This Privacy and Security Policy is provided for the benefit of customers and clients of Illumified, Inc. (“Dubb”) as well as other consumers and parties who seek information from or about Dubb and/or its website(s), particularly dubb.com (“Website” or “dubb.com”), and/or applications (“Apps”) (collectively, “Dubb Services”).
1 OPENING STATEMENTS
1.2 Our Commitment to Privacy
At Dubb, we respect the privacy and the confidentiality of our customers’ information, particularly our customers’ PII (also commonly referred to as personally identifiable information) (“PII”). We are committed to keeping confidential the PII you share with us. This Privacy and Security Policy explains how Dubb collects, uses, discloses and protects the information we obtain.
1.3 Applicability of Privacy and Security Policy
Our Privacy and Security Policy applies to all individuals and entities from whom or for the benefit of whom we receive PII, whether it be collected through our corporate owned websites; Apps; traditional mailing and/or faxing channels; telephone or electronic communications; from some other medium; and/or from our clients.
1.4 Website and Apps Not Directed to Minors
The Website is a professional website directed toward individual job seekers, individual consultants, and consultant groups seeking employment as well as employers (either directly as customers of Dubb or through Staffing Customers that use Dubb Services) seeking to hire individual job seekers, individual consultants, or consultant groups or consultant groups for employment. As such, an individual must be aged fifteen (15) or over to create an account through the Website. As such, the Website is not directed toward children or minors. This also applies to all Dubb Apps.
1.5 U.S.-EU Safe Harbor Framework.
Dubb complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Dubb has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Dubb’s certification, please visit http://www.export.gov/safeharbor/
2 PERSONAL INFORMATION COLLECTED AND HOW IT IS USED
2.1 Personally Identifiable Information or PII is any information that would, by itself, identify you or tend to identify you as a particular individual or entity. This PII may include, but not be limited to, your name, your address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver’s license number).
2.1.1 PII does not include any public information that is readily attainable through federal, state or local public record distribution channels.
2.1.2 PII does not include any information that, by itself, could not identify you as a particular individual or entity.
2.1.3 PII also does not include raw data that becomes aggregated for statistical purposes and cannot, thereafter, be identified with you as a unique individual or entity.
2.1.4 Dubb does consider your Internet Protocol (“IP”) address to be PII and will treat it as such.
2.2 Information Collected
2.2.1 Dubb collects information that is considered PII and other information that, by itself, would not be considered personally identifiable information (“Non-PII”).
2.2.2 When you create an account and register for any of our Dubb Services (whether through a Website, App, or other portal), we collect information submitted by you including, but not limited to, your username, your full name, company name (if applicable), email address, zip code, and primary industry. We use this information to identify our customers and send notifications related to the use of our Dubb Services. We reserve the right to request additional information from you.
2.2.3 Dubb shall also collect information to one or more of your financial accounts for purposes of processing payments to provide you with Dubb Services. This information may likely contain both PII and Non-PII.
2.3 Collecting and Using Personally Identifiable Information
2.3.1 Dubb will explain how it intends to use PII either before it collects the information (such as in this Privacy and Security Policy) or contemporaneously with the solicitation of such information. Exceptions may exist where the intended use is obvious to a reasonable person.
2.3.2 Generally, Dubb collects personal identifiable information when an individual registers with or uses any of the Dubb Services. This information typically includes, at a minimum, a full name, username, company name (if applicable), physical address, email address, phone number, cell phone number, zip code, primary industry and any additional information provided by the account holder that could identify that account holder. For persons seeking employment, it should be recognized that a collection of information that would otherwise be considered non-PII could transform into PII (eg employment history, employment position at a company). Consequently, an individual account holder must be aware of making public through any of the Dubb Services information that could identify them where they seek to keep private their search for employment. The same can be said of consultants and employers in certain circumstances.
2.3.3 We will use the PII collected only for the purposes explained to you. Further, we limit the collection of PII to only that information which is necessary for the purposes explained to you.
2.3.4 Generally, we use the PII collected and/or received about you in connection with our Apps, Website, Dubb Services, and their various features. We also use information collected and/or received about you in connection with other users and advertisers that purchase ads through the Apps or on the Website.
For example, we may use the information we receive about you (a) as part of our efforts to keep Dubb safe and secure; (b) to provide you with location features and services, like telling you how far a job opening is from you or notifying you of jobs that pertain to your qualifications or keywords in your profile or if a job fair is nearby; (c) to measure or understand the effectiveness of ads you and others see; (d) to provide Dubb Services; (e) to make suggestions to you and other users on Dubb; and (e) provide support.
