disclose that Information. We will provide notice in clear and conspicuous language when individuals are first asked to provide Personal Data to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.

Choice

Company shall provide the individual with the choice and means for limiting the disclosure of their Personal Data. The Company will offer individuals the opportunity to choose (opt out) whether their Personal Data is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Consent for Personal Data to be collected, used, and/or disclosed in certain ways (including opt-in consent for Sensitive Personal Data) may be required in order for an individual to obtain or use our services.

For Sensitive Personal Data, the Company will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Company shall treat Sensitive Personal Data received from an individual the same as the individual would treat and identify it as Sensitive Personal Data.

Such consent is provided through a clear affirmative action such as like a click on a button or/and ticking a box. Company shall treat Sensitive Personal Data received from an individual the same as the individual would treat and identify it as Sensitive Personal Data.

Disclosures and Onward transfers

We do not disclose an individual’s Personal Data to third parties, except when one or more of the following conditions is true:

  • We have the individual’s written permission to make the disclosure.
  • The disclosure is required by lawful request by public authorities.
  • The disclosure is required by law or mandatory professional standards. The disclosure is reasonably related to the sale or other disposition of all or part of our business.
  • The information in question is publicly available.
  • The disclosure is reasonably necessary for the establishment of legal claims.
  • The disclosure is to anotherShortlist Project, Inc. entity or to persons or entities providing services on our or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
  • Is subject to law providing an adequate level of privacy protection; or
  • Has agreed to provide an adequate level of privacy protection.

We may transfer Personal Data from one jurisdiction to another.  Privacy laws vary by jurisdiction, and some may provide less or different legal protection than others.  However,Shortlist Project, Inc. will protect Personal Data in accordance with the Privacy Shield Program regardless of the jurisdiction in which the data resides.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Shortlist Project, Inc.is potentially liable.

  1. Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to Shortlist Project, Inc. These third party service providers are required not to use your Personal Data other than to provide the services requested by Shortlist Project, Inc.Shortlist Project, Inc. requires its service providers or any third party to whom it discloses Personal Data and who are not subject to the laws based on the EU Data Protection Directive 95/46 and Directive 2002/58/EC, and in each case as amended, replaced or superseded from time to time, including without limitation by the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR”) and any data protection laws substantially amending, replacing or superseding the GDPR following any exit by the United Kingdom from the EU, or,  and to the extent applicable, the data security or data privacy laws of any other country (collectively “European Economic Area (“EEA”) Data Protection Laws”); or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Privacy Shield principles.
  2. Affiliates and Acquisitions. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this  Privacy Policy.
  3. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below),Shortlist Project, Inc. may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Shortlist Project Inc; (c) to protect or defend the rights or property of Shortlist Project, Inc. or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use.Shortlist Project, Inc. may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Access Requests by Public Authorities

Company may be required to disclose your personal information in response to lawful requests from public authorities, including to meet national security or law enforcement requirements. Where permitted by law, the Company has the option to issue reports relating to data protection inquiries.

Data Security

We employ various physical, electronic, and managerial measures, including education and training of our personnel, designed to reasonably protect the Information from loss, misuse and unauthorized access, disclosure, alteration or destruction.

Personal Data collected or displayed through aShortlist Project, Inc. site is protected in transit by standard encryption processes. Company cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

Company process Personal Data only for the limited and specific and relevant purpose for which it was originally collected or authorized by the individual. To the extent necessary for such purposes, Company take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.

We maintain a strict “No-Spam” policy. We do not sell, rent, or otherwise give your e-mail address to any non-agent third party organization. If this practice should change in the future we will update this policy accordingly, identify the third parties, and provide individuals with opt-out choice. Shortlist Project, Inc. complies with the CAN-SPAM Federal Law.

Access

Company shall allow an individual access to their Personal Data and allow the individual to correct, amend or delete inaccurate information, where it is inaccurate or has been processed in violation of the Principles. The individual will need to provide sufficient identifying information, such as name, address, and birth date. We may request additional identifying information as a security precaution such as possibly a national identifier (e.g. a Social Security number). In addition, we may limit or deny access to Personal Data where providing such access would be unreasonably burdensome or expensive in the circumstances, or where the burden or expense of providing such access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. In some circumstances, we may charge a reasonable fee, where warranted, for access to Personal Data.

Accountability and Enforcement

Company uses a self-assessment approach and program to assure compliance with this Statement and monitor its adherence to the Principles.  This program will include a statement, at least once a year, signed by an authorized representative of the Company, verifying that this Statement is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data in accordance with the Principles.

Type of Information

Note differences in this policy regarding the term “human resources data”. Human Resources Data refers to Personal Data about employees, past or present, collected in the context of the employment relationship. Information other than Human Resources data includes the following: customer, client, visitor, and clinical trial data.

Shortlist Project Inc Privacy Policy covers: Personal Data other than human resources data

Purposes for which Shortlist Project, Inc. collects and processes Personal Data in reliance on the Privacy Shield:

  1. General Use
    We use your Personal Data in the following ways:

    • facilitate the creation of and secure your account on our network;
    • identify you as a user in our system;
    • provide improved administration and quality of experience of our Site and Services;
    • provide the Services you request;
    • send you administrative e-mail notifications, such as security or support and maintenance advisories;
    • respond to your inquiries related to employment opportunities or other requests; and
    • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Shortlist Project, Inc..
  2. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve user experience.Shortlist Project Inc reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.
  3. Disclosure of Your Personal Data. We disclose your Personal Data, End User Contact Data and Completed Contact Data as described elsewhere in this Privacy Policy.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield Framework. We will post any revised policy on this website.

Information subject to other policies

The Company is committed to following the Principles for all Personal Information within the scope of the Privacy Shield Framework. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this privacy policy. Under certain conditions, more fully described on the Privacy Shield website, individuals may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Contact us

In compliance with the Privacy Shield Framework, Shortlist Project Inc commits to resolve complaints about our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding this Statement or our compliance with the Principles should first contact Shortlist Project Inc:

Shortlist Project, Inc., HQ
ATTN: Joey Fraiser
650 California St
CA 94108
United States

info@shortlist.co

+1 (646) 712-9306

Organization Corporate Officer Certifying Shortlist Project, Inc.’s compliance with the Privacy Shield Framework:

By submitting this self-certification, the below listed corporate officer attests that he/she is authorized to submit the self-certification on behalf of your organization and all entities or subsidiaries indicated below.

Martin Konrad
CEO
info@shortlist.co
+1 (646) 712-9306