Privacy Policy
Introduction
SurePeople Technologies, Inc. (“SurePeople,” “us,” “we,” or “our”), recognizes that privacy and security are concerns for itself and individuals accessing SurePeople’s websites and/or applications. This Privacy Policy describes the types of information we may collect from individuals (“you” or “your”) that visit, download, install, or use the surepeople.com website or any of our publicly available websites (the “Websites”), our Mobile Application for the iOS and Android operating systems (the “Mobile Application”) or the Prism psychometric assessment. This Privacy Policy also describes the security measures we take to protect Personal Information (as herein defined) we collect.
We refer to the Websites, Mobile Application, and Prism psychometric assessment together as the “Platform.” This Privacy Policy applies whether you access the Platform for your own use or for use by one of our client companies.
This Privacy Policy works together with our User Agreement, and any other agreements (each a “SurePeople Application Agreement”) we have with individuals or businesses (for example, your employer) that use or interact with SurePeople products or services (each such individual or business, together with its employees and other authorized users, a “Customer”). By using any part of the Platform on which SurePeople has posted this Privacy Policy, you authorize SurePeople to collect and use your information as set forth in this Privacy Policy and any applicable SurePeople Application Agreement. Such SurePeople Application Agreements may further define the way in which SurePeople collects, uses, and shares information provided by SurePeople Customers when they use part of the Platform.
When you submit information through the Platform, including the Prism psychometric assessment, you are instructing us to transmit that information to certain third parties, including our Customer (who may be your employer), and to the third parties listed in Section 5 below.
Any revisions to this Privacy Policy will be posted at www.surepeople.com/privacy. Your continued use of the Platform after we post such changes will constitute your acceptance of the revised Privacy Policy to the extent permitted by applicable law.
2. What Information is collected and how is it collected?
SurePeople collects “Personal Information” for its own business purposes and to fulfill its contractual obligations to its Customers. Personal Information includes the following information from and about users of the Platform:
Information you provide to us when you download, register with, or use the Websites, Mobile Application or Platform (such as your name, title, company, address, country, e-mail address, phone numbers, gender, ethnicity/race, and age range, as well as information that reasonably can be related or linked to a particular individual or a household, including through an IP address, such as relationship information regarding services we provide or may provide to you, information about how you use the Platform, and information about the device(s) and networks that you use in conjunction with the Platform, such as Device ID, browser type, ISP, referring or exit pages, operating system, date/time stamps, or clickstream data.)
Information that you provide by filling in forms in the Websites, the Mobile Application, or the Platform. This includes information provided at the time of registering to use any part of the Platform, subscribing to our service, posting material, and requesting further services. SurePeople may also ask you for information when you provide responses to any psychometric self-assessment(s) and/or questionnaires (including information used to construct your Prism profile), enter a contest or promotion sponsored by us, and when you report a problem with any part of the Platform.
Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
Your responses to any psychometric self-assessment(s) and/or questionnaire(s) that we might ask you to complete for research purposes, or in connection with your creation of your Prism profile.
Details of transactions you carry out through any part of the Platform and of the fulfillment of your orders, including financial information you enter in connection with orders placed through the Platform. Although SurePeople does not have access to payment card numbers, our payment processors will collect the financial information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy.
Your search queries on the Websites, Mobile Application or Platform.
You may also post or provide information for display on public areas of the Platform (collectively, “User Contributions”). Your User Contributions are posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. We cannot guarantee that your User Contributions will not be viewed by unauthorized persons.
Unless otherwise required by law, Personal Information does not include publicly available information or aggregated or deidentified information that cannot be used to identify you individually or reasonably be re-associated with you.
3. How is My Information Collected?
In addition to the User Contributions and other Personal Information described in Section 2 above, SurePeople collects information in a number of different ways.
(a) Automatically. When you download, access, and use the Platform, the Platform may use technology to automatically collect:
· Usage Details. SurePeople may automatically collect details of your access to and use of any part of the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use through the Platform.
· Device Information. SurePeople may collect information about your device and internet connection, including the device’s unique identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
· Stored Information and Files. The Platform also may access metadata and other information associated with other files stored on your device.
