1. Introduction
This website (“Site”) is owned and operated by Positive Circularity Inc. We are committed to your data privacy. This Privacy Policy details the information we collect about you and how we use it, outlines the steps we take to protect the information you entrust to us, and describes your choices with respect to your information. By registering on this Site, submitting any information on our Site, or by otherwise accessing or using any of our services, you agree to the terms of this Privacy Policy and consent to the policies and practices described here.
2. What Information We Collect
We collect certain information from you in order to pursue our lawful business interests, including providing you with access to our services, improving your experience, communicate with you in connection with or regarding our services, and to enhance and improve our website and operations based on insights we are able to obtain from your information, such as whether a given Site layout is convenient and accessible.We collect only the information necessary to fulfil our lawful business interests and keep your information for only as long as is necessary to fulfil those interests. If you choose not to provide information, we may not be able to provide you with requested services, or information.We may combine your information with publicly available information and information we receive from or cross-reference with select partners and others. By combining this information, we are better able to communicate with you about our services and promotions and to personalize your user experience; the broader understanding we gain from combining information enables us to more effectively deliver opportunities that lead to user satisfaction, such as relevant communications, tailored suggestions, and special offers.
Information Establishing Your Identity
In order to effectively deliver our services, it is vital that we accurately establish the specific identity of the person who is registering on our Site. In other words, we need to take steps to verify that you are who you say you are, and to be able to distinguish you from other people. We collect certain personal information in order to assist us in establishing your identity, including:
Information to Authenticate Your Identity.
Once you have registered as a user, we need to ensure there are measures in place to authenticate your identity when you attempt to access the account you have created. To enable our authentication system to verify that the person attempting to access your account is you, we collect certain information including:Knowledge-based information:
Information You Provide in Connection with an Employment Application
If you apply for a job or contract position with us, we collect certain information from you as part of the employment application process. This information is collected to determine your eligibility and suitability for the position for which you are applying, and to expedite the onboarding process if we move forward with your candidacy.
The information we collect includes:
Information Collected in the Course of Using Our Services
Your use of our services may cause us to generate or collect certain information in order to facilitate providing those services and enabling them to be useful, including:
3. How We Use Your Information
We may use the information we collect from you in the following ways:
Delivering Services, Including:
Sending you an invitation to use our services (for example, when your employer or potential employer invites you to use our services, we may send you an invitation)To provide you with customer or technical support (e.g. by contacting you via email address)To facilitate social interactions between you and other users of our services (such as employers)To notify you of future changes and improvements to our servicesTo provide you with access to the functionality and features of our services (e.g. in order for you to create or update your CV, to request shifts, to find employers or employees)To manage our relationship with you and to manage the payment and recovery of amounts payable to us by you.
Business and Internal Operations Purposes, Including:
To analyze data to ensure appropriate service levels are being achievedTo enable us to operate, maintain and improve the functionality and features of our servicesIf you have opted-in to receive advertising or coupons through the LIFELENZ app, to enable third parties to provide you with advertising or coupons in relation to offers for goods or servicesTo provide you with other direct marketing communications regarding offers of goods and/or services which may be relevant to youTo enable us to conduct our business generally, such as notifying our insurers, quality assurance, internal teaching and data processing and handling and in connection with any potential sale of our business and for other purposes which are reasonably necessary in connection with our normal functions and activities.
For our internal management purposesOur Employment/Contract Application Process, Including:
To assess and determine your eligibility or suitability for a job or contract with us
To, with your permission, contact professional or other reference(s) you have provided in connection with a job application to discuss your experience/employment.
4. How We Share Your InformationWe may share your information in certain circumstances, including:
Affiliated Companies
We may share your information with our affiliated companies to fulfill the purposes described in this Privacy Policy, including for data processing, marketing, and administrative purposes.
Vendors and Other Third Parties
We may authorize vendors and other third-party companies to provide certain services. We provide these companies with only the information they need to perform their services and work closely with them to ensure that your privacy is respected and protected. These companies are prohibited by contract from using this information for their own marketing purposes or from sharing this information with anyone other than us.
The services provided include:
Information Technology (providers are located in the United States, Canada, Australia)
Hosting and operation of the Site and other platformsProcessing transactions and paymentsDigital marketing and advertising
Marketing, Advertising and Customer Service (providers are located in the United States and Canada.)
