OneTen Privacy Policy

Last Updated: August 21, 2023

This Privacy Policy describes the data protection practices of OneTen Coalition, Inc. (“OneTen,” “we” “us,” or “our”) with respect to the operation of the OneTen Platform. This Privacy Policy applies to all websites and services operated by us that link to this Privacy Policy and related online and offline services offered by us (collectively, the “Services”). This Privacy Policy explains: (i) how we process the information you provide us when you access or use the Services; and (ii) options you have with respect to our use of your information.

BY ACCESSING OR USING THE PLATFORM AND ASSOCIATED SERVICES, YOU AGREE TO OUR USE OF YOUR INFORMATION AS DESCRIBED HEREIN, AND ALSO AGREE THAT THE ONETEN PLATFORM TERMS OF USE GOVERN YOUR USE OF THE SERVICES. Terms which are capitalized but not defined in this Privacy Policy have the meanings assigned in the Terms of Use. As stated in the Terms of Use, the OneTen Platform is only available for use by individuals located in the United States.

This Privacy Policy includes the following sections:

Information We Collect
How We Use Your Information
Analytics, Cookies, and Similar Technologies
How We Disclose Your Information
Your Rights and Choices
Third Party Links and Features
Children’s Privacy
How We Protect Your Information
Retention of Information
Changes to This Privacy Policy
How to Contact Us

1. Information We Collect

When you use the Services, we collect a variety of information from and about you as described in this section. We collect this information from a variety of sources such as: (i) directly from you (through our website and surveys, or when you contact us or request information from us); (ii) employers; (iii) universities, colleges, and talent development organizations (collectively, “Talent Developers”); (iv) the computer or device you use to access the Services; and (v) others, such as third-party partners and credential verification providers. We may combine the information collected through these various sources and information we derive from it, and use such combined information in accordance with this Privacy Policy.

Information we collect from you, your employer, Talent Developers, or credential verification providers. We may collect the following types of information from these sources:

Contact information, such as your name, email address, phone number, and mailing address.
Log-in information, such as the username and password you use to access the Services.
Demographic information, including your age, gender, race, military or veteran status, and career interests, and/or other self-identification information you may choose to provide. Note that certain of your demographic information may be considered “sensitive personal information” under applicable laws, and OneTen will collect and process sensitive personal information in accordance with such laws.
Preference information, such as job and career pathway preferences and goals.
Professional/Employment information, such as your role, the name of your employer, your employment history, the industry in which you work, your areas of expertise, licenses, and memberships.
Education and professional development information.
User-generated content and messages, such as information you post to the Services or messages you send us when requesting customer support.

Information we collect from your computer or device. As you use the Services, we and our Suppliers may automatically collect information about the computer or device you use to access the Services. This session-based information includes your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).

To collect this information, we and our Suppliers may also make use of “cookies” or similar tools that track, measure, and analyze the behaviors and usage patterns of our users as further described in Section 3 below.

Information we collect from others. We and our Suppliers may receive information about you from other sources, including third parties that help us update, expand, and analyze our records or prevent or detect fraud. We and our Suppliers may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. In addition, if you choose to log in, access or otherwise connect to the Services, or contact us, through a social networking service (such as Facebook), we and our Suppliers may collect your user ID and username associated with that social networking service, as well as any information you make public using that social networking service. We and our Suppliers may also collect information you have authorized the social networking service to disclose to us. Information received through such platforms is governed by the privacy settings, policies, and/or procedures of the platform, and we encourage you to review them. We and our Suppliers may obtain information about potential job candidates from (i) third parties who provide data they have collected from various sources commercially and (ii) publicly available sources where job candidates have made available their professional information including resumes, such as professional social networks or employment-related search engines for job listings. The information obtained from these sources generally includes contact information, professional and educational backgrounds, and information included in resumes. Obtaining this information helps companies locate individuals who are the right fit for their employment needs and helps those potential job candidates find new job opportunities that may interest them and/or be a better fit for their professional skills.

2. How We Use Your Information

How your personal data is used will be subject to the choices you make in your account settings and controls.

We and our Suppliers may use the information collected from and about you to:

Provide and offer the Services to you and verify your information.
Respond to your requests for information and provide you with more effective and efficient customer service.
Contact you in connection with your use of the Services and future Services.
Analyze use of the Services to better understand how users are interacting with the Services, improve the Services, and create new products and services.
Improve content and opportunities presented to you.
Secure the Services, resolve technical issues, and investigate and help prevent fraud, security issues, and abuse.
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.
For any other purpose with your consent.

Aggregate/De-Identified Information. We or our Suppliers may aggregate and/or de-identify your information collected through our Services so that such information can no longer be traced to the specific individual or device (“Aggregate/De-Identified Information”). We or our Suppliers may use such information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers and partners.

