Last updated: June
Pymetrics, Inc. (“Pymetrics”, “we”,
“our”, or “us”) values the trust our users (“you”) place in us when they give
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. 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
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
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
THAT WE COLLECT ABOUT YOU
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:
and last name
occupation and title
You may also be asked to provide your demographic
information. However, providing such
information will always be voluntary.
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.
Created or Provided by You
We also collect the content you create,
upload, or receive from others when using our Site. This includes things like videos
that you record and submit to an employer and/or save on the Site.
Provided When You Contact Us
We may collect Personal Information that you voluntarily
provide to us when you contact us with a question, comment, business inquiry,
or other request for information. We 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:
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.
When you record and submit videos (“Videos”) on the Site,
we may also collect and retain voice and audio information and a transcript of your
audio information in the Video.
We may collect application log information like you’re the companies
you’ve submitted a job application for through the Site, the specific role(s)
you’ve applied for, and the time and date of such applications.
please see the Cookies and Other Tracking
Technologies section below.
We may collect certain additional information when you
access our Site with a mobile device or with Pymetrics IOS and Android mobile
apps. This information may include location, device type, unique device
identifier, operation system, and other app-specific user data. This data is
analyzed to help us create a more user-friendly mobile experience. You may restrict
collection of certain data, like location by changing the setting preferences
on your mobile device.
3. COOKIES AND
OTHER TRACKING TECHNOLOGIES THAT WE USE
scripts, and local shared objects in connection with the Site.
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.
information about visitors’ activities while using the website.
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 assist
our site with the automated collection data on user behavior. Pymetrics will
not be able to personally identify you in connection with these practices.
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
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.
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.
Analytics. We may also use service providers, such as Google Analytics,
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
Uses. We use the information we collect to
manage, analyze, develop, customize, and improve our Site as well as our
products and services (including our Games). We sometimes use automated
decision making in processing your information, such as to create your “Trait
Profile.” Your "Trait Profile" is used to
help inform employer decisions by determining your "fit" by comparing
your individual results against the results of a general candidate pool.
Provided When You Register for an Account and Use Our Site and Other Products
and Services. 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 or Video submissions, 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.
Provided When You Contact Us (Including Signing Up for Sales and Marketing Communications).
We may use this information to understand and respond to your question or
comment, and/or reach out to you regarding your business inquiry or request
regarding our products and services.
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 Video
submissions, and developing your Trait Profile.
or De-identified Data. We may use your Personal Information and
passively-collected information to create aggregate or de-identified data, such
as 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 aggregated or de-identified data
about the Site’s users for any lawful purposes.
We also reserve the right to use such information in collaboration with
outside researchers to measure and quantify the effectiveness of our products
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 or submit Videos 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.”
Candidates. If you were directed to
visit the Site, create an Account (or to sign into your existing Account), and
play the Games or submit Videos as part of the job application process for a
specific employer, then we may use your information to assess your fit to the specific
role(s) for this employer. In such a
scenario, you would be deemed a “Job Candidate.”
Purpose. We may use your information
for any additional purpose which you separately authorize in the course of
accessing and using our Site.
Lawful Basis for
Processing Your Information. If
European data protection law applies and we act as a controller, our lawful
will depend on the information concerned and the specific context in which we
collect or use it. We normally collect
or use information from you or others only where we have your consent to do so,
where we need the information to perform a contract with you, or where the
processing is in our legitimate interests and not overridden by your data protection
interests or fundamental rights and freedoms. In some cases, we may have
a legal obligation to collect or retain personal information or may need the
personal information to protect your vital interests or those of another
person. If you have questions about or
need further information concerning the lawful basis on which we collect and
use your personal information, please contact us using the contact details
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 aggregated 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.
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.
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 the option is available to you, and 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 the option is available to you, and 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.
Candidates. If you are a job candidate
playing the Games as part of the job application process, then we share your
Personal Information and Trait Profile with the employer and any third party that is pertinent to the employment application
process for the specific role(s) you are applying to through our Site.
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.
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.
– International Transfers of Personal Information. If you
are located outside of the United States, the Personal Information that we
collect from you may be transferred to, and stored at, a destination internationally
(for example, 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 internationally (for example, outside
the EEA who work for us or for one of our suppliers). The country in which your Personal
Information may be transferred to and processed in may have data protection
laws that are different to the laws of your country (and in some cases, may not
be as protective). By submitting your
Personal Information on the Site, 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
more information on where we store Personal Information and on
our security, please see the “Security” section in Section 8 of this
6. EU-U.S. AND SWISS-U.S. PRIVACY SHIELD NOTICE
Effective: October 19, 2018
participates in and has certified our compliance with the EU-US Privacy Shield
and the Swiss-US Privacy Shield frameworks regarding the collection, use, and
onward transfer of Personal Information that we collect and process from the
EEA, United Kingdom, and Switzerland. We
have certified to the Department of Commerce that we adhere to the Privacy Shield
Principles of notice, choice, onward transfer, security, data integrity,
access, and enforcement for Personal Information that we receive from companies
or individuals in the EEA, United Kingdom, and Switzerland. Our Privacy Shield certification will be
available here. We also receive some data in reliance on
other compliance mechanisms, including data processing agreements based on the
EU Standard Contractual Clauses. If
Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield
Framework, visit the US Department of Commerce’s website
Processed. See Sections 2 and 3 of
Information Processing. See Section
4 of this Policy.
