PYMETRICS PRIVACY POLICY

Last updated: February 6, 2018

1. INTRODUCTION

Pymetrics, Inc. (“Pymetrics”) values the trust our users place in us when they give us access to their personally-identifiable information (“Personal Information”). This Privacy Policy (“Policy”) describes how we work to maintain that trust.

Pymetrics has created this Policy in order to outline our collection, use, and sharing of information you provide to us when you access or use Pymetrics’ online and/or mobile services and websites (collectively, the “Site”), including, without limitation, pymetrics.com, any Pymetrics- mobile application, and any software provided by Pymetrics in connection with such services or websites. For the purposes of this Policy, any references to “we,” “our,” or “us” shall mean Pymetrics. This Privacy Policy covers only information that we collect through the Site, and not any other information collection or processing outside of the Site.

Please note that we reserve the right to review and update this Privacy Policy from time to time. Accordingly, each time you access or use the Site, you should check the Last Updated legend at the top of this Policy, and review any changes since you last accessed or used the Site. If you access or use the Site after an updated Privacy Policy is published, you will be deemed to have agreed to the amended Policy.

BY ACCESSING AND USING THIS SITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THIS SITE.

2. INFORMATION THAT WE COLLECT ABOUT YOU

Information Provided by You Upon Creating an Account

When you create and register a user account (“Account”) on the Site, you may be asked to provide or confirm certain pieces of Personal Information, which may include one or more of the following:

1. First and last name
2. E-mail address
3. Educational history
4. Current occupation and title
5. Employment history
6. Demographic information

We may supplement the Personal Information you provide with additional Personal Information we gather from public sources or from third-parties (e.g., consumer reporting agencies) that may lawfully provide such information to us.

You are under no obligation to provide your Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the Site’s features and services.

Information Provided When You Contact Us

We may collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Site.  We generally collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our products and services:

1. Name
2. E-mail address
3. Phone Number

Passively Collected Information

When you access and use our Site, we may automatically collect and retain certain types of information, including your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, such as your browser type and version, time zone setting, and operating system and platform. 

When you play our online neuroscience-based games (the “Games”) on the Site, we also collect and retain your “Gameplay Data,” which is defined as information and data collected from your behavior and actions in the course of playing our Games, including metadata about your real-time user interaction with the Games. After your completion of the Games, the Site will review your Gameplay Data and generate your specific “Trait Profile,” which contains the Site’s assessment and description of your cognitive, social, and personality traits.

We also use cookies on our Sites; for more information, please see the Cookies and Other Tracking Technologies section below.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE

We and our service providers use cookies, beacons, embedded scripts, and local shared objects in connection with the Site.

• Cookies are small text files that are stored on your computer or device when you visit our Site. Cookies allow a website to recognize a particular device or browser. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website.

• Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Site and typically work in conjunction with cookies to identify our users and user behavior.

• An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

• Local Shared Objects.  Local shared objects (or Flash cookies) are pieces of data that websites which use Adobe Flash may store on a user’s computer or device. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity use local shared objects. Various browsers may offer their own management tools for removing local shared objects. In addition, you may manage Flash cookies by clicking here:  http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

The above technologies are used in analyzing trends; administering the Site and its features and services; tracking users’ movements around the Site; and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies on an individual as well as aggregated basis.

We use cookies to remember users’ settings, market products and services to users, and for authentication purposes. To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept, or delete cookies from our Site at any time.  The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies; how to have the browser notify you when you receive a new cookie; or how to disable cookies altogether.  Please note that if cookies are disabled or removed, not all features of our Site will operate as intended.

Third-Party Analytics.  We may also use service providers, such as Google Analytics, that may use cookies or other technologies to collect information about your online activities across this and other sites over time for non-advertising purposes such as those described above.  To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/.

4. WHAT WE DO WITH THE INFORMATION WE COLLECT

• General Uses.  We also use the information we collect to manage, analyze, develop, customize, and improve our Site as well as our products and services (including our Games).

• Information Provided When You Register an Account and Play Our Games.  We may use this information to authorize and administer your access to the Site, verify your identity, authenticate your visits, and provide our products and services to you. We may also use your information to improve and personalize your experience with us (including showing you relevant information such as your job matches), and, with your consent where necessary, notify you when you match a new open role on the Site, notify you when a recruiter or another user contacts you, remind you to finish any incomplete Games, send you information about us, and keep you informed of our products and services that may be of interest to you. We may combine your Personal Information with other Personal Information lawfully collected from third parties in order to better market and provide our products and services.