3. Analytics, Cookies, and Similar Technologies

We or our Suppliers may use cookies and similar tools to analyze use of the Services and deliver features of the Services, to help us understand how users engage with the Services, and to improve your experience. Such features may appear on our Services, or on other websites or services. We use these technologies in order to offer you a more tailored experience in the future.

A cookie is a small text file that is placed on your computer or mobile device when you use the Services, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Services and associated advertising; and (iii) access user cookies.

You can learn more about opting out of analytics from our third-party providers by visiting their respective opt out pages and the Digital Advertising Alliance. Please note that using these opt out options does not mean that you will not receive advertising while using the Services or while you are browsing the web. We are not responsible for maintaining these opt out choices or for the advertising activities of third parties.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

Certain U.S. laws (such as the privacy law in Colorado, which is the only state privacy law to apply to OneTen as a nonprofit) treat the disclosure of “personal data” to analytics and advertising partners as the “sale” or the “processing” of personal data for “targeted advertising” purposes (with all terms in quotation marks as defined in applicable law). To opt out of these uses of your personal data, please use the opt out mechanisms above.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.

4. How We Disclose Your Information

Please note that we do not disclose your information to third parties for their direct marketing purposes without your permission. We and our Suppliers may disclose your information in the following ways:

Hiring Companies. In order to connect potential job candidates with Hiring Companies in the Platform, we may disclose your information to Hiring Companies and their authorized users and service providers. Hiring Companies and their authorized users may include companies that created the job positions or act as intermediaries such as counselors or recruiters for such companies and in turn may forward your submitted information to the employers. Hiring Companies may also choose to implement the Platform with service providers they select, and your information may be disclosed to those service providers. The websites and services of Hiring Companies and their authorized users and service providers are outside of our control and are not covered by this Privacy Policy, and we and our Suppliers are not responsible for their selection, content, security, or privacy practices.
Your Employer as our Partner. To provide administrative access of the Platform to you as an employee of either a Hiring Company or a Talent Developer.
Talent Developers as our Partners. To facilitate job matching, training, advancement, and participation in the Services, it is necessary for us to provide our Talent Developer partners with information about eligible and participating Candidates regarding applicable matches, onboarding, and job status. If you were invited by a Talent Developer onto the Platform, we may allow that Talent Developer to view your profile and contact you within the Platform to facilitate job matching, training, advancement, and participation in the Services.
In Accordance with your Account Settings. You may be able to choose whether your information is visible to Hiring Companies, Talent Developers, and Candidates in OneTen’s network and on the Services.
Our Affiliates. We and our Suppliers may disclose your information to our affiliates (including companies under common ownership or control) in order to provide Services to you.
Service Providers. We work with third party Service Providers to assist us with the provision of Services to you (e.g., without limitation, website hosting, app design, maintenance services, database management, web analytics, research, app analytics, billing, payment processing, fraud protection, marketing, improvement of Services). These Service Providers have access to your information only to perform the respective tasks assigned to them on our behalf.
Compliance with Laws. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We and our Suppliers may disclose your information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary in our good faith determination to comply with any legal obligation, enforce or apply our Terms of Use, respond to claims and legal process, protect our Services, users, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).
Sale or Transfer of Business or Assets. We and our Suppliers may disclose some or all of your information in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In such circumstances, your information may also be transferred as a business asset. If another company acquires our business, or assets, that company will possess the information maintained by us and may continue to use it for compatible purposes. Any such company will assume the rights and obligations regarding your information as described in this Privacy Policy.
Other Legitimate Business Purposes. We and our Suppliers may also disclose your information when it may be necessary for other legitimate purposes as reasonably determined by us and in accordance with applicable law. Such purposes include our interests in conducting our business, fulfilling contractual obligations, and managing and delivering the best services on the Platform, as well as the interests of the Hiring Companies and Candidates’ interests in engaging with each other.
With Your Consent. We and our Suppliers may disclose your information for any purpose with your consent.

5. Your Rights and Choices

OneTen is committed to accuracy, precision, and transparency in processing your information. To keep your information current and complete, to request access to your information, or to request deletion of your information, please update your information within the Services or contact us at operations@oneten.org. If you are an authorized agent submitting a request on behalf of another individual, please submit the request at operations@oneten.org.

Please note that we may not be able to fulfill all of your requests. For example, we need certain information in order to provide our Services to you or to comply with our legal obligations. To protect your privacy and security, we may take reasonable steps to verify your identity before granting such requests. Depending on your state of residence, if we deny your request in full or in part, you may have the ability to appeal our decision. In such circumstances, we will inform you of your appeal right and how to submit your appeal.

You may be referred to us by various participants such as a Talent Developer, and your information may be sent to other participants on the Platform such as a Hiring Company. To the extent you dispute any such participant’s ability to refer you or handle your information, you must first contact such participant to resolve the dispute and failing that you may contact OneTen to exercise your privacy rights in accordance with this Privacy Policy.

