Last updated September 2022
By accessing and using the Platform, you agree that you have read and understand this Policy. This Policy does not apply to any other websites. You can access and interact with our Platform in many ways, including from a computer or mobile device. This Policy applies regardless of how you access or interact with our Platform. Depending on how you interact with our Platform, there may be some cases where we need to provide you with additional information about how we use your Personal Data and/or what options you have regarding our use of your Personal Data. We may provide this additional information via notices on the Platform or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Policy.
Please read this Policy carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Policy, please do not use our Platform, provide us with your Personal Data or authorize a third party to make your Personal Data available to us. By using the Platform, providing us with your Personal Data or otherwise making your Personal Data available to us, you acknowledge that you understand that we may use your Personal Data as described in this Policy. If you have any questions about how we collect, use, protect, disclose or otherwise process Personal Data, including whether we have received your Personal Data from a third party, please contact us by email at firstname.lastname@example.org.
WE COLLECT PERSONAL DATA AND USAGE INFORMATION
When we refer to “Personal Data” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
Our primary goals in collecting Personal Data are to provide and improve our Platform, conduct our operations, communicate with you and enable visitors to our Platform to enjoy and easily navigate it.
Categories of Personal Data We Collect
Depending on the type of activity you are performing on the Platform or how you use or interact with our Platform, we may collect and disclose the following Personal Data:
- identifiers and contact information, such as your name, email address, telephone number, postal address, physical address, date of birth, online identifier, IP address and other similar information;
- demographic information, such as your age, national origin, and other similar information;
- internet and other similar network activity information, such as your browsing history, search history, interactions with the online portions of our Platform and online advertisements and other similar information;
- professional or employment-related information, including current or past job history and other similar information;
- online identifiers you use, such as your username, social media handles and other similar information;
- communication information, such as information contained in voicemails, chats, emails and other similar information;
- location information, such as where you live, where you are located and other similar information; and
- other information you provide us or authorize us to collect about you.
Depending on how you access, interact with, or use our Platform, the Usage Information that we, or third parties acting on our behalf, collect may include:
- device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a computer or mobile device used to access or interact with our Platform;
- information about your interactions with our Platform, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with activities on our Platform;
- information about Internet and network activity, such as websites visited, search engine results and other similar information associated with a computer or mobile device that accesses or interacts with our Platform;
- information automatically collected by cookies and other technologies on our Platform; and
- any other information that a computer or mobile device automatically sends whenever connected to a website or an online application.
For more information about how we collect Usage Information, please see the “How We Collect Usage Information” section below.
HOW WE COLLECT YOUR PERSONAL DATA
A large portion of the Personal Data we, or third parties acting on our behalf, collect is collected directly from you. In some cases, we may collect Personal Data from third parties in the ways described in this Policy.
Directly From You.
When you engage with us in connection with our Platform, such as requesting information, creating an account, communicating with us or otherwise interacting with us, we may ask you to provide certain Personal Data. Some of the Personal Data we request may not be required, however, we will specifically indicate what Personal Data is required to engage in such activity.
From Third Parties.
We, or third parties acting on our behalf, may collect Personal Data about you from third parties, including, without limitation, online and offline sources, entities and individuals affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Sources”). The collection of Personal Data from these Third Party Sources can occur in a variety of ways, including, without limitation:
- When you access, use or interact with our Platform through Third Party Sites, associate your access, use or interaction with our Platform with Third Party Sites or share our content via Third Party Sites, you acknowledge that you are authorizing use to collect, share, store and use any Personal Data we receive from those Third Party Sites about you. In some cases, you may be able to revoke our access to your Personal Data and other content and information we receive from Third Party Sites by changing the appropriate settings for your account with the applicable Third Party Site.
- When you use single sign-on tools. Some of the features of our Platform may provide you with the ability to register and sign into our Platform through the accounts you have with certain third parties, such as Google (“Third Party Single Sign On Providers”). When you use these features, we, or third parties acting on our behalf, gather the data necessary to create an account on our Platform from the applicable Third Party Single Sign On Provider, which may include, without limitation, your name, email address, IP address, device model, device operating system and web browser, time zone, carrier, screen size, processor cores, total disk space and remaining disk space. Your data associated with the applicable Third Party Single Sign On Provider will not be sold, redisclosed or edited through this process. Your ability to use this option may be limited where the applicable Third Party Single Sign On Provider requires you to use a device or operating system that meets that Third Party Single Sign On Provider’s requirements. Please note, by using these features, the applicable Third Party Single Sign On Provider will know that you are signing into our Platform and that you are a user of our Platform.
- We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with our Platform (“Service Providers”). Service Providers may include, without limitation, third parties that host our Platform, parties that provide us services related to the communications we send and receive, and other financial institutions and financial services companies that we partner with to provide our Services.