Third Parties with
Whom We May Share Information. See
Section 5 of this Policy.
Complaints. If you are a resident of a European country participating in
the Privacy Shield and you believe we maintain your Personal Information within
the scope of this Privacy Shield certification, then you may direct any
questions or complaints concerning our Privacy Shield compliance via the
contact information in Section 8 of this Policy below. We will work with you to resolve your issue.
Resolution. If you are a resident of
a European country participating in the Privacy Shield and you have not
received timely response to your concern, or we have not addressed your concern
to your satisfaction, you may seek further assistance, at no cost to you, from
JAMS (www.jamsadr.com), which is an independent dispute resolution body in the
Arbitration. You may also be able to invoke binding
arbitration for unresolved complaints but prior to initiating such arbitration,
a resident of a European country participating in the Privacy Shield must first:
(1) contact us and afford us the opportunity to resolve the issue; (2) seek
assistance from JAMS; and (3) contact the U.S. Department of Commerce (either
directly or through a European Data Protection Authority) and afford the Department
of Commerce time to attempt to resolve the issue. If such a resident invokes binding
arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the
Privacy Shield, the arbitrator(s) may only impose individual-specific,
non-monetary, equitable relief necessary to remedy any violation of the Privacy
Shield Principles with respect to the resident.
Trade Commission Enforcement. Our
Privacy Shield compliance is subject to the investigatory and enforcement powers
of the U.S. Federal Trade Commission (FTC).
Right of Access. See Section 7 of this Policy.
Disclose. We may disclose Personal
Information when we have a good faith belief that such action is necessary to:
conform to legal requirements or to respond to lawful requests by public
authorities, including to meet national security or law enforcement
requirements, or to enforce our contractual obligations.
Liability. If a third-party service provider providing
services on Pymetrics’ behalf processes Personal Information from the EEA or
Switzerland in a manner inconsistent with the applicable Privacy Shield
Principles, Pymetrics will be liable unless we can prove that we are not
responsible for the event giving rise to the damages.
Data. Pymetrics commits to
cooperating with EU Data Protection Authorities (DPAs) and the Swiss Federal
Data Protection and Information Commissioner (FDPIC) and will comply with the
advice provided by such authorities with regard to human resources data
transferred from the EU and Switzerland in the context of Pymetrics’ employment
relationship with our employees.
7. YOUR CHOICES REGARDING YOUR INFORMATION
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
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
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.
We may also send you information for marketing purposes if
you have signed up for such communications or otherwise indicated an interest
in receiving such communications. If you
no longer wish to receive these communications, you may opt-out by contacting
us directly or by clicking the opt-out link in our email marketing
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 firstname.lastname@example.org 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.
A note about our Games specifically: 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 twelve (12) months after you have completed the Games.
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 email@example.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.
You may request to delete your Personal Information by emailing
us at firstname.lastname@example.org with information necessary for us to process your
request. Note that any deletion request
will be subject to our Retention Policy below.
A note about our Games specifically: 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 twelve (12) months after you have completed the
GDPR Rights. If
you are a ‘data subject’ protected under the EU General Data Protection
Regulation (GDPR), you have certain rights regarding your Personal Information.
For more information regarding your rights as a ‘data subject’, please refer to
the Privacy Notice that is presented to you immediately before you begin using
our Site and other products or services.
We retain Personal Information from you with your consent,
or where we have an ongoing legitimate business need (for example, to provide
you with a service or other information you have requested or to comply with
applicable legal requirements). When we have no on-going legitimate business need
to process your Personal Information, we will either delete, de-identify or
anonymize it, or, if this is not possible (for example, because your Personal
Information has been stored in backup archives), then we will securely store
your Personal Information and isolate it from any further processing until
deletion is possible. The follow are
examples of how long we typically retain your Personal Information for
legitimate business needs:
- When You
Interact with Sales, Marketing, and Customer Support: We may retain your Personal Information as long
as necessary to provide you with your request for information or other responses.
- When You Sign Up for an Account: 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 Terms of Service).
In accordance with our
obligations and requirements under local law, we must retain your information
for a period of two (2) years following the date of your last recorded
assessment for a particular role (“Assessment”). 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 do not have any recorded
assessments for a role during the last two (2) years, then we will process your
request within ten (10) business days of receipt.
Even if we are obligated to retain
certain information, once you delete your Account or request 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 (if available to you) through the Privacy Settings tab of
your Account profile.
As discussed above, we may aggregate or de-identify our user’s
Personal Information and other information; such data cannot be used to
identify you. We will retain such data
even after any Personal Information deletion requests have been processed.
- When We Process Your Personal Information on Behalf
of Our Customers: We retain your Personal Information in accordance
with the timeframes set out in the relevant customer agreements between us
and the applicable customer(s).
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.
Public Features of the Sites. Our Site may contain features, e.g. job boards,
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
Single Sign-On. You can create
an Account using third-party 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. While
we take all steps we consider appropriate to protect your data, including technical
and organization measures to ensure that your Personal Information is handled
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
eighteen (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 eighteen (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
free to contact us at email@example.com or at:
ATTN: Data Protection Officer
102 Madison Avenue, 5th Floor
New York, NY 10016
United States of America