Untapped Privacy Policy

Welcome to Untapped and thank you for taking the time to read our Privacy Policy.  Untapped is a community network purposefully designed to provide more employment opportunities to everyone. We are passionate about making the world a more equitable place by providing candidates and employers the opportunity to connect on the world’s leading diversity recruiting platform.  

1. Overview

This Privacy Policy explains how Untapped Labs, Inc. and its affiliates (collectively, "Company", "we", and "us") may collect, process, share and/or utilize information relating to an identified or identifiable natural person’s ("you" and "your") personal information ("Personal Data"), including information from:

• Visitors to our website (a "Visitor"),
• Individuals seeking employment at Company (a "Job Seeker"),
• Candidates who create a Company account (a "Member"), either directly on the Company website or after being referred to Company.
• Users of our mobile applications.
• Event attendees.
• People who choose to allow Company to send them communications, including email subscriptions.

This Privacy Policy applies to the Personal Data that is provided to us through the use of our site www.untapped.io (the "Site"), mobile applications, events and/or any communications including email subscriptions (collectively, our “Platform”).

This Privacy Policy does not apply to information that you may provide to one of our employer partners ("Employers"), other Company Members, and applications or services that Company does not own or maintain or to any entities that are integrated with Company using the Company Application Programming Interface ("API").  If you applied for a job with an Employer, the Employer may provide your information to Company directly so they can use the Company services for managing their recruiting activities. We will use the information in accordance with our agreement with that Employer. Your agreement with that Employer should explain how they share your information with Company. Please contact the Employer if you have questions about this sharing. We are not responsible for the privacy practices of any third-party website operator that you may link to from our website.

Company is dedicated to protecting the privacy and security of your Personal Data and to monitoring governance regulations. We are committed to performing our responsibilities regarding the collection, processing, utilization and retention of in-scope data in accordance with applicable data privacy laws such as GDPR and CCPA. This data is only used for legitimate and lawful purposes, and residents of California may find more information in the Notice to California Residents.

2. Personal Data We Collect

a. Personal Data that we collect about you.

You may choose to share different types of Personal Data with us when you use our Platform.

For example:

• We collect your full name, email address, and account log-in credentials when you create a Company account.
• We collect your full name, job title, company name, telephone number, and email address when you complete a form on our website to receive a product demo.
• We collect your full name, email address and other application data such as your resume when you apply for a job at Company.
• We collect information you add to your profile, such as: your resume, social media links, personal biographical details and comments you post in group chats or bulletin boards.
• When you respond to Company emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call us.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Sites.

Our websites use cookies and other technologies to function effectively. These technologies record information about your use of our websites, including:

• Browser and device data, such as IP address, location, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting.
• Usage data, such as time spent on the websites, pages visited, links clicked, language preferences, and the pages that led or referred you to our websites.

We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our websites to help us analyze your use of our websites and diagnose technical issues.

To learn more about the cookies that may be served through our sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy.

c. Collection of Sensitive Personal Data

You may choose to enhance your Company Member profile with information that could be categorized as “sensitive”, depending on where you live. For example, we ask you to self identify your race and ethnicity when you create your Company account. You do not have to provide this information in order to have a Member profile on Company, but providing this information can help you to get more from our services, including helping Employers utilizing our services to find you. It’s your choice whether to provide this sensitive information, and if you do, we request that you please be mindful that it will become a part of your Company profile.

d. Information Provided to us by Employers

We contract with Employers who use the Company services. These Employers may share Personal Data about individuals who have applied for an employment opportunity with their organization (an "Applicant").  This Privacy Policy does not apply to Applicants. We encourage you to review the terms of service and privacy policy of that organization in order to better understand your rights. If you are an Applicant, you may choose to become a Member by creating an account, which can include your Employer-provided personal information.

3. How We Use Personal Data

a. Our products and services.

We use your Personal Data compliantly. We use Personal Data to facilitate the business relationships we have with Members and to pursue our legitimate business interests. For example:

• We use Personal Data to provide the Company services to you, including when we create and manage your Company account or share your profile with an Employer who uses the Company platform for recruiting activities.
• We may use Personal Data to comply with a regulatory or other legal request.
• We may use Personal Data for our business, such as when we respond to customer support inquiries, to improve our services, to develop new services, and to conduct general analysis related to activities such as security, decision making, administrative, and reporting.

b. Marketing and events-related communications.

