Collection of Information
Information We Collect from You
We collect information directly from you in a variety of ways. For example, we collect information from you when you create an account, participate in any interactive areas of our Services, sign up to receive news, information or special offers from us, make a purchase from us, provide feedback or other submissions to us, fill out a form, participate in a contest or promotion, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.
The types of information we collect directly from you include your name, email address, job title and company name, grade point average or other academic qualifications, photos, ratings and attribute scores you provide, content you create, edit, save or tag, information about meetings or events you create or contribute to, test and assessment responses you provide, and other preferences you express when using the Services.
When you access or use our Services, we automatically collect information about you, including
- Log Information such as information related to your access to and use of the Services, including the search strings you enter, media you view or interact with in our Services, the type of browser you use, app version, access dates and times, pages viewed, your IP address, and the page you visited before navigating to our Services;
- Device information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information; and
Information We Collect from Others
We may also obtain information about you from other sources. For example, we may collect information such as ratings, dots and descriptions about you provided by other users of our Services. If you or your social media friends create, log into, or link a PRIOS account with a social media site, or use other features of our Services that integrate with social media sites, we may receive certain information such as your name and profile photo, in accordance with the authorization procedures determined by such social media site. We may also collect information, including demographic information (such as your gender and age range), from analytics providers and other third parties that provide us with information so we can better understand you.
Information We Infer
We may derive information or draw inferences about you based on the other personal information we collect about you. For example, based on the attribute scores or dots you receive through our Services, we may infer your strengths and weaknesses or how you rank with regards to certain attributes as compared to others in your group. We may infer your location from our collection of your IP address. We may also derive various insights from the information submitted by and about you through our Services.
Use of Information
We use the information we collect for various purposes, including to:
- Provide, maintain and improve our Services, including to provide you with more relevant and personalized content;
- Complete the transactions you request, perform our contractual obligations, and as otherwise anticipated within the context of our ongoing business relationship;
- Create and manage your online accounts and profiles;
- Identify and authenticate users and send technical notices, updates, security alerts, and support and administrative messages;
- Respond to your comments, questions, requests and any other communications from you, including to provide customer service;
- Communicate with you about products, services, opportunities and events offered by PRIOS and our partners, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
- Monitor, audit and analyze trends, usage, and activities in connection with our Services;
- Conduct internal research and development;
- Detect security incidents and protect against illegal or objectionable activities, including the unauthorized use of the Services, and protect the rights and property of PRIOS and others;
- Personalize your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, and browsing behavior;
- Debug, identify and repair errors that impair existing intended functionality of our Services;
- Comply with our legal obligations, including those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions;
- Carry out certain short-term activities and other reasonable internal purposes related to the products or services you purchase from us or your ongoing relationship with us;
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; and
- Carry out any other purpose described to you at the time the information was collected.
Sharing Of Information
We share personal information as described below:
- With vendors, service providers, and consultants that need access to such information to perform services for us, including to help us store information, authenticate users, send transactional and promotional communications, and debug, secure and improve our Services;
- With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
- If you use our Services as part of your work, we share certain personal information with your employer or business who has subscribed to our Services;
- With other users of the Services if you participate in the interactive areas of our Services;
- With law enforcement authorities and individuals involved in legal proceedings, in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements or if we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Principles or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- With our legal, financial, insurance and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of PRIOS' business or operations; and
- With your consent or at your direction.
In certain instances, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.
To the extent permitted by applicable law, we store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. If you close your account with us, we will delete personal information about you within ninety (90) days. We also automatically delete accounts if a user has not interacted with our Services after two (2) years. Please refer to Your Choices below for information about how to delete your account and other choices available to you.
Transfer Of Information to the U.S. and Other Countries
PRIOS is based in the United States and we process and store information in the U.S. and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. When we transfer personal information from the EEA or the UK, we do so in reliance on an approved data transfer mechanism. We have also certified to the U.S. Department of Commerce that we adhere to its EU-U.S. Privacy Shield Framework in connection with our transfer to the United States of personal information that relates to individuals in the EEA and the UK. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield, we are committed to resolving complaints about our processing of your personal information. You may contact us about any questions or complaints regarding our compliance with the Privacy Shield program as indicated in the "Contact Us" section below. We have further committed to refer unresolved Privacy Shield complaints to JAMS, 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/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. PRIOS is subject to the investigatory and enforcement powers of the Federal Trade Commission. If we share personal information transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party's processing in violation of the Privacy Shield PRIOS, unless we can prove that we are not responsible for the event giving rise to the damage.
