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.
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.
“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.
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 firstname.lastname@example.org.
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.
- 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.
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.
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.
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.
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 email@example.com If requested to remove data, we will respond within a reasonable timeframe.
Shortlist Project Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Shortlist Project Inc., HQ
ATTN: Joey Fraiser
650 California St
+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.