We may send you email marketing communications about Company products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For example, when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

c. Advertising.

When you use our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Company services to you on our Sites and other websites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. Please see our Cookie Policy for more information. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

We do not share, rent or sell Member Personal Data for interest-based advertising.

4. How We Disclose Personal Data.

Company does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. Service providers.

We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.

b. Business partners.

We share Personal Data with business partners when this is necessary to provide our services to you.

c. Employers.

We share Personal Data with Employers who use the Company services for recruiting activities.

d. Corporate transactions.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

e. Legal compliance and harm prevention.

We share Personal Data as we believe necessary: (i) to comply with applicable law; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Company, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. Your Rights and Choices.

You have choices regarding our use and disclosure of your Personal Data:

a. You may opt out of receiving electronic communications from us.

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our services.

b. You may view or change your account Personal Data.

If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your Company account and accessing your profile dashboard, or by contacting us at privacy@untapped.io

c. Your data protection rights.

Depending on your location and the law there, you may have the following rights with regard to your Personal Data:

• The right to request confirmation of whether Company processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
• The right to request that Company rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
• The right to request that Company erase your Personal Data in certain circumstances provided by law;
• The right to request that Company restrict the use of your Personal Data in certain circumstances, such as while Company considers another request that you have submitted (including a request that Company make an update to your Personal Data);
• The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide services to you; and
• Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

In general, you may log into your Company account in order to: (i) obtain a copy of your Personal Data, or (ii) rectify, edit or update your Personal Data. You may have your Personal Data about your Company Account removed from our database by logging into your account, navigating to the Settings section, and clicking on “Delete Account”.  This will remove your profile from the Company Platform within 30 days after that request is initiated. Please contact Company as described in the Contact Us section below with other questions or for more information about your rights. If you are an Applicant of an Employer, please contact the Employer directly with questions about your rights with respect to your information.

6. Security and Retention.

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Company uses role-based access control to limit personnel access to your Personal Data to those requiring it to perform their duties as required to deliver the services. Please contact us immediately at security@untapped.io if you have reason to believe that your account has been compromised.

In general, we retain your Personal Data as long as you remain a Member. We may retain Personal Data after we stop providing services to you, even if you close your Company account, in order to comply with our legal obligations. We may also retain Personal Data to comply with our tax, accounting, and financial reporting obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International Data Transfers.

Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy.

If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. We use EU Standard Contractual Clauses with a data recipient outside the EEA or the UK where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism.

8. Notice to California Residents

This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).

a. How We Collect, Use, and Disclose your Personal Information.

Section 2 describes the Personal Data we may have collected over the last 12 months, including the categories of sources of that information. We collect this information for the purposes described in Section 3. We share this information as described in Section 4. Company uses cookies, including advertising cookies, as described in our Cookie Policy.

b. Your CCPA Rights and Choices.

As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

• Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
• • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected the personal information;
  • the categories of third parties with whom we shared the personal information; and
  • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
• Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
• Exercising the right to opt-out from a sale. You may request to opt-out of any “sale” of your personal information that may take place. As described in Advertising, we do not use, share, rent or sell the Personal Data of our Members for interest-based advertising. We do not sell or rent the Personal Data of our Employers or Applicants.
• Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

To submit a request to exercise any of the rights described above, you may contact Company at privacy@untapped.io. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If you are an Applicant of an Employer, please direct your requests directly to the Employer with whom you shared your personal information.

9. Use by Minors.

The Platform is not intended for use by individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Platform.

10. Updates To this Privacy Policy and Notifications.

We are always finding ways to improve our Platform, which means we get new data and create new ways to use data. Our services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy. The “Last updated” designation at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Platform. We may also provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a Member, by contacting you through your Company dashboard, email address, and/or the physical address listed in your Company account.

11. Contact Us

If You have any questions or complaints about this Privacy Policy, please contact us electronically at privacy@untapped.io.  Due to the pandemic, we are not currently checking our physical mailbox regularly, however, our physical address is:

8605 Santa Monica Blvd
Suite 84561
West Hollywood, CA 90069