· Location Information. The Platform may also collect real-time information about the location of your device.
If you do not want SurePeople to collect this information, then do not download the Mobile Application or delete it from your device, and do not access the Platform. For more information regarding your choices about our use and disclosure of information, see Section 5. Note, however, that opting out of the Platform’s collection of location information will disable its location-based features.
(b) Information Collection and Tracking Technologies. SurePeople also uses various information collection technologies:
· Cookies (or mobile cookies). A cookie is a small file placed on your device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your device or browser. However, if you select this setting, you may be unable to access certain parts of our Platform. We use cookies to perform the following tasks:
ensure that the Platform functions as intended;
guard against fraud;
understand how you engage with the Platform or our services;
advertising our Platform or our services where allowed.
· Web Beacons. Pages contained within the Platform and our emails or other communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit SurePeople, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
(c) Third Party Information Collection. Some content or applications on the Platform are served by third-parties or from third-party servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. For clarity, SurePeople does not currently sell any Personal Information to any third party advertisers.
We do not control these third parties' tracking technologies or how they may be used. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
4. How is my information used?
SurePeople uses information that it collects about you or that you provide to us, including any Personal Information, to:
· Provide you with the Platform and its contents, and any other information, products or services that you request from us. This includes processing certain information (including, your responses to any psychometric self-assessments and questionnaires) through generative artificial intelligence tools like OpenAI.
· Provide a Customer (for example, your employer) or its employees and authorized users with the Platform and its contents. This also includes processing certain information (including, your responses to any psychometric self-assessments and questionnaires) through generative artificial intelligence tools like OpenAI.
· Fulfill any other purpose for which you provide such information, including in connection with your creation of a Prism profile and any coaching and/or individualized development that you or your company elects to receive.
· Process payments.
· Give you notices about your subscription, including any expiration and renewal notices.
· Carry out SurePeople’s obligations and enforce its rights in connection with your use of the Platform.
· Notify you when Mobile Application or Platform updates are available, and of changes to any products or services we offer or provide though it.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
The usage information we collect helps us to improve our Platform and Mobile Application and to deliver a better and more personalized experience by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Mobile Application or Platform according to your individual interests and preferences.
· Speed up your searches.
· Recognize you when you use the Platform.
· SurePeople uses location information we collect to provide tailored suggestions.
5. With whom does SurePeople share my information?
SurePeople may, without restriction, disclose aggregated information, and information about our users that does not identify any individual. SurePeople may also disclose Personal Information that we collect or you provide as described in this privacy policy:
· To our subsidiaries and affiliates.
· To secure and verified third party payment processors such as Stripe. Our payment processors will collect the information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy.
· A copy of Stripe’s privacy policy can be found at https://stripe.com/privacy.
· To generative artificial intelligence providers, such as OpenAI, to perform functions and services as part of the Platform.
· A copy of OpenAI’s privacy policy can be found at https://openai.com/policies/row-privacy-policy/
· To contractors, service providers, and other third parties (including, without limitation, major financial institutions providing merchant services) but solely (i) for the purpose of providing services to you and (ii) provided such parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SurePeople’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SurePeople about our Platform users is among the assets transferred.
· To fulfill the purpose for which you provide it, including, without limitation, the provision of services by SurePeople to you.
· To third parties to market their products or services to you if you have not opted out of these disclosures.
· For any other purpose disclosed by SurePeople when you provide the information; and
· With your consent.
· In addition, if your employer (or another authorized third party) (each, an “Organization”) has created an account for your use and benefit on behalf of such Organization (each, an “Enterprise Account”), then your Personal Information may be shared to additional parties within the Organization as follows:
· Administrator: One or more account creator(s) or owner(s) within the Organization (the “Administrator(s)”) may be able to access all of your Personal Information and the Personal Information for all members of the Organization. Upon registering for the Platform, the Administrator(s) for your Organization will be disclosed to you, and you consent to such disclosure of Personal Information to the Administrator.
· Leader: Any individual leader(s) within the Organization (the “Leader(s)”) may be able to access all Personal Information related to a designated group of persons within your Organization. Upon registering for the Platform, the Leader for your Organization will be disclosed to you, and you consent to such disclosure of Personal Information to the Leader.
