pymetrics privacy policy 

Last updated: December 18, 2019

1. Introduction

pymetrics, Inc. (“pymetrics”, “we”, “our”, or “us”) values the trust our users (“you”) place in us when they give us access to their personally-identifiable information (“Personal Information”). This Privacy Policy (“Policy”) describes how we work to maintain that trust.

pymetrics has created this Policy in order to outline our collection, use, and sharing of information you provide to us when you access or use pymetrics’ online and/or mobile services and websites (collectively, the “Site”), including, without limitation, pymetrics.com, any pymetrics mobile application, and any software provided by pymetrics in connection with such services or websites.

Please note that we reserve the right to review and update this Privacy Policy from time to time. Accordingly, each time you access or use the Site, you should check the Last Updated legend at the top of this Policy and review any changes since you last accessed or used the Site. If you access or use the Site after an updated Privacy Policy is published, you will be deemed to have agreed to the amended Policy.

TO THE EXTENT PERMITTED BY APPLICABLE LAWS, BY ACCESSING AND USING THIS SITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THIS SITE.

2. 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:

  1. First and last name
  2. E-mail address
  3. Educational history
  4. Current occupation and title
  5. Employment history
  6. Accessibility Accommodations

You may also be asked to provide your demographic information. However, providing such information will always be voluntary. 

We may supplement the Personal Information you provide with additional Personal Information we gather from public sources or from third-parties (e.g., consumer reporting agencies) that may lawfully provide such information to us.

You are under no obligation to provide your Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the Site’s features and services for which your information is required.

Data submitted by Your use of Our Site

When you play our online games (the “Games”) on the Site, we also collect and retain your “Gameplay Data,” which is defined as information and data collected from your behavior and actions  in the  course of  playing our  Games, including  metadata about  your real-time  user interaction with the Games. After your completion of the Games, the Site will review your Gameplay Data and generate your specific “Trait Profile,” which contains the Site’s assessment and description of your cognitive, social, and personality traits.

When you record and submit videos (“Videos”) on the Site, we may also collect and retain images, video, voice and audio information and a transcript of your audio information in the Video.

Information Provided When You Contact Us

We may collect Personal Information that you voluntarily provide to us when you contact us with a question, comment, business inquiry, or other request for information. We collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our products and services:

  1. Name
  2. E-mail address
  3. 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.

We may collect application log information like the companies you submit a job application for through the Site, the specific role(s) you  apply for, and the time and date of such applications.
We also use cookies on our Sites; for more information, please see the Cookies and Other Tracking Technologies section below.

We may collect certain additional information when you access our Site with a mobile device or with pymetrics IOS and Android mobile apps. This information may include location, device type, unique device identifier, operation system, and other app-specific user data. This data is analyzed to help us create a more user-friendly mobile experience. You may restrict collection of certain data, like location by changing the setting preferences on your mobile device.

3. Cookies and other tracking
    technologies that we use

We and our service providers use cookies, beacons, embedded scripts, and local shared objects in connection with the Site.

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.

We use cookies to remember users’ settings, market products and services to users, and for authentication purposes. To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept, or delete cookies from our Site at any time. The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies; how to have the browser notify you when you receive a new cookie; or how to disable cookies altogether. Please note that if cookies are disabled or removed, not all features of our Site will operate as intended.

Third-Party Analytics. We may also use service providers, such as Google Analytics, that may use cookies or other technologies to collect information about your online activities across this and other sites over time for non-advertising purposes such as those described above. To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/.

4. What we do with the information we collect

Lawful Basis for Processing Your Information. If we act as a controller, our lawful basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the specific context in which we collect or use it. We normally collect or use information from you or others only where we have your consent to do so, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the contact details provided in Section 8 of this Privacy Policy.

5. What we do with 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  use  and/or  transfer  aggregated  de-identified  data derived  from  Personal  Information, for lawful purposes in our discretion. Note that we do not share Personal Information with third parties for their direct marketing or revenue generating purposes.

Non-US Residents – International Transfers of Personal Information. If you are located outside of the United States, the Personal Information that we collect from you may be transferred to, and stored at, a destination internationally (for example, outside the European Economic Area (“EEA”) in reliance on a variety of compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses). It may also be processed by staff operating internationally (for example, outside the EEA who work for us or for one of our suppliers). The country in which your Personal Information may be transferred to and processed in may have data protection laws that are different to the laws of your country (and in some cases, may not be as protective). By submitting your Personal Information on the Site, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. For more information on where we store Personal Information and on our security, please see the “Security” section in Section 8 of this Policy below.

