LAST UPDATED: October 22, 2019

Suited Inc. (“Suited”) is committed to safeguarding your information. We understand the importance of privacy and want you to make an informed decision about sharing information with us when visiting our website and using our services.

This privacy policy (“Privacy Policy”) describes the services offered through the Suited website at www.wellsuited.com (the “Site”) and how we collect, use, share, and protect personal information we obtain through the Site. We will refer to the Site and related services offered through the Site as the “Services.” This Privacy Policy applies to all visitors, users, and others who access the Services. Please read the Privacy Policy carefully to understand our practices regarding your information and how we will treat it. By visiting the Site and/or using the Services, you acknowledge that the collection, use, and sharing of your information will take place as described in this Privacy Policy.

So we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean information about an individual that (either by itself or when combined with information from other available sources) allows that individual to be identified, including, your name, address, telephone number, or e-mail address. When we use the phrase “Anonymized Information” in this Privacy Policy, we mean information that does not allow for the identification of an individual or is not associated with or linked to your Personal Information. Anonymized Information does not enable identification of or contact with individuals.

If you have questions regarding the Privacy Policy or about Suited, please contact us by email at support@wellsuited.com.

1. INFORMATION WE COLLECT

We collect information in several ways to match qualified candidates with employers and to enhance your experience with Suited.

INFORMATION YOU GIVE TO US

Account Creation for Certain Companies and Candidates
To create an account, you provide Personal Information including your name, email address, and a password.

We also collect data and Personal Information from you when you provide or upload it to the Services, such as when you fill out a form, submit a resume or other document, or respond to a survey or questionnaire. This can include your mobile phone number, demographic data, resumes, personality and cognitive ability assessments, background information, location data, current and former employment data, GPAs, and standardized test scores.

INFORMATION FROM OTHERS

We collect data and information that others provide when they use our Services, including information about you.

Social Networking Service Information
If you create an account with Suited through one of the Social Networking Services (“SNS”) that we support (such as LinkedIn), we will receive some Personal Information in accordance with your privacy settings with the SNS.

Social Provider Information
We may use service providers to log usage data about you and your computer or mobile device, and how you use and interact with the Services, such as when you view or click on ads or perform a search. For example, when you access the Services, we may use log-ins, cookies, device information, and internet protocol (“IP”) addresses to identify you and log your use. We collect this technical data to analyze usage trends and give us more information about how people use the Services to better the user experience.

From Partner Companies
We may receive Personal Information about you if you interact with and/or apply to our customers and partners, such as employers or prospective employers having a relationship with Suited (each a “Partner Company”).

COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES

Like many online services, we may use cookies, web beacons, or other similar technologies to collect information depending on the Services you use. These technologies help us make the Services and your experience better. For example, we use cookies to see which of our Services visitors use and we use web beacons to determine whether users open or act on our communications. You can control cookies through your browser or operating system settings, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our Services.

DO NOT TRACK

At this time, we do not have a system to respond to Do Not Track requests.

2. HOW WE USE YOUR INFORMATION

We use the data that we have about you to provide, support, personalize, and make our Services more relevant and useful to you and others. How we use your information will depend on the Services you use.

We may use the information we collect from and about you to: (1) process, facilitate, and administer your account; (2) provide and deliver services that you request; (3) allow you to search for Partner Companies;(4) allow you to interact with and/or apply for employment at  Partner Companies; (5) communicate with you, including about our Services and policies, to provide customer support, to send marketing communications, and to respond when you contact us; (6) create Anonymized Information; (7) operate, maintain, and improve our Services; (8) to deliver ads; and/or (9) to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity. To the extent we deliver marketing emails, you may change your communication preferences to opt out of marketing emails, but please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

Please note that our Services involve evaluating your candidacy for a job by considering the information you provide through our Site. Our platform helps our Partner Companies understand you as an individual by using machine learning to analyze your profile and match it with attributes shown to drive success at those Partner Companies and/or in their industry.

If you do not provide the information requested, we may not be able to provide some or all of the Services you have requested, as the information required (1) for contacting you is necessary for us to keep in touch with you and provide the services; and (2) to complete a profile is necessary for our prediction models to evaluate your employment candidacy.

Please note that the demographic questions on gender, ethnicity, and age are optional; they include the option not to supply such information.

3. HOW WE SHARE INFORMATION

Candidates use the Services to connect with Partner Companies. We make this possible by sharing your information. We may share your information (1) exactly as you provide it to us; (2) in a manner consolidated, but not substantively altered, by us; or (3) in the form of a result or score derived from our technology’s analysis of your information. Each of the foregoing forms of your information are considered Personal Information, and may be shared by us as described in the following paragraph. In addition, we may share with third parties Anonymized Information that we create from the information we collect from and about you – that is, information we strip of your name, contact information, and/or any other information that could permit you to be identified as an individual. Anonymized Information is not considered your Personal Information.