Marketing or promotional assistance
Advertising, such as:
In Connection With Your Application for a Job or Contract With Us
Disclosure to any professional or personal reference(s) you provide in connection with your job or contract application to the extent necessary for us to consider your application.
Social Sharing, Including:
Legal or Business Requirements, Including:
Shared by You, Including:
Posting to the Site or other public forums, such as social media pages
Information you disclose through these services will become public
At Your Discretion, Including:
5. Automated Information Collection
We may collect information about you using automated information collection technologies. Such information may include browser and device information, demographic information and other information provided by you, and aggregated information where we combine your information with the information obtained from other users and other sources. We may use and disclose such information for any lawful purpose.
Cookies and Other Tracking Technology
We and our service providers use cookies and other related technologies to receive and store certain types of information whenever you interact with us or use our services through your computer or mobile device.
“Cookies” are small pieces of information, which typically include an anonymous unique identifier, that are sent to your browser and stored on your hard drive or in device memory when you view a webpage, an advertisement, a video or other types of content.
We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website.
Cookie information includes, but is not limited to, (a) the pages you visit on our site or mobile application, (b) the web addresses you use, (c) the type of browser, devices, or hardware you are using, (d) search terms you use, and (e) IP address-based geographic location.
Cookies help us (a) recognize you and authenticate your access, (b) streamline your use of our services by remembering certain details, (c) customize your website experience, and (d) make our marketing messages and other communications more relevant.You may be able to control or customize the use of cookies on your browser and devices. For instance, the help function of your browser should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued or to not receive cookies at any time.
If you choose to disable cookies on your browser or device, we may not be able to provide you with certain personalized services, and therefore, you may not be able to take full advantage of all of our features. Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit to disable the tracking of an individual user. There is no industry consensus as to what “Do Not Track” means in this context. Similar to many other providers, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.
Our partners, affiliates and other service providers may use Cookies and other technologies to improve the quality of your experience when you interact with our website and services and to deliver or target advertising to you. We may receive reports based on the use of certain technologies by these companies on an individual and aggregated basis.We may also use cookies, clear gifs and other technologies in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
We use local shared objects, also known as Flash cookies, when we provide you with video content. Third Parties, with whom we partner to provide these features on our website, use Flash cookies to collect and store information.
Device Information
Depending on your device settings and permissions and how you use our services, we may collect information from each device you use to access our services, such as:
Mobile
If you use a mobile device, your device may share location information (when you enable location services) with our websites, mobile applications, services, or our service providers. We may also track and collect usage data, such as the date and time you use a mobile application to access our servers and the specific information accessed, based on your device number or other identifier. We use this information to improve our services, and provide you more relevant and personalized advertisements, services, and promotions.
Aggregated Information
We may collect and use aggregated personal information, which does not personally identify you. For example, we may calculate the percentage of our site users who have a particular area code. In the course of aggregating data, we may combine third party data with yours and that of other users.
6. Cross-Device Identification
If you use multiple devices to access the Site, we may acquire and utilize capabilities that link your various devices so that content you access on one device can result in relevant advertising on another device. Information we have collected from your different devices may be combined with other information you have provided us. We may use such information to help provide more tailored experiences and consistent services across all of your devices. We also may use this information to help identify when your account is accessed from an unfamiliar device.
7. Behavioral/Targeted Advertising
We use cookies to help determine which of our ads are shown to you on websites.
To opt out of this targeted online advertising that utilizes our cookies, please click here privacy@lifelenz.com to email us so we can remove you from the list. We also work with third-party companies that use their tracking technologies (including cookies and pixel tags) on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet (this type of advertising is called “interest-based advertising”).
Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising. These companies may collect information over time about your activity on our sites and other sites and your interaction with our advertising and other communications and use this information to determine which ads you see on third-party websites and applications. These technologies and the information collected about you may also be used to track your activity across multiple devices.
For more information about this practice and to understand your options including how to opt out of receiving these tailored advertisements, please click here privacy@lifelenz.com to email us with any questions regarding your privacy and other concerns with your online experience.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
We work with Google AdWords and other advertising networks.
To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance.Please note that even if you opt-out, these tracking technologies may still collect data and you will still see ads, but they will not be targeted based upon the information collected through these tracking technologies.