Our collection, use, disclosure, and storage of the Personal Data we receive from Third Party Sources will be as described in this Policy.
Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more Third Party Sources.
HOW WE COLLECT USAGE INFORMATION
We, and third parties acting on our behalf, collect Usage Information in a variety of ways. Some Usage Information, such as the IP address of a device attempting to access, use or interact with our Platform, is necessary for us to make certain portions of our Platform available. Other Usage Information, such as information about which features of our Platform are popular, helps us improve and advertise our Platform. The primary systems and technologies used to collect Usage Information in connection with our Platform are:
- the systems we use to make our Platform available to you, including the systems we use to help us identify and address technical issues and errors. When you access, use, or interact with our Platform, these systems automatically record certain information that your browser or device sends whenever you visit a website or utilize an online application as well as information about how long your device is connected to our Platform and the activities that device engages in while connected. These systems also automatically collect information about your actions and activities on our Platform.
- other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Platform, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
- Third party analytic tools, such as:
- LinkedIn Insight Tag. We may use Linked Insight Tag, a cookie placed by LinkedIn that enables us to measure the effectiveness of advertising campaigns served on LinkedIn. The information collected by that cookie will be transmitted directly to and stored by LinkedIn. For more information about LinkedIn’s privacy practices, please refer to https://www.linkedin.com/legal/privacy-policy. To opt-out, you can update your advertising preferences through your LinkedIn account. If you do not have a LinkedIn account, LinkedIn allows you to opt-out of applicable targeted advertising by visiting https://www.linkedin.com/psettings/guest-controls.
Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
HOW WE USE YOUR PERSONAL DATA AND USAGE INFORMATION
This section describes the primary purposes for which we use the Personal Data we, or third parties acting on our behalf, collect.
- Operational Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Platform, which may include, without limitation, presenting content to you and other users to fulfill our business purposes and to facilitate your use of features you elect to use on our Platform, such as engaging in transactions with other users through our Platform; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) notifying you about issues with, or changes to, our policies, terms, and agreements; (5) sending you emails to provide you with alerts and updates about your engagement with our Platform, including without limitation informing you if relevant job postings would be a good fit for your contacts; (6) providing customer service; (7) conducting statistical or demographic analysis; (8) complying with legal and regulatory requirements; (9) customizing your experience with our Platform; (10) protecting and defending us against legal actions or claims; (11) preventing fraud; (12) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (13) registering your account; (14) any purpose for which you authorize or instruct us to use your Personal Data; and (15) other business purposes permitted under applicable law.
- Marketing Purposes – we may, either on our own or jointly with our third party marketing partners (“Marketing Partners”), use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Policy) and use such linked information for Marketing Purposes. Our Marketing Purposes may include using Personal Data collected through cookies and other tracking technologies to facilitate the delivery of promotions, and offers to you, on behalf of ourselves and our Marketing Partners on and off our Platform.
We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Platform for materially different, unrelated or incompatible purposes without providing you notice.
Please note, we may use and disclose aggregated, anonymized or de-identified information collected in connection with our Platform and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Policy.
HOW – AND WHY – WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES
To operate our Platform and provide our Services, we may share certain Personal Data that we, or third parties acting on our behalf, have collected, with certain third parties under the following circumstances:
- With your consent. Except for as outlined below, we only share your information with third parties when you have directed us to do so.
- With our Service Providers. We may share your Personal Data with our Service Providers as needed to complete any transaction or provide any Service you have requested or in connection with the services they provide to us, including, without limitation, order fulfillment, marketing of our products and services, data hosting, fraud protection and prevention, and as otherwise provided in this Policy. We require these Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which it was provided to them.
- For legal reasons. We may share your Personal Data with government and law enforcement officials or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Platform and any equipment used to make our Platform available or to comply with applicable laws.
THIRD PARTY INFORMATION COLLECTION
Based on the nature of our Platform, third parties may collect information from or about you through or in connection with our Platform. In addition to other information provided in this Policy, including, without limitation, the section titled “How We Collect Usage Information” the categories of third parties that may collect information about you through or in connection with our Platform include:
- Third parties whose content is linked to on our Platform. Any links to other websites, applications or other third party content on our Platform, are not an endorsement, authorization, or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications, or content you access.
- Other users of our Platform. Depending on how you interact with our Platform, other users may collect information about you that is published or otherwise generally made available on our Platform. All users of our Platform are subject to our Terms of Service which are available at https://www.huntclub.com/terms. While we place restrictions on what our users are allowed to do with information made available to them on our Platform, we are not responsible for any misuse of any information, including your Personal Data, by any user. If you believe that another user has misused your Personal Data or any other information available on our Platform, please contact us at email@example.com.
MANAGING YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data.
- To update or correct any Personal Data you have provided us, update your preferences, or otherwise contact us about our use of your Personal Data, please email us at firstname.lastname@example.org.
