Jurdu, Inc., d/b/a Thine (“Thine”) is committed to safeguarding your information. We understand the importance of privacy and want you to make an informed decision about sharing information with us when visiting our website and using our services. We value the trust our users place in us when they give us access to their personally-identifiable information (“Personal Information”).
1. INFORMATION THAT WE COLLECT ABOUT YOU
Information Provided by You Upon Creating an Account
When you create and register a user account (“Account”) on the Site, you may be asked to provide or confirm certain pieces of Personal Information, which may include one or more of the following:
- First and last name
- E-mail address
- Educational history
- Current occupation and title
- Employment history
- Demographic information (providing such information will always be voluntary)
We also collect data and Personal Information from you when you provide or upload it to the Services, such as when you fill out a form, submit a resume or other document, or respond to a survey or questionnaire. This can include resumes, personality and cognitive ability assessments, background information, location data, and GPAs.
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. Your information may also be required by a potential employer in order to identify your assessment results with your job application.
Information Provided By Our Customers
We may receive Personal Information about you from law firms or other legal employers with whom we contract to provide services through our Site (each, a “Customer”) if you interact with, are associated with, and/or apply for a role with any of our Customers.
Information Provided When You Contact Us
We may collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Site. We generally collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our products and services:
- E-mail address
- Phone Number
Passively Collected Information
When you access and use our Site, we may automatically collect and retain certain types of information, including your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, such as your browser type and version, time zone setting, and operating system and platform.
When you take our online assessments (the “Assessments”) on the Site, we also collect and retain your “Assessment Data”, which is defined as information and data collected from your responses, including metadata about your real-time user interaction with the Assessments. After your completion of the Assessments, the Site will review your Assessment Data and generate your specific “Trait Profile”, which includes your development report and contains the Site’s assessment and description of your personality traits. If you record and submit videos on the Site, we may also collect and retain images, video, voice and audio information and a transcript of your audio information in such videos.
We may collect application log information like the employers you submit a job application for through the Site, the role or roles you apply for, and the time and date of such applications.
We may collect certain additional information when you access our Site with a mobile device. This information may include location, device type, unique device identifier, operation system, and other related user data. This data is analyzed to help us create a more user-friendly mobile experience. You may restrict collection of certain data by changing the setting preferences on your mobile device.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE
Cookies, Beacons and Embedded Scripts
- Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Site and typically work in conjunction with cookies to assist our site with the automated collection data on user behavior. We will not be able to personally identify you in connection with these practices.
- An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
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.
3. WHAT WE DO WITH THE INFORMATION WE COLLECT
- General 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 Assessments, Trait Profile and success models. We sometimes use automated decision making in processing your information, such as to create your “Trait Profile”, which is used to help inform employers’ decisions by determining your "fit" by comparing your individual results against a benchmark profile of current employees.
- Information Provided When You Register an Account and Take Our Assessments. 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 by showing you relevant information such as your job matches and, with your consent where necessary, notify you regarding new roles on the Site, remind you to complete the Assessment or job applications, send you information about us, and keep you informed of our products and services that may be of interest to you. We may also combine such Personal Information with other Personal Information lawfully collected from third parties in order to better market and provide our products and services.
- Information Provided When You Contact Us. We may use this information to understand and respond to your question or comment, and/or reach out to you regarding your inquiry or request regarding our products and services.
- Passively-Collected Information. We use passively collected information to monitor and maintain the performance of our Sites; analyze trends, usage, and activities in connection with our services; validate users and ensure the Site’s technological compatibility with users; optimize our marketing efforts; and to provide our products and services to you, including analyzing your Assessment Data and developing your Trait Profile.
- Aggregate or De-Identified Data. We may use our users’ Personal Information and passively-collected information to create aggregate or de-identified data which cannot be used to identify you (“Aggregate Data”). For example, Aggregate Data may include data that describes the general demographics, usage, Assessment Data, or other characteristics of a Site’s users. We reserve the right to use, transfer, and/or sell Aggregate Data about the Site’s users for any lawful purposes. We also reserve the right to use such aggregate information in collaboration with outside researchers to measure, quantify and audit the effectiveness, validity and fairness of our products and services.
- Incumbent Employees. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and take the Assessment by your current employer, then we may use your information to create a talent assessment model for a specific role at your current employer. In such a scenario, you would be deemed an “Incumbent Employee”.
- Job Candidates. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and take the Assessment at the suggestion of your law school or as part of the job application process for a specific employer, or if you visited the Site, created an Account (or signed into your existing Account), and took the Assessment as part of a more generalized recruiting process, then we may use your information to assess your fit to a specific role(s) at the specific employer or across our network of employers, as applicable. In such a scenario, you would be deemed a “Job Candidate”.