Granting us this permission not only allows us to provide Dubb as it exists today, but it also allows us to provide you with innovative features and services we develop in the future that use the PII we receive about you in new ways.
We may use your PII to communicate with you for the foregoing and other reasons by email, text message, phone call, or other electronic, written or oral communication method, unless you expressly indicate to Dubb not to use a particular method of communication.
While you are allowing us to use the PII we receive about you, you always own all of your information. Your trust is important to us, which is why we don’t share PII we receive about you with others unless we have: (a) received your permission; (b) given you notice, such as by telling you about it in this policy; or (c) removed your name or any other PII from it.
Additionally, we may use aggregated information derived from PII to improve the Dubb Services and any related matters thereto.
2.3.5 Unless we are required to do so by law, we shall not obtain your consent before collecting PII about you from parties other than Dubb. Rather, Dubb shall presume that you have previously provided such consent to any such third party from whom Dubb obtains such information.
2.3.6 In the normal course of its business operations, Dubb restricts the use of your PII to Dubb’s personnel and its Strategic Partners. However, by using Dubb Services, you may necessarily disclose PII to potential employers and Staffing Customers when they access your information, profiles, interviews, and other Content.
2.3.7 We shall not sell your PII in the normal course of business operations. Should all or any part of Dubb’s business operations be sold, this paragraph shall not restrict the transfer of your PII as part of the Website sold to a third party.
2.3.8 We may also use the PII you provide in registering with and using Dubb to inform you by electronic mail, phone, text or other communication method of additional products and services about which you might be interested, which may include our periodic e-newsletters and other promotional communications from Dubb.
2.4 Disclosing Personal Information
22.214.171.124 Dubb may use PII in the normal course of providing the Dubb Services; to operate or improve the Apps, Website and/or Dubb Services; to outsource certain services to Strategic Partners; to complete a transaction that has been requested; to develop aggregate information; and/or as otherwise disclosed to you.
126.96.36.199 In particular, by the very nature of the Dubb Services, information submitted by our customers seeking employment or employees will be shared with other customers as applicable to the customers’ particular searches and use of Dubb Services.
188.8.131.52 Additionally, Staffing Customers that use Dubb Services may provide their employer customers, Third-Party Customers, information about Dubb customers in an effort to match individuals using Dubb Services to the needs of their employer Third-Party Customers. In some cases, Third-Party Customers may not be Dubb Customers. Although Dubb requires its Staffing Customers to ensure that their Third-Party Customers agree to terms similar to those of Dubb, Dubb has no control over the use of customer PII and non-PII by such Third-Party Customers where a Third-Party Customer is not a Dubb Customer.
184.108.40.206 In some cases, Dubb Customers may be able to download your Profile Videos and other public information, and store them on, their computers and servers. Other Dubb Customers may also be able to use shared links by which they provide related parties who might not also be Dubb Customers access to your content.
2.4.3 Strategic Partners. Dubb may employ, engage or retain certain trusted third parties (“Strategic Partners”) to perform functions and/or provide services on its behalf. Dubb will share PII with these Strategic Partners only to the extent necessary to perform the functions and/or provide the services for which they have been employed, engaged or retained. Dubb shall also secure contractual obligations from our Strategic Partners to maintain the privacy and security of the PII shared with them.
2.4.4 Business Transfers. Dubb reserves the right to sell, transfer or otherwise share some or all of its assets, including PII, in connection with a sale of assets; a merger, acquisition, or reorganization; or, filing for bankruptcy. You will have the opportunity to opt out of any such transfer if the planned processing of your information by the purchaser differs materially from that set forth in this Privacy and Security Policy.
2.4.5 Legal Compliance. Dubb may disclose any information about you and/or Content created by you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (1) comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority; (2) respond to claims, court orders, or other legal process (including subpoenas); (3) to enforce the terms of this and other Dubb agreements as well as to protect the property and rights of Dubb, its Strategic Partners or other third parties; (4) to protect, in Dubb’s sole discretion, the public or any person from harm; (5) to investigate, prevent, stop, or take other action regarding any action perceived to be fraudulent, illegal, unethical, or legally actionable in Dubb’s sole discretion; and/or, generally, (6) to comply with the law.
2.4.6 Notice. Unless restricted from doing so, Dubb will attempt to notify you before it releases any of your PII or Content pursuant to (1) and (2) in paragraph 2.4.5 only. In such cases, Dubb will also provide you with general information on how you may seek to block such a release of information and/or direct you to resources that can provide such general information. The provision of such general information to you is not and should not be construed as providing you with legal advice. Additionally, Dubb is under no other obligation to assist you in challenging or opposing a release of your information
2.5 Non-Personally Identifiable Information
2.5.1 In addition to collecting PII as previously described, Dubb also collects other non-PII.
2.5.2 Non-PII collected by Dubb may be utilized without restriction.
2.5.3 Although non-PII can be used in a number of ways, you can be assured that the use of the non-PII cannot identify you as a particular individual.
