Privacy Policy

Effective Date: July 25, 2024

At Jobble, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Jobble’s Services is at all times subject to our Terms of Service , which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Categories of Personal Data We Collect

The chart in this section details the categories of Personal Data that we collect and have collected over the past 12 months:

Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• “You”
  • When you provide such information directly to us.
  • When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled “Information Collected Automatically” below).
•  “Third Parties”
  • Third parties that provide us with Personal Data about you. Third Parties that share your Personal Data with us include:
    • Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.

Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.For more information about our use of cookies, please see our Cookie Policy.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:

• To meet or fulfill the reason you provided the information to us.
• To communicate with you about the Services, including Service announcements, updates or offers.
• To provide support and assistance for the Services.
• To create and manage your Account or other user profiles.
• To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services.
• To process orders or other transactions.
• To respond to user inquiries and fulfill user requests.
• To improve and develop the Services, including testing, research, analysis and product development.
• To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Privacy Rights Act (the “CPRA”).

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at legal@jobble.com.

How We Share Your Personal Data

Categories of Third Parties with Whom We Share Personal Data 

We disclose your Personal Data as indicated in the chart above to the following categories of service providers and other parties:

• “Service Providers”
  • These are third parties that help us provide our Services, including payment processors, ad networks, security and fraud prevention providers,  hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel.
•  “Acquirors”
  • These are parties who acquire your Personal Data through an acquisition or other change of control. Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
• “Data Brokers”
  • These may be ad networks or other organizations that primarily buy and sell data.
• “Selected Recipients”
  • These are third parties that we share your Personal Data with at your direction, including:
    • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
    • Social media services (if you intentionally interact with them through your use of the Services).
    • Third-party business partners who you access through the Services.
    • Other parties authorized by you

Disclosures of Personal Data for a Business Purpose

We disclose your Personal Data to service providers and other parties for the following business purposes:

• Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture (or that was manufactured for us) or control.

We disclose your Personal Data to the following categories of service providers and other parties:

• Service providers, including:
  • Ad networks.
  • Security and fraud prevention consultants.
  • Hosting and other technology and communications providers.
  • Analytics providers.
  • Staff augmentation and contract personnel.
• Parties who acquire your Personal Data through an acquisition or other change of control.
  • Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
• Other parties at your direction.
  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
  • Social media services (if you intentionally interact with them through your use of the Services).
  • Third-party business partners who you access through the Services.
  • Other parties authorized by you.
• If you use the Jobble for indi account, data we receive from indi may be used by Jobble to make payments to you using your indi account number or to improve the services we market to you. This data will not be shared or sold to any third party, except the routing and account number associated with your indi account may be shared with third parties only if needed to process payments from Jobble to your indi account.

Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed above:

• A. Personal identifiers.
• B. Customer records identified by state law.
• C. Protected classification characteristics under state or federal law.
• D. Commercial information.
• E. Biometric information.
• F. Internet or other similar network activity information.
• G. Geolocation data.
• H. Sensory data.
• I. Professional or employment-related information.
• J. Non-public education information.
• K. Inferences drawn from other personal information.
• L. Age or date of birth.
• M. Special categories of data under the EU General Data Protection Regulation.
• N. Personal Data about children under the age of 16.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Deletion of Personal Data

Users have the right to request the deletion of their Personal Data, including contact information such as phone numbers, email addresses, and other identifying information. To make such a request, you can:

1. Submit a Privacy Inquiry: Visit https://jobble.com/submit-a-privacy-inquiry/ and fill out your personal information including name, phone number, and the email associated with your account. Then select “Delete personal data” from the dropdown menu under “Nature of your request.”
2. Email: Send an email to legal@jobble.com with the subject line “Data Deletion Request”
3. Mail: You can also send a written request to:

   Jobble Inc.
   P.O. Box 121254
   Boston, MA 02112-1254

Upon receiving your request, we will confirm the deletion of your data within a reasonable timeframe, usually within 30 days, unless a legal obligation requires retention. Please note that certain data may be retained as required by law or for legitimate business purposes, such as completing transactions you initiated or other actions you have requested, or if deleting your Personal Data involves disproportionate effort.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at legal@jobble.com.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at legal@jobble.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

To request the deletion of your Personal Data, please submit a privacy inquiry here: https://jobble.com/submit-a-privacy-inquiry/

Under “Nature of your request” select “Delete personal data” from the drop down menu.

