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Privacy Policy

Last Updated August 19, 2019

Eightfold AI Inc. (“Eightfold,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains who we are, how we collect, process, share, and use personal information about you, and how you can exercise your privacy rights. For purposes of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual.

Eightfold uses artificial intelligence through its software services built upon its Talent Intelligence Platform which provides an effective solution for our customers (“Customers”) to acquire, engage and retain a diverse workforce (the “Services”).

This Privacy Policy describes our information practices for both our website and our Services. The Our Website section explains how Eightfold collects and uses the Personal Data of visitors to our website. The Our Software Services section explains how our software services, as used by our Customers’ employees or authorized users as well as job candidates, collect and use Personal Data. In the General section, this Policy explains how Personal Data may be transferred cross-border, how it is secured, how it is retained, as well as individuals’ rights to their Personal Data.

OUR WEBSITE

  1. Personal Data We Collect

When you contact us or interact with our website (the “Site”) we may collect Personal Data that alone or in combination with other information could be used to identify you as follows:

Customer Account and Inquiries: If you are a Customer or prospective Customer (or a representative or employee), we collect and process your Personal Data when you (i) visit the Site or make a request to receive information about our Services, including to book a demo, (ii) contact our sales team or customer support team, and (iii) sign up for an Eightfold account and use the Services. The Personal Data we collect may include your first and last name, job title, company name, email address, mailing address, password to access your Customer portal, payment and billing information, phone number, country location.

Job Applicants: If you are applying a job with us, we collect and process your job application information that may contain Personal Data such as those in your resume.

Information We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Twitter, and LinkedIn (“Social Media Pages”). We may collect Personal Data from you when you interact with our Social Media Pages, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our website from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our website with your social media profile.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.

Information We Receive From Your Use of the Site: When you visit, use and interact with the Site, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

  • Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies, Pixel Tags and similar technologies: Please see the “Cookies and Other Technologies” section below to learn more about how we use cookies and other technologies.
  • Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities. 
  1. How We Use Information

We use Personal Data for the following purposes:

As necessary for certain legitimate business interests, which include the following:

  • To respond to inquiries, comments, feedback or questions;
  • To find employment opportunities for you as job applicants;
  • To send administrative or account related information to you, for example, information about the Site or Services, and changes to our terms, conditions, and policies;
  • To analyze Site usage and provide, maintain and improve the content and functionality of the Site. For example, we regularly fix bugs and User experience issues. We use cookies and similar technologies to analyze how users interact with our Site. And that analysis can help us improve the Site;
  • To conduct analytics to inform our marketing strategy and enable us to enhance and personalize the experience we offer to our customers;
  • To prevent fraud, criminal activity, or misuses of our Site and to ensure the security of our IT systems, architecture and networks;
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, customers, or other third parties; and
  • If you ask us to delete your data and we are required to fulfill your request, we will keep basic data to maintain a record of your request, our response to it and prevent further unwanted processing.

For information about what we mean by legitimate interests and the rights of individuals, please see the “Your Rights” section below.

Marketing. We may contact you to tell you about services we believe will be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing messages you receive by updating your settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and Services and to respond to your requests.

  1. Sharing and Disclosure of Information

We do not sell or otherwise disclose Personal Data we collect about you, except as described in this Policy or as we disclose to you at the time this information is collected. In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

  • Third Party Vendors and Service Providers: We authorize these service providers to use or disclose the information only as necessary to perform services on behalf of Eightfold (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website). To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with providers of hosting, marketing, and sales/customer relationship management services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (v) protect against legal liability.
  1. Links to Other Websites

The Site may contain links to other websites not operated or controlled by Eightfold (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

  1. Your Choices

Whether or not you provide Personal Data to us is completely up to you, but if you choose not to provide information that is needed to process your orders or to use some features of our Site, we may be unable to process your orders or you may be unable to use those features. You can also contact us to access, update, correct, or remove your Personal Data from the Site.

OUR SOFTWARE SERVICES

  1. Personal Data We Process on Behalf of Our Customers

Eightfold will use Personal Data only as necessary to provide and deliver the Services to our Customers, to prevent or address any service or technical issues, to respond to a Customer’s support request, or for any other purpose provided for in the Customer agreement, or in accordance with or as may be required by law. Customers collect and manage Personal Data through their use of our Services in accordance with their own privacy policies, which are outside the scope of this Privacy Policy.