2.5.4 Because non-PII cannot be used to identify you, Dubb may in its discretion provide non-PII to other persons or entities.
Information Obtained From Use of Dubb’ Websites
2.6.1. Cookies can be defined as bits of data stored on your computer that allow website(s) to identify your browser and session.
220.127.116.11. If you reject all cookies, you may not be able to use the Dubb Services or products that require you to “sign in” and you may not be able to take full advantage of all offerings.
18.104.22.168. Most web browsers automatically accept and collect Cookies. However, most browsers also allow you to configure them to accept all cookies, reject all cookies, or notify you when a cookie is set. Depending upon your web browser’s security settings, you may have the ability to reject all cookies.
22.214.171.124 The Dubb Website uses its own cookies for a number of purposes including, but not limited to:
A. Requiring you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents;
B. Keep track of preferences specified by our users while using the Dubb Website;
C. Estimate and report our total audience size and traffic; and,
D. Conduct research to improve the content and services provided on the Dubb Website.
2.6.2. Google AdWords Marketing
126.96.36.199. Dubb may use, from time to time, Google Adwords marketing campaigns to promote its products and services. In particular, Dubb intends to use Google AdWords “Remarketing” campaigns.
188.8.131.52. In using Google Adwords marketing campaigns, Google will place a cookie on your computer when you visit Dubb’s website(s). As you leave Dubb’s website(s), this cookie will later enable banners and other materials to appear through which you can return to Dubb’s website(s).
184.108.40.206. The foregoing being said, through the use of any Google AdWords marketing campaign, Dubb:
A. SHALL NOT run an interest-based advertising campaign that collects PII;
B. SHALL NOT use or associate PII with remarketing lists, cookies, data feeds, or other anonymous identifiers;
C. SHALL NOT use or associate targeting information, such as demographics or location, with any PII collected from any Google AdWords ad or landing page associated with it;
D. SHALL NOT target children under the age of 13 through any Google AdWords campaign;
E. SHALL NOT share any PII with Google through Dubb’s remarketing tag or any product data feeds which might be associated with Dubb’s ads;
F. SHALL NOT, when creating a remarketing list, use any sensitive information (as defined by Google), or products associated with such sensitive information, about visitors to Dubb’s Website(s), any of its Webpages, or Apps, whether Dubb collected it directly or associated it with a visitor, based on the visitor’s profile or behavior on Dubb’s website(s), webpages, and/or through its Apps;
G. SHALL NOT create a remarketing list or ad that seeks to reach people through prohibited methods; and,
H. SHALL NOT create or produce ad content that implies knowledge of PII or sensitive information.
220.127.116.11. Dubb has no objection to Google providing notice or labels to disclose interest-based advertising to its users.
18.104.22.168. Dubb has no objection to Google displaying to its users the remarketing lists, including those of Dubb, upon which they appear.
22.214.171.124. For your protection, Google will not disclose Dubb remarketing lists or other similar audience lists to another advertiser without Dubb’s consent. At this time, Dubb shall not permit such disclosures.
2.6.3. Browser and Session Information
Dubb may collect information about your browser and session at the Website and/or using the Website Services.
2.6.4. IP Addresses
126.96.36.199. Dubb maintains a log of Internet Protocol (IP) addresses when any corporate owned computers, servers, and/or websites (including, the Website) have been accessed. An IP address by itself does not allow us to collect additional PII about you.
188.8.131.52. IP addresses may be used for various purposes, including to:
A. Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP;
B. Estimate the total number of users visiting a Dubb computer, server and/or website from specific geographical regions.
C. Help determine which users have access privileges to certain content, services or resources offered; and,
D. Monitor and prevent fraud and abuse.
184.108.40.206. OTHER THAN YOUR IP ADDRESS, Dubb DOES NOT DIRECTLY COLLECT ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU UNLESS YOU VOLUNTARILY PROVIDE US WITH THIS INFORMATION.
2.7 Data Retention
2.7.2. The length of time for which Dubb retains PII and other information will vary depending on the nature of the services for which the information has been collected and the nature of the information.
2.7.3. Although this period may extend beyond the end of your relationship with Dubb, it will be retained for only so long as necessary for Dubb to respond to any issues arising from your relationship with Dubb.