Users may request deletion of their accounts at any time. Jobble may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Processing of Sensitive Personal Information Opt-Out

We collect Personal Data that is considered Sensitive Personal Information” under the CPRA. Because we use or disclose Sensitive Personal Information for purposes other than those set forth in section 7027(m) of the CPRA regulations, California residents have the right to request that we limit the use or sharing of their Sensitive Personal Information (“Right to Limit”). The Right to Limit allows California residents to direct a business that collects Sensitive Personal Information to limit its use of this information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, to perform the services set forth in paragraphs (2), (4), (5), and (8) of subdivision (e) of Section 1798.140, and as authorized in the CPRA regulations. You may exercise your Right to Limit by using the following methods:

• You can complete the online form found here; or
• Email us at legal@jobble.com

Sales of Personal Data Opt-Out and Opt-In

In this section, we use the term ‘sell’ as it is defined in the CPRA. We sell your Personal Data, subject to your right to opt-out of these sales (see the “Your Rights” section below for information about how to opt-out).

As described in the “Information Collected Automatically” and “Information about Interest-Based Advertisements” sections above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPRA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt-out of data selling and/or sharing by following the instructions in the “Exercising Your Rights under CPRA and VCDPA” section below.

We sell your Personal Data to the following categories of third parties:

• Advertisers

Over the past twelve months, we have sold the following categories of your Personal Data to third parties:

• A. Personal identifiers.
• B. Customer records identified by state law.
• C. Protected classification characteristics under state or federal law.
• D. Commercial information.
• E. Biometric information.
• F. Internet or other similar network activity information.
• G. Geolocation data.
• H. Sensory data.
• I. Professional or employment-related information.
• J. Non-public education information.
• K. Inferences drawn from other personal information.
• L. Age or date of birth.
• M. Special categories of data under the EU General Data Protection Regulation.
• N. Personal Data about children under the age of 16.

We have sold the foregoing categories of Personal Data for the following business or commercial purposes:

• Improving the Services, including testing, research, internal analytics and product
  development.
• Personalizing the Services, website content and communications based on your
  preferences.
• Doing fraud protection, security and debugging.
• Marketing and selling the Services.
• Showing you advertisements, including interest-based or online behavioral advertising.

To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

Personal Data Sharing Opt-Out and Opt-In

Under the CPRA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We have shared the following categories of Personal Data for the purposes of cross-contextual behavioral advertising.

• [List of categories of Personal Data that have been shared with third parties for cross-contextual behavioral advertising]

As described in the “Information Collected Automatically” and “Information about Interest-Based Advertisements” sections above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPRA, sharing your data through third party Cookies for online advertising may be considered a “sharing” of information. You can opt out of data selling and/or sharing by following the instructions in the “Exercising Your Rights under CPRA and VCDPA” section below.

We share Personal Data with the following categories of third parties:

• Ad Networks
• Data brokers
• Marketing providers (including for cross-contextual behavioral advertising purposes)

Over the past 12 months, we have shared the foregoing categories of Personal Data with the categories of third parties listed for the following purposes:

• Marketing and sell the Services.
• Showing you advertisements, including interest-based or online behavioral advertising

To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CPRA

We will not discriminate against you for exercising your rights under the CPRA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CPRA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CPRA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Virginia Resident Rights

If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@jobble.com.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete your Personal Data.

Opt-Out of Certain Processing Activities

• You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We process your Personal Data for targeted advertising purposes. To opt-out of our processing of Personal Data for targeted advertising purposes, please see the “Exercising Your Rights under CPRA and VCDPA” section below.
• You have the right to opt-out to the sale of your Personal Data. As discussed in the “Sales of Personal Data Opt-Out and Opt-In” and “Personal Data Sharing Opt-Out and Opt-In” under the “California Resident Rights” section, some of our data sharing relationships constitute a “sale” as defined by the Virginia Consumer Data Protection Act (“VCDPA”).
• You have the right to opt-out from the processing your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable.

Appealing a Denial

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint .

You may appeal a decision by us using the following methods:

• Email us at: legal@jobble.com (title must include “VCDPA Appeal”)

Exercising Your Rights under CPRA and VCDPA

To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt the time period
required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request by emailing us at: legal@jobble.com

If you are a California resident, You may also authorize an agent (an “Authorized
Agent”) to exercise your rights on your behalf. To do this, you must provide your
Authorized Agent with written permission to exercise your rights on your behalf, and we
may request a copy of this written permission from your Authorized Agent when they
make a request on your behalf.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at legal@jobble.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at legal@jobble.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

International Visitors

Our Services are hosted in the United States. Our Services are not intended for visitors located in the European Union or the United Kingdom and you may not access our Service if you live in the European Union or United Kingdom.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Jobble website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: legal@jobble.comw