Marketing Opt Out. You may choose to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Services, as well as targeted offers from third parties. You can stop receiving these promotional emails by clicking the “unsubscribe” links in the emails or sending a request to the email address in the “Contact Us” section below. Please note that it may take some time to process your request in accordance with our legal requirements. If you decide not to receive promotional emails, we may still send you service-related and other transactional communications.

Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.

How We Source, Use, and Disclose Information for Business Purposes. The following chart details the categories of personal information we collect, the sources of such personal information, and how we use and disclose such information for our business purposes. For more information about each of these categories, please see the “Information We Collect,” “How We Use Your Information,” and “How We Disclose Your Information” sections above.

PI Collected	Sources	Purposes for Use	Disclosures of PI
Contact information (e.g., name, email address, phone number, and physical address)	You Your Employer Your Talent Developer Hiring Company Publicly available and other sources You Your Employer Your devices	Provide the Services Respond to your requests Contact you Analyze usage of the Services Customize content Security and Technical Uses Comply with Law Defend Legal Rights	Hiring Companies Your Employer Your Talent Developer Our affiliates Suppliers Legal compliance Business transactions Legitimate purposes, or Consent
Login information (e.g., username and password)	You Your Employer Your devices	Security and Technical Uses Provide the Services Analyze Usage of the Services Comply with Law Defend Legal Rights	Our affiliates Suppliers Legal compliance, or Business transactions
Demographic information (e.g., your age, gender, race and military or veteran status) and other self- identification information you may provide	You Your Employer Your Talent Developer Publicly available and other sources	Provide the Services Analyze Usage of the Services Customize content Comply with Law Defend Legal Rights	Hiring Companies Your Employer Your Talent Developer Our affiliates Suppliers Legal compliance Business transactions Legitimate purposes, or Consent
Preference information and inferences (e.g., job and career goals, interests)	You Your Employer Your Talent Developer Suppliers	Provide the Services Respond to your requests Contact you Analyze usage of the Services Customize content Comply with Law Defend Legal Rights	Hiring Companies Your Employer Your Talent Developer Our affiliates Suppliers Legal compliance Business transactions Legitimate purposes, or Consent
Professional/Employment information (e.g., employer, role, employment history)	You Your Employer Your Talent Developer Hiring Company Publicly available and other sources	Provide the Services Respond to your requests Contact you Analyze Usage of the Services Customize content Comply with Law Defend Legal Rights	Hiring Companies Your Employer Your Talent Developer Our affiliates Suppliers Legal compliance Business transactions Legitimate purposes, or Consent
Educational/Professional Development information (e.g., attendance, enrollment, credential, degree, and certificate information)	You Your Employer Your Talent Developer Publicly available and other sources (e.g., credential verification providers)	Provide the Services Respond to your requests Contact you Analyze Usage of the Services Customize content Comply with Law Defend Legal Rights	Hiring Companies Your Employer Your Talent Developer Our affiliates Suppliers Legal compliance Business transactions Legitimate purposes, or Consent
Device and online information (e.g., IP address, browser type, operating system, usage information)	Your device Suppliers	Provide the Services Analyze Usage of the Services Customize content Security and Technical Uses Comply with Law Defend Legal Rights	Our affiliates Your Talent Developer Suppliers Legal compliance Business transactions Legitimate purposes, or Consent
User-generated content	You	Provide the Services Respond to your requests Contact you Analyze Usage of the Services Customize content Security and Technical Uses Comply with Law Defend Legal Rights	Hiring Companies Your Employer Your Talent Developer Our affiliates Suppliers Legal compliance Business transactions Legitimate purposes, or Consent

6. Third Party Links and Features

The Services may connect with third-party websites (e.g., social media sites) and features (e.g., social “like” or sharing buttons). If you choose to use these sites or features, this may result in the disclosure of your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of such third-party websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

7. Children’s Privacy

The Services are not designed or directed to minors under 18, and we do not knowingly collect personal information from minors under the age of 18. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

8. How We Protect Your Information

We employ a variety of physical, procedural, and technological measures designed to protect your information from unauthorized loss, misuse, access, disclosure, alteration, or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, although OneTen regularly monitors our systems for possible attacks and vulnerabilities, we cannot guarantee its absolute security.

9. Retention of Information

We and Suppliers will retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we and our Suppliers consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we and our Suppliers process your information, whether we and our Suppliers can achieve those purposes through other means, and the applicable legal requirements.

10. Changes to this Privacy Policy

This Privacy Policy was last updated on the “Last Updated” date herein. We may update this Privacy Policy from time to time, due to changes in the law, technology, or our practices. When we do so, we will post the new Privacy Policy on our Services. You should consult this Privacy Policy regularly for any changes. If required by applicable law, we will also provide you with appropriate notice and/or give you the opportunity to consent before such changes become effective. Continued use of Services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our Services.

11. How to Contact Us

If there are any questions regarding this Privacy Policy, you may contact us at:

OneTen Coalition, Inc.
28 Valley Road
Suite 1
Montclair, NJ 07042
operations@oneten.org