Promotional and Marketing Communications
We may send you email marketing communications about our products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law.You may opt out of receiving promotional communications from us at any time by: (i) logging into your online account and updating your preferences; (ii) contacting us by phone, email or postal mail, or (iii) following the removal instructions in the communication that you receive.
8. International Transfer of Information
If you are located outside of the United States, please take note that information we collect from you may be transferred to other jurisdictions, where the applicable privacy protections may not be as comprehensive as those of your country of residence or citizenship, in order to fulfill the business purposes set forth in this Privacy Policy. By providing us with any information, you consent to your information being transferred to and processed in other countries whose privacy protections may be less comprehensive. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your information.If you are located in the European Economic Area (“EEA”) or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your information to the US. LifeLenz adheres to the Privacy Shield Principles. In addition, we have implemented intra-group data transfer agreements, which you may view upon request.Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.
9. California Residents – Your California Privacy Rights
Pursuant to California Civil Code Section 1798.83, California residents who provide us with Personal Information in using the Services are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. Alternatively, the law provides that a company may comply, as LifeLenz does, by disclosing in its privacy statement that it provides consumers choice (opt-in or opt-out) regarding sharing Personal Information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated above in this Privacy Statement, LifeLenz provides you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time LifeLenz offers that choice, LifeLenz does not share your information with that identified third party for its direct marketing purposes.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: privacy@lifelenz.com or write to us at the following mailing address:
Email Adress: privacy@lifelenz.com
Adress:Level 10, 315 Montgomery St, San Francisco, CA94104
You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your email address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
10. Security and Retention of Your Information
We maintain physical, electronic, contractual, and administrative safeguards to protect your personal information. When we collect or transmit sensitive information such as a credit or debit card number, we use industry standard methods to protect that information. You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse. Unfortunately, no data transmission or storage system can be 100% guaranteed to be secure. If you have reason to believe that your information is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at privacy@lifelenz.com.We retain your information for as long as we are providing the Services to you. However, we are obligated to retain your information after we cease providing Services to you, to the extent necessary to comply with our legal obligations. We may also retain your information to comply with our tax, accounting, and financial reporting obligations. Where we retain data, we do so only in accordance with the limitation periods and records retention obligations that are imposed by applicable law.
11. Access and Update Your Information
Under the New Zealand Privacy Act 1993, you have rights of access to and correction of your personal information. In order to keep your personal information accurate and complete, you can access or update some of it in the following ways:
12. Children’s Personal Information
Our Site is not directed toward children under the age of 13. Furthermore, we do not knowingly collect any personal data from children under the age of 13. No one under the age of 13 should provide any personal data on our Site. If a child under the age of 13 has provided us with personal information online, we ask that a parent or guardian email privacy@lifelenz.com.
13. Updates to Privacy Policy
As we continue to offer you new and different types of content and services, we may modify our information collection, use, or disclosure practices. Should there be a material change to our information collection, use or disclosure practices, it will be applied only to information collected on a going forward basis, and we will update this privacy policy statement and notify you of the changes well in advance of their taking effect.
14. Data Controller and Contact Information
The data controller is Positive Circularity Inc, a Company organized and existing under the laws of Delaware US located at Level 10, 315 Montgomery St, San Francisco, CA 94104.If you have any questions or concerns about privacy-related issues, you may contact our Data Protection Officer:Stephen Kirkby, Level 10, 315 Montgomery St, San Francisco, CA 94104, privacyt@lifelenz.com, ph +1 415-829-4216.
15. Your Choices
Where the processing of your information is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your information on grounds relating to your particular situation.If You would like to review, correct, or update information that You have previously disclosed to us, You may do so by signing in to your account or by contacting privacy@lifelenz.com.In order to exercise your data protection rights, you may contact privacy@lifelenz.com. We will comply with your request to the extent required by applicable law. However, if we no longer hold your information, we will not be able to provide it to you. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.
16. Your Rights Under EU General Data Protection Regulation
If you are located in the EU, you have the following rights with respect to your personal data. You may contact us at privacy@lifelenz.com if you wish to exercise any of these rights:
17. Links To Other Websites
The Services may provide the ability to connect to other websites. We strongly suggest you review these websites’ own privacy notices or policies. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.