You may update certain account information you provide to us at any time by logging into your account and adjusting your settings. If you no longer want us to process information about you, you can request that we delete your account through the customer support functions of our Services, but note that we may retain certain information as required by law or for legitimate business purposes, where permitted by applicable law. We may also retain cached or archived copies of information about you for a certain period of time.
EEA/UK users have a choice as to whether to accept non-essential cookies when you access our Services. We will only set non-essential cookies if you give us your consent.
Advertising and Analytics Services Provided by Others
If you receive promotional emails from PRIOS, you may opt out at any time by following the instructions in those emails, or by contacting us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional emails, such as those about your account or updates to our user terms or policies.
Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Information for California Consumers; Your California Privacy Rights
If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to disclose the following information with respect to our collection, use, and disclosure of personal information.
In the preceding twelve (12) months, we have collected the following categories of personal information: identifiers; internet or other electronic network activity information; demographic information (note that some demographic information may be considered characteristics of protected classifications under state or federal law); professional or employment related information; education information; audio, electronic, visual, thermal, olfactory, or similar information; inferences; and other information that relates to or is reasonably capable of being associated with you. For examples of the precise data points we collect and the sources of such collection, please see Collection of Information above. We collect personal information for the business and commercial purposes listed in Use of Information above.
We may share your personal information with third parties as described in Sharing of Information above. In the preceding twelve (12) months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:
- We share identifiers with email marketing service providers, data analytics providers, advertising networks, development partners, customer service providers, user authentication service providers, payment processors, technical support providers, internet service provider, operating systems and platform, data storage providers and cloud service providers.
- We share internet and electronic network activity information with email marketing service providers, data analytics providers, advertising networks, technical support providers, internet service provider, operating systems and platform, data storage providers and cloud service providers.
- We share commercial information with payment processors, data storage providers and cloud service providers.
- We share visual information with user authentication service providers and data storage providers.
- We share professional or employment related information with document parsing and indexing providers and data storage providers.
- We share other information that we have derived or inferred about you or that relates to or is capable of being associated with you with development partners, data analytics providers, technical support providers, data storage providers, and cloud service providers.
Subject to certain limitations, you have the right to (1) request to know more about the categories and the specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) opt out of any "sales" of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. Please note that we may retain certain information as required or permitted by applicable law. You may make these requests by emailing us at email@example.com or visiting this page. If you would like to use an authorized agent registered with the California Secretary of State to exercise these rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA. We will verify your request by asking you to provide information about you that matches the information we already maintain. If you request to delete your personal information, some of our Services may no longer be available to you.
Individuals in the European Economic Area (EEA) and the United Kingdom (UK)
If you are in the EEA/UK, you have certain rights and protections under the law regarding the processing of your personal information.
Legal Basis for Processing
If you are in the EEA/UK, when we process your personal information we will only do so in the following situations:
- We have your consent to do so, for example when you create and manage your online profile or agree to receive promotional communications from us. When your consent is the legal basis for our processing, you may withdraw such consent at any time.
- We need to use your personal information to perform our responsibilities under our contract with you, for example to provide the services you have requested.
- We have a legitimate interest in processing your personal information to provide you with a good user experience and protect and promote PRIOS. For example, we may process your personal information to respond to your questions or comments, to conduct internal research, to communicate with you about changes to our Services, and to secure and improve our Services.
- We find such processing is necessary to comply with our legal obligations, for example to maintain a record of your consents and those who have opted-out of promotional communications.
Data Subject Requests
If you are in the EEA/UK, you have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or shared with another provider. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may do so by emailing us at firstname.lastname@example.org or visiting this page. If you have created an account to access and use our Services, you may also update certain personal information by logging into your account.
Questions or Complaints
If you are in the EEA/UK and have a concern about how we process personal information, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
General Data Protection Regulation (GDPR) - European & UK Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as our GDPR representative in the EU and the UK. You can contact EDPO regarding matters pertaining to the GDPR by:
- Sending an email to email@example.com
- Using EDPO UK’s online request form at https://edpo.com/contact/
- Writing to EDPO London, HQ Bloomsbury, 4/4a Bloomsbury Square, London, WC1A 2RP, Greater London, United Kingdom
NOTE: please do not forget to mention that your request relates to "PRIOS, LLC."
25 Ford Road
Westport, Connecticut 06880