2.7.4. When Dubb no longer needs or requires your personal information, Dubb will destroy, delete, erase or convert information to an anonymous form without notice to you.
2.7.5. Depending on the package of services purchased, Dubb may delete information including, but not limited to, stored messages, interviews, videos, audio, other content, and records of your account without notice to you. Dubb recommends that you back up on your own computer any critical and important information prior to allowing your Dubb Services to terminate or expire.
2.7.6. Should your account be terminated, Dubb may immediately and permanently delete all stored messages, interviews, videos, audio, other content, and records of your account without notice to you.
3.1. Dubb may obtain personal information about you through a variety of sources. For each source or method, the manner of consent may differ.
3.3. For these reasons, unless and until you expressly inform Dubb you do not wish your information to be used, Dubb shall presume it has your consent.
3.4. Where Dubb obtains information about a consumer from its customers or other third parties, Dubb presumes that the consumer has previously provided appropriate consent to the party from whom Dubb obtains the information. In any case, the consumer can be assured that this Privacy and Security Policy applies to any information obtained from a third party.
4.1 Subject to certain limitations imposed by applicable privacy laws, you may request that Dubb provide you with a copy of your personal information and/or information regarding how we have used that personal information.
4.2 Any requests for access to information should be directed to our Privacy Officer at the contact information provided below.
4.3 We will make every effort to respond to your request in a reasonable timeframe.
5.1. Dubb takes the issue of protecting your anonymity and personal information very seriously. Dubb protects the information it obtains about you with appropriate, commercially reasonable safeguards and security measures consistent with standard information practices. These measures include commercially reasonable technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.
5.2 For security purposes, Dubb does not disclose all of its security measures. Be assured that Dubb does employ commercially reasonable industry standard measures to protect your information.
6 DISPUTE RESOLUTION
6.1 Should you have any complaints with respect to our compliance with our Privacy and Security Policy and our Safe Harbor commitments, we encourage you to contact us directly to resolve any such complaints. We value our customers and their privacy. Consequently, we want to hear from you should you have any issues regarding our privacy practices. You may send an email to email@example.com.
6.2 Should you have any unresolved complaints with respect to our compliance with our Privacy and Security Policy and our Safe Harbor commitments, you may contact JAMS as an independent resource mechanism to hear any such disputes.
6.3. Should you have any unresolved complaints with respect to our compliance with our Privacy and Security Policy and our Safe Harbor commitments, you may also contact the Federal Trade Commission (“FTC”) (https://www.ftccomplaintassistant.gov/) as the appropriate statutory body that has jurisdiction over any claims related to our privacy practices. However, the FTC does not resolve individual consumer complaints.
7 DISCLAIMER AS TO THIRD-PARTY WEBSITES
Although our corporate owned websites may contain links to other third-party websites and/or may be advertised on such third-party websites, Dubb is not responsible for the privacy practices or the content of such websites and specifically disclaims any such responsibility. Dubb does not monitor the privacy practices or content of these websites. If you have any questions about the privacy practices of a website other than a Dubb owned website, you need to contact the Privacy Officer of the website about which you have a question.
8 INCORPORATION OF OTHER APPLICABLE TERMS
9 PRIVACY OF CHILDREN
We make it a practice not to knowingly obtain and/or retain information about individuals under the age of fifteen (15). Indeed, no part of Dubb Services is directed to anyone under the age of fifteen (15).
10 ADDITIONAL INFORMATION
10.1 When you post content on and/or through the Dubb Services, you have the ability to post content which may include personally identifiable information or PII about yourself. You are responsible for the information you (a) post online; (b) post through use of the Dubb Services; or, (c) share with another website that you link to from our Website. You do so at your own risk. Dubb warns you to be careful in posting information accessible to the public.
10.2 If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties or other unwanted and possibly harmful contact. Dubb warns you to be careful in posting information accessible to the public.
11 CUSTOMER OBLIGATIONS
12 REVISIONS TO PRIVACY AND SECURITY POLICY
12.2. Dubb shall provide notice of such changes by posting the revised policies to the applicable Dubb owned websites and by either (a) providing you a message the next time you login into your account or (b) sending you electronic mail to the email address you provided when creating your account.
12.3. With respect to this Privacy and Security Policy, you should visit our website at dubb.com from time to time to review the then-current terms. At any time, the current-posted policies govern and shall be binding.
For Additional Information or Questions, Contact Our Privacy Officer
Dubb has a designated Privacy Officer. If you have additional questions or concerns regarding how Dubb is managing or using your personal information, please send your concerns in writing to our Privacy Officer by e-mail at support(at)dubb(dot)com.