· Limited User: Some users may access the Platform solely to complete a Prism questionnaire (and not to use the Platform more generally) (a “Limited user”), in which event such Limited User’s Prism questionnaire may be shared with the Administrator(s) and/or Leaders. Certain information about users or their Prism questionnaire may be shared with other Limited Users as part of the services provided to users of the Platform.
SurePeople may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SurePeople, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Choices about how we use and disclose your information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
(a) Tracking Technologies and Advertising. In many cases, you can set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. Each browser and device is different, so use the “help” function of your browser or device to learn about cookie preferences and other privacy settings that may be available. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or not function as intended.
(b) Location Information. You can choose whether or not to allow the Mobile Application to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Mobile Application may become inaccessible or not function properly.
(c) Promotional Offers from the Company. If you do not wish to have your contact information used by SurePeople to promote our own products or services, you can opt-out by sending an email stating your request to privacy@surepeople.com. If we have sent you a promotional email, you may request to be omitted from future emails by sending us a return email or pressing the button provided. This opt out will not apply to our use of information provided to SurePeople as a result of a product or service purchase, warranty registration or other transactions.
(d) Google Analytics. SurePeople uses Google Analytics to monitor and improve our user experience. You can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaop
7. Accessing and correcting your information
You can review and change your personal information by logging into the Platform and visiting your account profile page. You may also send us an email at privacy@surepeople.com to request access to, correct, or delete any personal information that you have provided to us. In certain cases, we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our terms of use.
Residents of certain states, such as California, may have additional personal information rights and choices. Please see “California & Other State Laws” for more information.
8. California & Other State Laws
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
Although we do not currently sell data, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Mobile Application that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@surepeople.com.
In addition to California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
· Confirm whether we process their personal information.
· Access and delete certain personal information.
· Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
· Data portability.
· Opt-out of personal data processing for:
· targeted advertising (excluding Iowa);
· sales; or
· profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
· Either limit (opt-out of) or require consent to process sensitive personal data.
The exact scope of these rights may vary by state. To exercise any of these rights please email privacy@surepeople.com. To appeal a decision regarding a consumer rights request, please email privacy@surepeople.com
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to privacy@surepeople.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.
9. International Users and Visitors
By using the Platform or our services, you understand and acknowledge that your Personal Information will be processed and stored in the United States, and may be disclosed to our service providers and affiliates in other jurisdictions. You acknowledge that your Personal Information may be processed outside of the country in which you are a resident and in countries that are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the European Economic Area (EEA). In such cases, SurePeople will ensure that we or the recipient of your Personal Information offer an adequate level of protection and that such transfers are made consistent with applicable law.
Subject to any exemptions provided by law, if you are located in the EEA, you may have the right to request access to, as well as to seek to update, delete, correct, or restrict or object to the processing of your Personal Information. As explained above, we process Personal Information in various ways depending upon your use of our Platform. SurePeople relies on the following bases to process Personal Information: (1) as necessary to perform a contract when you request services; (2) as necessary for our legitimate interests in providing, enhancing, and protecting our Platform and providing you with marketing materials; and (3) with your lawful consent. You have a right to opt out of SurePeople’s use of your Personal Information for direct marketing purposes at any time.
You may write to our Privacy Office at privacy@surepeople.com with any questions or to make a request for access to, update to, deletion or correction of your Personal Information, or restriction or objection to the processing of your Personal Information. You also have the right to complain to the data protection authority in the country where you reside, work, or where an alleged infringement of data protection laws has taken place.
10. Data Security
SurePeople has implemented reasonable, risk-based technical and organizational measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored in a secure cloud environment. Any payment transactions will be encrypted using SSL technology.
Notwithstanding the foregoing, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform or Mobile Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Platform. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Application by any third party unless the circumvention was the result of our gross negligence or willful misconduct.
11. Children
The Platform is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Platform or through any of its features, register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of this Platform, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@surepeople.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see “California & Other State Laws” above for more information.
12. Additional Information
If you have any questions or concerns about your privacy on the Site, or wish to opt-out of any email list, please contact us at: privacy@surepeople.com