- Other Purpose. We may use your information for any additional purpose which you separately authorize in the course of accessing and using our Site.
Lawful Basis for Processing Your Information
4. WITH WHOM WE SHARE THE INFORMATION WE COLLECT
Personal Information of our users is an integral part of our business. We reserve the right to share your Personal Information with third parties as described below. We also reserve the right to transfer and/or sell other types of data, including Aggregate 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 or revenue-generating purposes.
- Service Providers. We, like many businesses, sometimes hire other companies (“Service Providers”) to perform certain business-related functions. Examples include customer service, maintaining databases, data storage, cloud services, and hosting services. When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include Personal Information and other information that you provide to us via the Site. These Service Providers are authorized to use your information only as necessary to provide these services to us.
- Legal Requirements. We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of users of the Site or the public; (d) protect against legal liability; or (e) or as otherwise required or permitted by law.
- Job Candidates. If you are a Job Candidate, then we share your Personal Information and Trait Profile with employers in our network and any third party that is pertinent to their employment application process for the role for which you are applying to through our Site.
- Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, total or partial sale of assets in bankruptcy or similar event, your Personal Information and other information may be part of the transferred assets.
- Other Third Parties. We may disclose your information to other third parties with your prior express consent.
You hereby consent to our sharing of your Personal Information and other information for the above purposes.
5. YOUR CHOICES REGARDING YOUR INFORMATION
Our Opt-out Policy
We may send you notifications and communications using the email address you provided to us when you registered your Account. To stop receiving some or all email communications from us, you can use your Account settings to edit your email preferences. Alternatively, you can use the “unsubscribe” mechanism provided in the email communication.
We will also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your Account.
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 communications.
Accessing, Correcting and Updating Your Information
You may access, correct, and update most of your Personal Information by changing the settings in your Account profile. You may also email us at email@example.com with information necessary for us to process your request. We may need to verify your identity before granting access to Personal Information in our custody or control.
Updating Assessment Data
Our Assessment and Trait Profiles are designed to measure traits and motivators at a particular point in time, and suggest avenues for improvement and growth. Because these traits and motivators take some period of time to change, and because taking multiple Assessments for the same role in a short period of time decreases the reliability of the Trait Profile, Assessments cannot be retaken, and Assessment Data will not be updated, for a period of two years from the date of completion.
Deactivating Your Account
You may deactivate your Account by sending a deactivation request through your Account profile. You may also deactivate your Account by emailing us at firstname.lastname@example.org with information necessary for us to process your request.
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 no longer be readily available to you.
Deleting Your Information
You may request that we delete your Personal Information by sending a deletion request through your Account profile. You may also request deletion of 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.
6. OUR RETENTION POLICY
As part of our Services for our Customers, we regularly build and update predictive models which are used by Customers to evaluate the employment candidacy for a Job Candidate. Every time a model is built or updated, we must re-evaluate the employment candidacy of a Job Candidate using the new model and the information Job Candidates have provided through the site. We also rely on information collected from Incumbent Employees to build and update these predictive models. Therefore, we retain the information you provide (1) as long as you have an active account with Thine, (2) as long as necessary to provide you with our services, comply with our legal obligations, 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), (3) or with your consent.
Upon your request to delete information associated with your Account, our retention policy differs depending whether you last took the Assessment as a Job Candidate:
- If you took the Assessment as a Job Candidate: If you were directed to visit the Site, create an Account (or sign into your existing Account), and take the Assessment as part of the job application process for a specific employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of two years following the end of the hiring cycle for the role of which you took part. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the two-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this two-year anniversary, then we will process your request upon 10 business days of receipt
- If you took the Assessment as an Incumbent Employee: If you were directed to visit the Site, create an Account (or sign into your existing Account), and take the Assessment as directed by your current employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of two years following the end of the hiring cycle for the role of which you took part. As a result, if you request deletion of any information prior to this two-year anniversary, we must wait until the two-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this two-year anniversary, then we will process your request upon 10 business days of receipt.
Even if we are obligated to retain certain information, once you deactivate your Account or request to deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site.
As discussed above, we may aggregate or de-identify our user’s Personal Information and other information to create Aggregate Data which cannot be used to identify you. We will retain such Aggregate Data even after any Personal Information deletion requests have been processed.
Other Websites. Our Site may contain links to websites or mobile applications owned and/or operated by third parties. 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.
Content, Blogs and Public Features of the Sites. Our Site may contain features (e.g., content, blogs, chat rooms, community forums, sharing functions, etc.) that permit you to upload, post, transmit, display, perform, or distribute content and information, including your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.
Minors. Visitors under 18 years of age are not permitted to use and/or submit their Personal Information at the Site. We do not knowingly solicit or collect information from visitors under 18 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.