Last updated: April 24, 2023
What is Personal Data?
Information we collect from you and why
Sometimes we collect Personal Data automatically when you interact with our Services and sometimes we collect Personal Data directly from you. At times, we may collect Personal Data about you from other sources and third parties (e.g., GSuite, Zendesk, etc.), even before our first direct interaction.
Personal Data Collected from Site Visitors and Account Holders
We collect the following Personal Data submitted to us by visitors to our Site and account holders:
- Account Information: When you register as an Assembled User, we may request you to provide Personal Data such as your name and email address. We also collect information, including Personal Data, that you submit to or provide on the Services. If your account is related to any of our Customers’ accounts, the Customers’ administrators (“Admins”) may also direct us to collect your work availability and other information. We use your Personal Data to provide the Services to you and our Customers and to respond to your inquiries.
- Inquiry Information: If you express interest in obtaining information about our Services or in signing up for an event or webinar, provide our business partner with your information, or download certain content, we may require you to provide us with Personal Data such as your name, email address, address, phone number, title, company name, and other information. We use this information to provide you with promotional materials, such as Assembled newsletters, marketing, or other information that may be of interest to you. If you decide that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in the communications or the instructions provided in the “Your Choices” section below.
- Survey Information: We may collect information from you in surveys that we may conduct in order to improve the Services.
- Payment Information: We may accept financial and billing information in order to process your payment for use of the Services.
- Employment Application Information: We may collect information you provide to us in connection with applying for a position through our Careers page, including your contact and demographic information, date of birth, photo, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
- Contact and Other Information: We may collect your name, email address, mailing address, company, employer, phone number and communication preferences when you interact with the Services. We also collect any other information you choose to provide this information to us.
Personal Data Automatically Collected
As is true of most digital platforms, we and our third-party providers may also use (i) cookies or small data files that are stored on your computer or device and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect information, which may contain Personal Data, from your devices while you navigate our Services or interact with emails we sent to you.
- When you use the Services, we may collect information about the devices you use to access the Services, including IP address, browser or device type, operating system, the website you visited before the Services, identifiers of your devices and location data (such as general geographic location based on the log data we or our third-party providers collect). We use this information to provide, improve, and protect the Services.
- When you interact with our Services, we collect information about how you use the Services, including tracking Users’ activity in our Services. We use this information to provide and improve the Services, and to protect the Services. We may also provide our Customers’ Admins with this information.
- We and our third-party providers may also utilize persistent cookies to save your username and password for future logins to the Services. We utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by visitors and Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Services. A tracking pixel is a unique identifier embedded in a website, online advertisement, or email. We use tracking pixels to understand how you interact with our websites and emails and they help us and our advertising service providers better promote our Services.
- We also use HTML5 local storage objects (“HTML5 LSOs”) or Flash local storage objects (“Flash Cookies”) to store content information and preferences. Our Site does not respond to Do Not Track signals.
For more information on how to manage cookies and related data collection technologies, please see the “Your Choices” section below.
Personal Data from Third Parties
We also obtain Personal Data from third parties; which we often combine with Personal Data we collect either automatically or directly from you.We may receive the same categories of Personal Data as described above from the following third parties:
- Our Customers: If you engage in our Services through any of our Customers, we may receive information from them such as name and contact information.
- Social Media: When you interact with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Data and often share some or all of this information with us.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Data we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
- Third Parties Related to Employment Applications: If you apply for a job with Assembled, we may receive information from your current or past employers, background check providers, third-party social media platforms and other third parties we use to obtain information about job applicants.
- Publicly Available Sources: We collect Personal Data about individuals that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.
Third Party Data Collection and Online Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. Please see “Your Choices About Online Ads” below, to learn more about interest-based advertising.
- Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies. We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
- Third Party Partners. We work with third-party service partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Site or Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On at https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
You also have choices with respect to technologies we use to automatically collect information as described below:
- Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your geolocation and to integrate with your other applications.
- How to Control Your Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt-out of Services-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
- How to Control Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
- Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at firstname.lastname@example.org. We may not be able to modify or delete your information in all circumstances.
- Your Choices About Cookies: If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.
Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.To learn how to manage privacy and storage settings for Flash Cookies, please visit the Macromedia site. HTML5 LSOs can be managed using browser tools and settings.
- Your Choices About Online Ads: We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.allaboutcookies.org. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.
How We Use Information
We collect and use the Personal Data described above in order to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email, text message, social media and/or telephone calls;
- Request individuals to complete surveys about our organization, organizations we partner with, and Services;
- Market our Services to individuals, including through email, direct mail, text message, social media and telephone calls;
- Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
- Facilitate customer benefits and services, including Customer support through our command center services;
- Identify and analyze how individuals use our Services;
- Conduct research and analytics on our Customer base and our Services;
- Improve and customize our Services to address the needs and interests of our Customer base and other individuals we interact with;
- Evaluate your candidacy for employment, communicate with you during the job application process, and facilitate the onboarding process;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Defend, protect or enforce our rights or applicable contracts and agreements;
- Process a business transaction or reorganization;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
- Comply with legal obligations.
Information Sharing and Disclosure
We disclose Personal Data in the following ways:
- Customers and Other Users: If your User account was provisioned by a Customer, the Customer’s Admin may have access and control over the information associated with your account. The Customer may have its own policies governing access and use of information in your User account. Additionally, depending on the Customer’s settings and your choices, we will share certain information with other Users that are also part of the associated Customer’s account.
- Service Providers: Assembled engages certain third-party service providers that perform business or operational services for us on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, marketing and advertising services, administrative services and employment application-related services.
- Affiliates: We may share your information, including Personal Data, with Assembled’s affiliates to provide, improve, protect, and promote the Services, or communicate with you.
- Other Businesses as Needed to Provide the Services: We may share Personal Data with third parties that an individual engages with through our Services or as needed to fulfill a request or transaction.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose your information to third parties, such as legal advisors and law enforcement: (a) to comply with applicable law, regulation, legal process, or government request, (b) to protect the health and safety or us and others, or any person from death or serious bodily injury, (c) to detect, suppress or prevent fraud, abuse, or any security issue of Assembled or others, (d) to protect Assembled’s or its licensors’ rights, property, safety, or interest, including to enforce our agreements and policies, and (e) in connection with the establishment, exercise, or defence of legal claims.
If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at email@example.com to submit such a request.
For EU and Swiss Individuals: Privacy Shield Notice for Personal Data Transfers to the United States
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Assembled’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Assembled remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Assembled proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Assembled commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Assembled by email at firstname.lastname@example.org or via post at:
2525 16th Street
San Francisco, CA 94103
Assembled has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Links to Third Party Websites or Services
Our Policy on Children
The Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Data from individuals under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any Personal Data either directly or by other means. If a child under the age of 13 has provided Personal Data to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Data from our systems. If Assembled becomes aware that a child under the age of 13 has submitted information to us, we will promptly delete the information. If you believe that we may have any information from a child under the age of 13, please contact us at email@example.com.
2525 16th Street
San Francisco, CA 94103