- For marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your interactions with our Platform.
- You may review or modify much of the Personal Data you provide to use through the Platform at any time by logging into your account and using the Platform’s account editing functions. Please note that information you remove through such means may still remain in backup copies for a reasonable period of time.
- To request deletion of your Personal Data, please submit a request to us by emailing us at email@example.com. Only you, or a party that you authorize to contact us on your behalf, may make a request related to the deletion of your Personal Data. You may also make a request on behalf of your minor child. Your request for deletion must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or delete your Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.
Making a request does not require you to create an account with us and we will only use Personal Data provided in connection with a request for deletion to verify the requestor’s identity or authority to make the request.
We endeavor to respond to deletion requests within a reasonable time period after we receive a deletion request. If we are unable to fully comply with your request to delete your applicable Personal Data, our response will explain the reasons why we are unable to fully fulfill your request.
If we determine that the request warrants a fee, as allowable under applicable law, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
PROTECTING YOUR PERSONAL DATA
We are committed to protecting the security of your Personal Data. We use commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the transmission of information via the internet and mobile platforms. Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose online and you do so at your own risk.
If you become aware of any breach of Platform security or this Policy, please notify us immediately. To further protect yourself, you should safeguard your account user name and password and not share the information with anyone. You should also sign off your account and close your browser window when you have finished your visit to our Platform. Note that we will never ask you for your Hunt Club user name and password over email.
RETENTION OF PERSONAL DATA
We reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Data; and (2) comply with applicable law.
We do not direct or target any piece of our Platform to children under the age of 18. If we learn that we have collected the Personal Data of anyone under the age of 18, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 18 and discover that your child has submitted Personal Data to us, please contact us at firstname.lastname@example.org. We will make reasonable efforts to remove such information from our databases.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Data to third parties for direct marketing purposes: (1) the categories of Personal Data we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Hunt Club Inc.
Re: CA Privacy Rights Request
33 N. Dearborn St., 2nd Floor
Chicago, IL 60602
EUROPEAN USERS’ RIGHTS
If you are located in the EU or Switzerland, you have certain rights with respect to your Personal Data. Following is a summary of those rights and additional information applicable to our collection and use of your Personal Data.
When you provide us with your Personal Data through the Platform, we serve as a data controller. When we act as a data controller we determine how your Personal Data will be utilized, in accordance with this Policy.
Legal Basis for Processing Personal Data
If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Data. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide you with our Services;
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims; and
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our Platform and Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information concerning the legal bases on which we collect and use your Personal Data, please contact us by emailing email@example.com.
Rights Under the General Data Protection Regulation
If you are located in the EU or Switzerland, you have the following rights in respect of your Personal Data that we hold:
- Right of access. The right to obtain access to your Personal Data.
- Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that Personal Data is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of that Personal Data.
- Right to portability. The right to portability allows you to move, copy or transfer Personal Data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please email us at firstname.lastname@example.org. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Retention of Personal Data
When reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Data; and (2) comply with applicable law.
Transfers of Personal Data
If you are located in the EU, the personal information we collect may be stored and processed in any country in which we or our affiliates, suppliers, third party electronic payment processors and/or financial institutions or agents maintain facilities, including, but not limited to, the United States of America. YOU CONSENT TO ANY AND ALL PERSONAL INFORMATION YOU PROVIDE AND SUBMIT VIA THE Platform AND SERVICES BEING SENT TO THE UNITED STATES OF AMERICA. The United States of America has not sought nor received a finding of “adequacy” from the EU under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR. YOU ARE ALSO INFORMED THAT THE UNITED STATES OF AMERICA PRESENTLY DOES NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION’S ADEQUACY DECISION ON OCTOBER 6, 2015 (CASE C-362/14) AND ARTICULATED IN THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION AND HAS NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA PROTECTION AUTHORITY. YOU AGREE TO THE TRANSFER OF YOUR DATA AND PERSONAL INFORMATION TO THE UNITED STATES OF AMERICA, HOWEVER, TO BE USED IN ACCORDANCE WITH THIS POLICY.
Obligations to Data Protection Authorities (DPAs)
We will respond diligently and appropriately to requests from DPAs about this policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Data, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
Personal Data collected in connection with the use and operation of our Platform is stored and processed in the United States. If you access, use or otherwise interact with our Platform or otherwise engage with us from outside the United States, please be advised that your personal information may be initially collected by servers located in the United States or, if initially collected outside the United States, transferred to the United States. Please note, the United States has not been assessed as having adequate privacy laws by some countries and economic regions.
CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the Services we provide are continually evolving, this Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will make it known on our Platform or by email and will indicate the last date it was updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Platform after any changes to this Policy become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Policy.
If you have any questions, concerns, complaints or suggestions regarding our Policy or otherwise need to contact us, please, email us at email@example.com.