6. EU-U.S. and Swiss-U.S. privacy shield notice

Effective: October 19, 2018

pymetrics participates in and has certified our compliance with the EU-US Privacy Shield and the Swiss-US Privacy Shield frameworks regarding the collection, use, and onward transfer of Personal Information that we collect and process from the EEA, United Kingdom, and Switzerland. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement for Personal Information that we receive from companies or individuals in the EEA, United Kingdom, and Switzerland. Our Privacy Shield certification will be available here. We also receive some data in reliance on other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn  more  about  the  Privacy  Shield  Framework,  visit  the  US  Department  of Commerce’s website (www.privacyshield.gov).

7. Your choices regarding your information

Choice

You are not required to create an Account to gain access to many services and features of the Site. If you use the Site’s personalized services and features (e.g., the Games and Trait Profile), you will  need to create an Account and enter Personal Information, which we will treat as described in this Privacy Policy.

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 the “Email Settings” tab of your Account profile 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 under the Account Settings tab of your Account profile. You may also email us at privacy@pymetrics.com with information necessary for us to process your request. We will respond to your request within a reasonable timeframe. We may need to verify your identity before granting access to Personal Information in our custody or control.

A note about our Games specifically: Because some of our Games are designed to test memory and instinctive behavior (which can be skewed through subsequent gameplay), once you start or complete the Games, your Gameplay Data and Trait Profile cannot be reset, amended, deleted or overridden for a period of three hundred and thirty (330) days after you have completed the Games.

Deactivating Your Account

You may deactivate your Account using the Deactivate Account button under the Account Settings tab on your Account profile. When you deactivate your Account, you will no longer be able to log into the Account. You will also no longer be able to create any new Accounts with the email address associated with the deactivated Account. If you wish to reactivate your deactivated Account, please email us at privacy@pymetrics.com with the email address.
 
A deactivated Account does not mean that all of the information associated with your Account is expunged from our systems, although such information will now no longer be readily available to you

Deleting Your Information

You may request to delete your Personal Information by emailing us at privacy@pymetrics.com with information necessary for us to process your request. Note that any deletion request will be subject to our Retention Policy below.
 
A note about our Games specifically: Because some of our Games are designed to test memory and instinctive behavior (which can be skewed through subsequent gameplay), once you start or complete the Games, your Gameplay Data and Trait Profile cannot be reset, amended, deleted or overridden for a period of  three hundred and thirty (330) days after you have completed the Games.

GDPR Rights

The underlying rationale of the GDPR is to empower you (Data Subjects) to control how your personal data is processed. We have a responsibility to protect your individual privacy and autonomy, and to comply with the requirements of the GDPR. More importantly, we genuinely believe the world will be a better place if you are empowered to control the use of your own data. We at pymetrics have invested heavily in enabling you to exercise your rights under the GDPR to the maximum extent possible.

Contact Details for Redress:
pymetrics, Inc
102 Madison Ave 5th Floor
New York, NY 10016
privacy@pymetrics.com

You have the following rights under GDPR:

i. Right to be Informed. You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR. How we help: The privacy policy is designed to inform you about how your information is processed, as well as what your rights are.

ii. Right of Access. You have the right to access your personal data and supplementary information to be aware of and verify the lawfulness of processing. How we help: After signing in, we allow you to access your personal data in JSON format, along with supplementary information in your privacy settings.

iii. Right to Rectification. You have the right to have personal data rectified if it is inaccurate or incomplete. How we help: After signing in, we allow you to edit your personal data via your profile page.

iv. Right to Erasure. You have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. How we help: After signing in, we allow you to request that your account be restricted. Your data will be removed from pymetrics and placed in restricted archival storage for 2 years before being deleted to comply with relevant laws governing employment records retention.

v. Right to Restrict Processing. You have the right to 'block' or suppress processing of your personal data. How we help: After signing in, we allow you to request that your account be restricted. Your data will be removed from pymetrics and placed in restricted archival storage for 2 years before being deleted to comply with relevant laws governing employment records retention.

vi. Right to Data Portability. You have the right to obtain and reuse your personal data for your own purposes across different services. How we help: After signing in, we allow you to export your personal data in JSON format in your privacy settings.

vii. Right to Object. You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing (including profiling), and processing for purposes of scientific/historical research  and statistics. How we help: We allow you to object to processing by changing your email settings, by exercising your right to restrict processing, or by contacting privacy@pymetrics.com.

viii. Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects. How we help: The data we collect is not necessarily used in automatic decision making. In case our client uses automated decision making, you may require human intervention. Please contact the Controller who invited you to complete an Assessment.

Our Retention Policy

We retain Personal Information from you with your consent, or where we have an ongoing legitimate business need (for example, to provide you with a service or other information you have requested or to comply with applicable legal requirements). When we have no on-going legitimate business need to process your Personal Information, we will either delete, de-identify or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. The following are examples of how long we typically retain your Personal Information for legitimate business needs:

When You Interact with Sales, Marketing, and Customer Support: We may retain your Personal Information as long as necessary to provide you with your request for information or other responses. 

