Privacy Policy

Last Updated: 21 May 2018

Shortlist Project Inc. (the “Company,” “we,” “us” or “our”) runs www.shortlist.co (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.
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.

We use your Personal Information 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.

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

Shortlist Project Inc. complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  The Company has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Definitions

“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

Type of personal data Shortlist Project Inc. collects:

  • First Name and Last Name
  • Email address
  • Profile picture

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 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.

Choice

The Company will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a non-agent 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.

Individuals choosing to opt out should contact the Company by sending an email request to privacy@shortlist.co.

For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively or explicitly (opt in) 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 Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward transfers

    1. Third Party Service Providers. We 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 to whom it discloses Personal Data 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 privacy inquiries.

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

Data Security

Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information 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 Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing 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.

Shortlist acknowledges that individuals have the right to access the personal information that we maintain about them. An individual who seeks access, or who

seeks to correct, amend, or delete inaccurate data, should direct their query to info@shortlist.co If requested to remove data, we will respond within a reasonable timeframe.

Enforcement

Company uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy 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 Information in accordance with the Principles.

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

Contact us

In compliance with the Privacy Shield Principles, Shortlist Project Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Shortlist Project Inc. at:

Shortlist Project Inc., HQ

ATTN: Joey Fraiser

650 California St

CA 94108

United States

info@shortlist.co

+1 (646) 712-9306

Shortlist Project Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, 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.

If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”).  To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work.  Shortlist Project Inc. agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel.

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.

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.

Attract, hire and retain top talent

Take the tour