• Information Provided When You Contact Us.  We may use this information to understand and respond to your question or comment.

• Passively Collected Information.  We use passively collected information to monitor and maintain the performance of our Sites; analyze trends, usage, and activities in connection with our services; validate users and ensure their technological compatibility with users; optimize our marketing efforts; and to provide our products and services to you, including analyzing your Gameplay Data and developing your Trait Profile.

• Aggregate Data.  We may use aggregate our user’s Personal Information and passively-collected information to create aggregate data which cannot be used to identify you (“Aggregate Data”). For example, Aggregate Data may include data that describes the general demographics, usage, Gameplay Data, or other characteristics of a Site’s users. We reserve the right to use, transfer, and/or sell Aggregate Data about the Site’s users for any lawful purposes. We also reserve the right to use such aggregate information in collaboration with outside researchers to measure and quantify the effectiveness of our products and services.

• Public Profile. If you select Public in your Privacy Settings tab on your Account Profile, we may use your information to match you with potential employers or job openings.

• Incumbent Employees. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and play the Games by your current employer, then we may use your information to create a talent assessment model for a specific role at your current employer. In such a scenario, you would be deemed an “Incumbent Employee.”

• Job Candidates. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and play the Games as part of the job application process for a specific employer, then we may use your information to assess your fit to a specific role(s) at this employer. In such a scenario, you would be deemed an “Job Candidate.”

• Other Purpose. We may use your information for any additional purpose which you separately authorize in the course of accessing and using our Site.

5. WITH WHOM WE SHARE THE INFORMATION WE COLLECT

Personal Information of our users is an integral part of our business. We reserve the right to share your Personal Information with third parties as described below. We also reserve the right to transfer and/or sell other types of data, including aggregate or de-identified data derived from Personal Information, for lawful purposes in our discretion. Note that we do not share Personal Information with third parties for their direct marketing purposes.

• Service Providers. We, like many businesses, sometimes hire other companies (“Service Providers”) to perform certain business-related functions. Examples include customer service, maintaining databases, data storage, cloud services, and hosting services. When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include Personal Information and other information that you provide to us via the Site. These Service Providers are authorized to use your information only as necessary to provide these services to us.

• Legal Requirements.  We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of users of the Site or the public; (d) protect against legal liability; or (e) or as otherwise required or permitted by law.

· Public Profile. If you select Public under the “Recruiting Visibility” section of the Privacy Settings tab on your Account profile, then we may share your Personal Information and Trait Profile with a potential employer when our Site determines that you might be a good match for this employer.

· Limited Profile. If you select Limited under the “Recruiting Visibility” section of the Privacy Settings tab on your Account profile, then we may share your Personal Information and Trait Profile with potential employers that you have actively expressed interest in.

• Job Candidates. If you were directed to visit the Site, create an Account, and play the Games as part of the job application process for a specific employer, then we share your Personal Information and Trait Profile with this employer and any third party that is pertinent to the employment application process.

• Business Transfers.  As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, total or partial sale of assets in bankruptcy or similar event, your Personal Information and other information may be part of the transferred assets.

• Other Third Parties. We may disclose your information to other third parties with your prior express consent.

You hereby consent to our sharing of your Personal Information and other information for the above purposes.

EU Residents – International Transfers of Personal Information.  The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) in reliance on a variety of compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your Personal Information, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

6. YOUR CHOICES REGARDING YOUR INFORMATION

Choice

You are not required to create an Account to gain access to many services and features of the Site. If you use the Site’s personalized services and features (e.g., the Games and Trait Profile), you will need to create an Account and enter Personal Information, which we will treat as described in this Privacy Policy.

Our Opt-out Policy

We may send you notifications and communications using the email address you provided to us when you registered your Account. To stop receiving some or all email communications from us, you can use the “Email Settings” tab of your Account profile to edit your email preferences. Alternatively, you can use the “unsubscribe” mechanism provided in the email communication

We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your account.

Accessing, Correcting, and Updating Your Information

You may access, correct, and update most of your Personal Information under the Account Settings tab of your Account profile. You may also email us at support@pymetrics.com with information necessary for us to process your request. We will respond to your request within a reasonable timeframe. We may need to verify your identity before granting access to Personal Information in our custody or control. 