When You Sign Up for an Account: We may retain your information for as long as your Account is active or as long as necessary to provide you with our services, comply with our legal obligations, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our Terms of Service).

In accordance with our obligations and requirements under local law, we must retain your information for a period of two (2) years following the date of your last recorded assessment for a particular role (“Assessment”). As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the 2-year period has passed, after which we will process your deletion request. If you do not have any recorded assessments for a role during the last two (2) years, then we will process your request within ten (10) business days of receipt.

Even if we are obligated to retain certain information, once you delete your Account or request deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site, regardless of whether you selected Public or Limited (if available to you) through the Privacy Settings tab of your Account profile.   

As discussed above, we may aggregate or de-identify our user’s Personal Information and other information; such data cannot be used to identify you. We will retain such data even after any Personal Information deletion requests have been processed.

When We Process Your  Personal Information on Behalf of Our Customers: Weretain your Personal Information in accordance with the timeframes set out in the relevant customer agreements between us and the applicable customer(s).

7. Miscellaneous

Other Websites. Our Site may contain links to third-party owned and/or operated websites or mobile applications. We do not own nor control these third-party websites or mobile applications, and accordingly assume no responsibility for the information practices of those sites  or apps. We suggest that you review their privacy, security, and data collection and distribution policies, if any, prior to providing such websites or apps with any information.

Blogs and Public Features of the Sites. Our Site may contain features, e.g. job boards, forums, sharing functions, etc., that permit you to upload, post, transmit, display, perform, or distribute content and information, including your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.

Single Sign-On. You can create an Account using third-party sign-in services such as Facebook or LinkedIn. This service will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form. Please note that your relationship with Facebook, LinkedIn, or any other third-party website is governed solely by your agreement with such third-party website.

Security. The security of your Personal Information is important to us. We take commercially reasonable  steps  to help  protect  your Personal  Information  from  loss, misuse, unauthorized access, disclosure, alteration, and destruction. For example, we use one or more of secure socket layer (SSL) encryption, firewalls, and self-updating anti-virus software. Your Personal Information will be stored in the United States and will be subject to laws applicable in that country. While we take all steps we consider appropriate to protect your data, including technical and organization  measures  to  ensure  that  your  Personal  Information  is  handled  securely  i accordance with this Privacy Policy; unfortunately, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. Please create a unique password for your Account and do not share your password with anyone else.

Minors. Visitors under eighteen (18) years of age are not permitted to use and/or submit their Personal Information at the Site. We do not knowingly solicit or collect information from visitors under eighteen (18) years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Contacting Us. The Contact Us link on the Site contains an e-mail link that allow you to contact us  directly with  any questions  or comments  that you may  have. If you have any questions about  this Privacy  Policy  or our  privacy  practices, please  feel free to  contact  us at privacy@pymetrics.com or at:

ATTN: Data Protection Officer
Pymetrics, Inc.
102 Madison Avenue, 5th Floor
New York, NY 10016
United States of America

Annex–Information for citizens of the US State of California under the California Consumer Privacy Act (“CCPA”)

Consumers residing in California have some  additional rights with respect  to their personal information under the California Consumer Privacy Act or (“CCPA”). If you are a California resident, this section applies to you and supplements the main privacy policy above.

1. Categories of Personal Information Collected. In the preceding 12 months, we have collected the categories of personal information listed under Section 2. “INFORMATION THAT WE COLLECT ABOUT YOU”  above.

2. Your Rights. Under the California Consumer Privacy Act of 2018 ("the CCPA"), if you are a California consumer, you have the right to know and see what personal information we have collected about you over the past 12 months, including: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting your personal information; the categories of third parties with whom we have shared your personal information; and the specific pieces of personal information we have collected about you. You also have the right to request deletion of your personal information (subject to certain exceptions), to opt out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of their other CCPA rights.

California consumers may make a rights request by sending a request via email to privacy@pymetrics.com. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address and name. We will not discriminate against you if you choose to exercise your rights under the CCPA. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

3. Sale of Personal Information. We do not sell your personal data to third parties.

4. Further disclosures. For further disclosures regarding your personal information, as required by the CCPA, please refer to the main privacy policy above. You can find information about the business and commercial purposes for which we collect your personal information in Section 4. “WHAT WE DO WITH THE INFORMATION  WE COLLECT”. Section  5 “WITH WHOM WE SHARE THE INFORMATION WE COLLECT” provides information about the categories of third parties to whom we disclose your personal information to, as well as information regarding which categories of personal information are being disclosed.