Personal Data Processed on Behalf of Customers: In order to provide the Services, Eightfold processes certain Personal Data input or uploaded into our Services by our Customers’ employees or authorized users, or prospective employees. Through those connections, we receive certain Personal Data about employees and candidates for employment that the Customer makes available to us, such as contact information, professional and educational backgrounds and information included in resumes.

For example, if you apply to a job posted on a career page of a prospective employer that is one of our Customers, your Personal Data may be processed by Eightfold in provision of the Services. We have no direct relationship with the individuals whose Personal Data we process on behalf of Customers, The prospective employer is the data controller and if you are an employee or job candidate of one of our Customers and would no longer like your data to be used by one of our Customers that use our Services or you would like to access, correct or request deletion of your data, please contact the Customer that you interact with directly.

To the extent that certain of our services, such as a mobile app, allow you to directly upload job application information including resumes in order to connect with potential employers, we process the information for purposes of connecting you with potential employers including analyzing, summarizing, displaying, and allowing downloading the information to our Customers and their authorized users. Our customers and their authorized users may include companies that created the job positions or that act as intermediaries such as counselors or recruiters for such companies and in turn may forward your submitted information to the employers. If you wish to access, correct or delete an earlier upload, you may do so as part of the applicant service or alternatively please see “Your Rights” section below and “Contact Us” section below for information on how to exercise your rights.  If you have interacted with a potential employer directly, please contact the employer if you would like to access, correct, or request deletion of your data held by the employer.

Personal Data Obtained from Third Party Sources: We may obtain information about potential job candidates from third parties who provide data they have collected and sources where job candidates have posted their resumes, such as professional social networks or employment-related search engines for job listings. Obtaining this information helps our Customers 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. The type of data we obtain from publicly accessible sources depends on the data that the job candidate makes available. It generally includes contact information, professional and educational backgrounds, and information included in resumes.

Information We Receive From Your Use of the Site: When you visit, use and interact with the Site, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

  • Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies, Pixel Tags and similar technologies: Please see the “Cookies and Other Technologies” section below to learn more about how we use cookies and other technologies.
  • Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
  1. Personal Data We Control

Eightfold may obtain Personal Data of authorized users of our Services and Customers’ administrative personnel in connection with the operation, support and/or use of the Services, including their names, emails, contact information and billing information.

  1. How We Use Information

We use Personal Data for the following purposes:

To provide our Customers with the Services so they can find potential job candidates to match with desired job requirements and facilitate employee career growth through internal mobility. This processing is necessary to perform our contract with our Customers.

As necessary for certain legitimate business interests, which include the following

  • To provide, operate, optimize and maintain the Services;
  • To address Customer inquiries, comments, feedback, questions, sales and marketing support, support requests and product development;
  • To manage Eightfold’s platform, system administration and to ensure the security of our IT systems, architecture and networks;
  • To compile anonymized statistics about the operation and use of the Services to carry out research, development, and analyze usage and provide, maintain and improve the content and functionality of the Services;
  • To send Customers administrative and technical alerts, reports, updates, security notifications and other Service-related communications;
  • To investigate and prevent fraud, criminal activity, unauthorized access or use of Services, breaches of terms and policies, and other wrongful behavior;
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, customers, or other third parties;
  • To carry out other legitimate business purposes, as well as other lawful purposes about which Eightfold will notify you.
  • To keep track of our Customer billing, payments and account management
  • If you ask us to delete your data and we are required to fulfill your request, we will keep basic data to maintain a record of your request, our response to it and prevent further unwanted processing.

For information about what we mean by legitimate interests and the rights of individuals in the European Union (“EU”) and other applicable jurisdictions, please see “Your Rights” section below.

  1. Sharing and Disclosure of Information

We do not sell or otherwise disclose Personal Data we process in our Services, except as described in this Services Privacy Policy or as we disclose to you. In certain circumstances, we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

  • Third Party Data Subprocessors: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with providers of hosting, marketing, sales/customer relationship management services, product support, product management, and security enhancement. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. Further details on our specific use of subprocessors are described in our Subprocessor Notice.
  • Customers: In order to connect potential job candidates with potential employers, we may share Personal Data with our Customers and their authorized users. Our customers 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.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (v) protect against legal liability.
  • Integration: Our Customers may choose to integrate their Eightfold accounts with other third party service providers selected by Customers.  While efforts are made to choose integration partners that share our standards for privacy, their websites and services are outside of our control and are not covered by this Services Privacy Policy, and we are not responsible for their content, security, or privacy practices.

