Privacy Policy

Last Updated: September 11, 2019

1. Introduction Project Guild values the trust our users and customers place in us when they give us access to their personal data. The Privacy Policy describes how we work to maintain that trust and protect that information. In particular, this Privacy Policy details our collection, use and disclosure of personal and non-personal data you give to Project Guild when you access or use Project Guild’s online and/or mobile services and websites, and software provided by Project Guild on or in connection with such services or websites (collectively, the “Site”). 1.1 The Project Guild Entities Responsible for Your Information All references to Software Engineer and Employer are defined as provided for in the Project Guild Terms of Service Introduction. This section determines which Project Guild entity acts as the controller of your Personal Data (as defined in section 1.2) provided to, or collected by or for, or processed in connection with our Site. With respect to Software Engineers, for the purposes of this Privacy Policy, “Project Guild” or “we” means Automate My Startup Incorporated if you are a Software Engineer located in the United States, or Project Guild Ireland Operations Limited if you are a Software Engineer located outside of the United States. With respect to Employers, “Project Guild” or “we” means Automate My Startup Incorporated if you are an Employer located in the United States, Project Guild Brasil Pesquisa de Empregos ltda. if you are an Employer located in Brazil, Project Guild India Operations (Pte.) Ltd. if you are an Employer located in India, Project Guild Singapore Operations (Pte.) Ltd. if you are an Employer in the Asia-Pacific Region, Project Guild Ireland Operations Limited if you are a Employer located elsewhere, and Project Guild Hire, Inc. if you are receiving the Project Guild Hire services. Project Guild is the controller for the Personal Data we process, unless otherwise stated in these terms or provided for in a separate agreement. 1.2 Personal Data and Non-Personal Data Personal data (“Personal Data”) refers to any information that relates to an identified or identifiable individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times Project Guild will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data. 1.3 The Scope of Project Guild’s Privacy Policy This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy. Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site. This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g., with respect to the types of data collected or our uses or disclosures of such information). Project Guild may amend this Privacy Policy at any time. 1.4 Changes to the Privacy Policy Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Project Guild is going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then Project Guild will notify users via email and/or by posting a notice on Project Guild’s Site for 30 days prior to such use or by other means as required by law. 1.5 Project Guild’s approach to privacy and the General Data Protection Regulation (GDPR) Please note this Privacy Policy describes, in a comprehensive manner, how Project Guild processes your data. For more information on Project Guild’s approach to privacy and GDPR, click here. 2. Information Collected You provide different types of information in order for Project Guild to provide our services, products and features to you. Project Guild associates this information with your Resume and account to create your Project Guild Profile. 2.1 Information You Provide to Project Guild – From Your Account We collect data from you when you create an Project Guild account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post a resume, complete an Project Guild Assessment, upload content or otherwise actively send us data on our Site. This may include, but is not limited to, your user name, password, first and last name, email address, telephone number (including mobile phone number), street address, gender, occupation, interests, messages you send to users, and any other data included in a submitted profile or resume, including but not limited to application materials and answers to screener questions submitted to Employers through Project Guild and answers you give to any questionnaires sent to you. This information may be associated with your profile. You may provide your specific location data when you provide it yourself on the Project Guild Apps (as defined in the Project Guild Terms of Service Introduction) to help you find more relevant Job Listings (including from the location service on your mobile device when you grant permission to an Project Guild App), or when you submit a photo to Job Spotter that includes the provision of the location data of where the photo was taken. Project Guild seeks your consent at the time of such provision, and such processing will only be performed where consent is secured. – Through Your Activity on Project Guild In addition, as part of the standard operation of the Site, Project Guild may collect and analyze information from your computer or mobile device and actions taken on the Site, including, but not limited to, your resume, your searches on Project Guild, the titles of jobs you search, click on or apply to, where those jobs are located, salary interest or experience, the general salary range or experience level of the jobs you view (where indicated), your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site. – When Using Automated Phone Screening If you use any automated phone screening product, Project Guild will record and store your answers to an Employer’s screening questions and will forward your answers to the Employer. Where you wish to use such a product, you will agree in advance to Project Guild listening to and analyzing the recording in accordance with this Privacy Policy. – When Providing Employer Information If you are an Employer, Project Guild may request that you provide certain Personal Data to Project Guild in order to verify your account. This information may include, but may not be limited to, your Federal Employer Identification Number (EIN), Business Registration information, or a utility bill, the name and email address of an Employer representative. This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit card numbers and related verification information). Please note that Project Guild only has access to the last four digits of Employer credit card numbers, and does not store full credit card numbers. 