We may share the Personal Information we collect from and about you (1) with Partner Companies, with your consent based on your account settings; (2) for legal and safety purposes, including in response to lawful requests by public authorities to meet national security, law enforcement, or other requirements; (3) to protect the rights of Suited, our agents, customers, and others, including by enforcing our agreements and policies; (4) with a new owner if the ownership or control of all or part of our Services changes; and/or (5) with third parties we contract with to perform functions related to the Services (“Service Providers”). Service Providers will have access to your Personal Information needed to perform their business functions, but may not use or share that Personal Information for purposes outside the scope of their functions related to the Services.

4. LEGAL BASIS FOR PROCESSING

The following legal bases apply to the ways in which we use individual’s Personal Information set out in sections 2 and 3:

  1. We process Personal Information on the basis of our performance of our contract with the individual, or in order to create such a contract. Our contract with the individual requires us to collect their data, in the form of answers provided to our questionnaire, and to prepare results as set out in this policy and the Terms of Service.
  2. We will rely on the individual’s consent with respect to (1) the processing of information relating to age, gender, and ethnicity (collectively, “Demographic Information”) (the provision of which is entirely optional), and (2) the transfer of Personal Information, including but not limited to Demographic Information, to one or more Partner Companies. This consent can be withdrawn at any time, but once the information has been passed to a Partner Company, that information cannot be retrieved.
  3. We also process the information provided by an individual in our legitimate interests in ensuring our business is conducted legitimately, to a high standard, and to market our Services.

Although we use your Personal Information for profiling, all we create is a test result which we will, with your consent, share with prospective employers. We do not make any decisions by automatic means.

5. LINKS TO OTHER SITES

The Services may contain links to other third-party sites. Any information you provide on those sites is subject to that third party’s privacy policy. Our Privacy Policy does not apply to such sites, and we are not responsible for the privacy and security practices and policies of those third-party sites.

6. CHILDREN

The Services are not directed to children and children are not eligible to use the Services. We do not collect or maintain Personal Information from individuals we actually know are under 16 years of age, and no part of the Services is designed to attract individuals under 16 years of age. If we later learn that a user is under 16 years of age, we will take steps to remove that user's Personal Information from our databases and to prevent the user from utilizing the Services.

7. RETENTION

As part of our Services for Partner Companies, we regularly build and update predictive models which are used by Partner Companies to evaluate your employment candidacy. Every time a model is built or updated, we must reevaluate your employment candidacy using the new model and the information you have provided through the site. Therefore, we retain the information you provide as long as you have an active account with Suited.

If you request to delete your account, we will retain your information for a period of one (1) year to allow you to reinstate your account in case you change your mind. After a period of one (1)year, your information will be anonymized by removing your Personal Information. Your Personal Information will then be deleted and the Anonymized Information will be included in our statistical database.

If you do not log in to the Suited Site for a period of five (5) years, we will consider your account inactive and your information will be anonymized by removing your Personal Information. Your Personal Information will then be deleted and the Anonymized Information will be included in our statistical database.

8. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to protecting the security of your Personal Information. While we take steps to help ensure the integrity and security of our network and systems, including employing certain physical, administrative, and technical security measures, we cannot guarantee our security measures.

9. CHANGES TO OUR PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we make any changes, we will change the Last Updated date above. We also may provide additional notice, as applicable, depending on the type of change. If you object to any changes, you may stop using the Services. Your continued use of the Services after we publish or otherwise provide notice about our changes to the Privacy Policy means that you have read and understood the updated Privacy Policy.

10. PRIVACY SHIELD

Suited complies with the EU-U.S. and Swiss-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 and Switzerland to the United States. Suited 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. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Suited is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.

Suited's accountability for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. Suited remains responsible and liable under the Privacy Shield Principles if Suited's third-party agents process Personal Information on Suited's behalf in a manner inconsistent with the Principles, unless Suited demonstrates that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Suited commits to resolve complaints about our collection or use of your Personal Information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Suited at: support@wellsuited.com.

Suited has further committed to refer unresolved Privacy Shield complaints to JAMS (Judicial Arbitration and Mediation Services, Inc), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. As further explained in the Privacy Shield Principles, a binding arbitration option may be used to address residual complaints not resolved by any other means.

11. GENERAL DATA PROTECTION REGULATION ("GDPR")

If you are based within the EU, in certain circumstances you will also have the following rights:

  1. Right to access: the right to request certain information about, access to and copies of the Personal Information about you that we are holding (please note that you are entitled to request one copy of the Personal Information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
  2. Right to rectification: the right to have your Personal Information rectified if it is inaccurate or incomplete;
  3. Right to erasure / “right to be forgotten”: where the processing of your information is based on your consent, the right to withdraw that consent and the right to request that we delete or erase your Personal Information from our systems (however, this will not apply if we do not rely on your consent to carry out the processing or if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
  4. Right to restriction of use of your information: the right to stop us from using your Personal Information or limit the way in which we can use it;
  5. Right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
  6. Right to object: the right to object to our of your Personal Information including where we use it for our legitimate interests or for marketing purposes.
  7. Right to lodge a complaint about us to a supervisory body in your country of work or residence (for instance, the Information Commissioner’s Office in the UK).

Requests in relation to the above rights should be sent to: support@wellsuited.com.