GENERAL SECTIONS

Cookies and Other Technologies

We use cookies and similar technologies such as web beacons alone or in conjunction with cookies to compile information about the usage of our website and interaction with emails from us. When you visit our website, we or an authorized third party may place a cookie on your browser, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine your browsing preferences and improve and customize your browsing experience.

You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our website.

We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our website. Such technologies are used to operate and improve our website and email communications.

Further information on how we use cookies and other similar technologies and how you can control cookies are described in our Cookie Notice.

Security

We care about the security of your Personal Data and take appropriate steps including technical and organizational measures to comply with industry standards to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. For example, we use available technology and other techniques to implement systems like firewalls, and/or encryption to secure marketing data transfers. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services. Please keep this in mind when disclosing any Personal Data to Eightfold via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Site, the Services, or third party websites.

International Transfer

If you are accessing our Site from the EU or other regions with laws governing data collection and use, please note that we may transfer your Personal Data to the United States for the purposes described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). Some of our service providers (such as Amazon Web Services) are certified to the Privacy Shield Frameworks operated by the US Department of Commerce for transfer of Personal Data from the EU and Switzerland, as applicable, to the United States. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of security protection where it is processed and your rights continue to be protected. For more information, please see the “Contact Us” section as described below.

Data Retention

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Any Personal Information we process on behalf of our Customers is retained in accordance with the timeframes set out in the relevant customer agreements.

Your Rights Relating to your Personal Data

You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EU (for these purposes, the EU includes European Economic Area countries of Iceland, Liechtenstein and Norway, the U.K., and, to the extent applicable, Switzerland), these rights may include your rights under EU General Data Protection Regulation (“GDPR”):

  • To access, correct, update or request deletion of your Personal Data held by us, taking into account the purpose of processing the Personal Data and to the extent permitted by applicable data protection laws.
  • To restrict our processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to processing of your Personal Data.
  • If you object to processing of your Personal Data, we will stop processing: (1) if we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or (2) If we are processing your Personal Data for direct marketing purposes.
  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us at privacy@eightfold.ai.
  • You have the right to request portability of your Personal Data that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means.
  • You have the right to be free from decisions based solely on automated processing of your Personal Data (including profiling) which produces a significant legal effect on you, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
  • If we rely on your consent to process your Personal Data, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns. For more information, please contact your local data protection authority.  See http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Please see the “Contact Us” section below for information on how to exercise your rights.

Legitimate Interest. “Legitimate interests” means our interests in conducting our business, and as applicable to our Customers, fulfilling the obligations under our customer contracts and managing and delivering the best services. It also refers to our Customers’ and job seekers’ interested in engaging with each other. This Privacy Policy describes when we process Personal Data for our legitimate interests, what these interests are and Your Rights. We will not use your Personal Data for activities where the impact overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Roles. Data protection laws in the EU differentiate between the “data controller” and “data processor” of Personal Data. Eightfold is the data controller for the processing of Personal Data obtained through the Site, our Social Media Pages, third-party databases, and with respect to other Personal Data which we process for our purposes, such as the Personal Data of our Customer’s  authorized users and administrative personnel for the operation, support and/or use of the Services for legitimate business purposes which may include billing, account management, technical support, product development and sales and marketing. Eightfold is the data processor for the processing of Personal Data provided or otherwise made available to us by Customers through the Services, which we process on Customers’ behalf pursuant to our contract with the applicable Customer.

OTHER INFORMATION

  1. Children

The Site and the Services are not directed to children who are under the age of 16. Eightfold does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Eightfold through the Site or Services please contact us and we will endeavor to delete that information from our databases.

  1. Do-Not-Track Signal Disclosure

Do Not Track Signals: Our Site currently does not respond to Web browser “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a Web browser DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

  1. Changes to the Privacy Policy

The Site, the Services, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use the Site or Services or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you if applicable, you consent to the revised Privacy Policy and practices described in it.

  1. Contact Us

If you have any questions about our Privacy Policy or the information practices of the Site, please feel free to contact us at privacy@eightfold.ai or at the mailing address below.

For Personal Data we process on behalf of our Customers, please direct any requests related to the data protection rights described in Your Rights above to the Eightfold Customer who holds the relevant Eightfold account. As a data processor of any Personal Data stored and processed on the Services, Eightfold will not be able to respond directly to such requests and will refer any such requests to the relevant Customer.

Eightfold AI Inc.
ATTN: Legal Dept.
480 Ellis Street
Mountain View, CA 94043 USA