Note that because some of our Games are designed to test memory and instinctive behavior (which can be skewed through subsequent gameplay), once you start or complete the Games, your Gameplay Data and Trait Profile cannot be reset, amended, deleted, or overridden for a period of 12 months after you have completed the Games.

Deactivating Your Account

You may deactivate your Account using the Deactivate Account button under the Account Settings tab on your Account profile. When you deactivate your Account, you will no longer be able to log into the Account. You will also no longer be able to create any new Accounts with the email address associated with the deactivated Account. If you wish to reactivate your deactivated Account, please email us at support@pymetrics.com with the email address.

A deactivated Account does not mean that all of the information associated with your Account is expunged from our systems, although such information will now no longer be readily available to you.

Deleting Your Information

You may request to delete your Personal Information by emailing us at support@pymetrics.com with information necessary for us to process your request. Note that any deletion request will be subject to our Retention Policy below.

Note that because some of our Games are designed to test memory and instinctive behavior (which can be skewed through subsequent gameplay), once you start or complete the Games, your Gameplay Data and Trait Profile cannot be reset, amended, deleted, or overridden for a period of 12 months after you have completed the Games.

Our Retention Policy

We may retain your information for as long as your Account is active or as long as necessary to provide you with our services, comply with our legal obligations and regulatory requirements, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our End User Agreement).

Upon your request to delete information associated with your Account, our retention policy differs depending whether you last played the Games as a Job Candidate:

· If you played the Games as a Job Candidate: If you were directed to visit the Site, create an Account (or sign into your existing Account), and play the Games as part of the job application process for a specific employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of 2 years following the end of the hiring cycle of which you took part. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the 2-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this 2-year anniversary, then we will process your request upon 10 business days of receipt.

· If you played the Games as a Site visitor: If you were NOT directed to the visit the Site and play our Games by a specific employer (either your current employer or a third party employer as part of its job application process), then we will process any information deletion request within 10 business days of receipt. Notwithstanding the foregoing, if you played the Games, we must retain your email address and Gameplay Data for a period of 12 months following the date of your last gameplay. We must do so in order to monitor and enforce our End User Agreement, which prevents users from playing the Games more than once in any 12-month period. Retaining email addresses for a period of 12 months is our only means of ensuring that users are not deleting Personal Information and Gameplay Data in order to replay our Games during this timeframe. Accordingly, if you request deletion of your email address and Gameplay Data prior to this 1-year anniversary, we must wait until the 1-year period has passed, after which we will process your deletion request. If you request deletion of your email address and Gameplay Data after this 1-year anniversary, then we will process your request upon 10 business days of receipt.

Even if we are obligated to retain certain information, once you deactivate your Account or request to deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site, regardless of whether you selected Public or Limited through the Privacy Settings tab of your Account profile.

As discussed above, we may aggregate our user’s Personal Information and other information to create de-personalized Aggregate Data which cannot be used to identify you. We will retain such Aggregate Data even after any Personal Information deletion requests have been processed.

7. MISCELLANEOUS

Other Websites.  Our Site may contain links to third-party owned and/or operated websites or mobile applications. We do not own nor control these third-party websites or mobile applications, and accordingly assume no responsibility for the information practices of those sites or apps. We suggest that you review their privacy, security, and data collection and distribution policies, if any, prior to providing such websites or apps with any information.

Blogs and Public Features of the Sites.  Our Site may contain features, e.g. blogs, chat rooms, community forums, sharing functions, etc., that permit you to upload, post, transmit, display, perform, or distribute content and information, including your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.

Single Sign-On.  You can create an Account using sign-in services such as Facebook or LinkedIn. This service will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form. Please note that your relationship with Facebook, LinkedIn, or any other third-party website is governed solely by your agreement with such third-party website.

Security.  The security of your Personal Information is important to us. We take commercially reasonable steps to help protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. For example, we use one or more of secure socket layer (SSL) encryption, firewalls, and self-updating anti-virus software. Your Personal Information will be stored in the United States and will be subject to laws applicable in that country. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. Please create a unique password for your Account and do not share your password with anyone else.

Minors.  Visitors under 18 years of age are not permitted to use and/or submit their Personal Information at the Site. We do not knowingly solicit or collect information from visitors under 18 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Contacting Us. The Contact Us link on the Site contains an e-mail link that allow you to contact us directly with any questions or comments that you may have. If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at support@pymetrics.com or at:

Pymetrics, Inc.
373 Park Avenue South, 9^th Floor
New York, NY 10016
United States of America