2.2 Information Collected When You Apply for Jobs or Access Project Guild from Some Third-Party Websites – When You Apply to Jobs on Some Third-Party Sites Project Guild may also collect information about web sites and web pages you visit through our mobile software or while using Project Guild for Chrome about job postings that you save, notes or applications statuses that you save or update, or data regarding how you engage with websites or other actions you take on such website, including URLs of websites you visit. We do this in order to allow a Software Engineer to keep a record of particular Job Listings of interest, to detect a job application form on a third-party website to give a Software Engineer the option to auto-fill parts of the form using Project Guild Resume, or to confirm an application. Project Guild for Chrome also allows Project Guild to learn about what types of jobs and Project Guild product features are of interest to you, so that we can provide you with improved job listing searches, job listing recommendations and product features. – When You Log In or Use Project Guild from Some Third-Party Sites You may also create an account or log in to your Project Guild account using third-party websites including, but not limited to, Facebook or Google. If you do not already have an Project Guild account but log in to Project Guild using your Facebook or Google account, this creates an Project Guild account using the same email address used in your Facebook or Google account. If you agree to provide this information to Project Guild, Facebook or Google will authenticate you and redirect you to Project Guild’s Site. Please note, when you log in to Project Guild using your Facebook or Google account, Facebook or Google will cookie you in order to authenticate you as a Facebook or Google user. By accessing Project Guild through your Facebook or Google account, you understand that Facebook or Google will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Facebook or Google account. This information will be considered Project Guild account information for purposes of your use of the Site. You have the ability to disable the connection between your Facebook or Google account and your Project Guild account at any time by accessing your privacy settings on your Facebook or Google account. Facebook or Google may also ask for your permission to share certain other details with Project Guild, including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with Project Guild, which may use this information to provide Services to you, including populating your Project Guild profile. The shared information will remain associated with your Project Guild profile until you modify or delete it. PLEASE NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE. – When You Use Project Guild Embox Project Guild Embox is a browser extension or add-on developed by Project Guild that can be downloaded from the Google Chrome Web Store or G Suite Marketplace. Project Guild Embox serves as a free extension or add-on in Gmail that allows you to manage your candidates by updating their application statuses and utilizing templates to respond to applications. To use Project Guild Embox after installing it on a particular device, you must first sign in to your Project Guild Employer account within the browser extension or add-on (some older versions of Project Guild Embox did not require users to sign in to their Project Guild Employer accounts to use the extension or add on). Once you sign in to your Project Guild Employer account, Embox will sync automatically with your Project Guild Employer Dashboard, and all candidates, plus their profiles and statuses, in your Project Guild Employer dashboard will also appear in Project Guild Embox. Only candidates’ status changes sync from Project Guild Embox to your Project Guild Employer Dashboard. Notes made in, messages and attachments sent through, and any candidates added only to Project Guild Embox will not sync to your Project Guild Employer Dashboard. This syncing is device specific. To stop syncing with Project Guild Embox installed on any device, you must log out of your Project Guild Employer account at Project Guild.com on that device. Stopping syncing on one device will not stop syncing enabled on another device. If you use Project Guild Embox, Project Guild may collect your email address and information that you save or update in Embox while you use the extension or add-on, including your notes and information about a candidate or candidate’s statuses that you save or update. Project Guild may use this information to provide and improve the Embox product offering and to communicate with you about Embox. Some versions of Embox will prompt you to sign in to your Gmail account, in Embox, in order to use the extension or add-on. If you sign in to Gmail in Embox, Project Guild may also collect information about your activity in Gmail as it relates to Project Guild Embox or to help improve Project Guild Embox offerings. For example, Project Guild may identify that you have not responded to an email from a candidate and send you a notification reminder. Project Guild may use this information to add labels to candidates in your inbox (which you may remove, if you so wish), to detect if you receive an email through Project Guild’s email relay service, and to automatically launch the extension or add-on. Project Guild may also use information obtained from Gmail to provide and improve the Embox product offering and to communicate with you about Embox. This information will not be used to market other Project Guild products and services to you. Embox Plus is a different Project Guild browser extension. References to Embox in this Privacy Policy do not apply to Embox Plus. – When You Use Project Guild Text2Apply Project Guild Text2Apply is an autodialed text messaging service that Project Guild developed to allow you to apply to certain jobs entirely from your mobile device by answering a series of questions presented to you via text messages. You initiate the application process by texting a specific keyword to the telephone number that appears on a Job Ad on our Site or on advertising materials, such as a sign or flyer at an Employer’s place of business. Your application will not be complete and we will not share it with the Employer unless you answer all questions in the correct format. Your use of Project Guild Text2Apply is subject to this Privacy Policy and Project Guild’s Text2Apply Beta Terms of Service. If you use Project Guild Text2Apply, Project Guild may collect your name, telephone number, email address, and any other information you choose to provide, such as your answers to the screening questions associated with the particular Job Ad that we present to you via text message during the application process. Project Guild may use and disclose this information for all of the purposes outlined in Sections 4, 5, and 9 of this Privacy Policy, including but not limited to for the purpose of assembling your application to the Job Ad, sharing your application with the Employer identified in the Job Ad, providing and improving the Text2Apply service offering, communicating with you about the Text2Apply service offering and your use of it, and enhancing your Project Guild Profile if you have an Project Guild account (please note that your Text2Apply application will not be displayed in your Project Guild Profile at this time, but future development may add this feature). You may unsubscribe from the Text2Apply service at any time by texting the word “STOP” to the telephone number provided in the Job Ad. Doing this will unsubscribe you from the service and pause any incomplete application. Project Guild will send you one additional text message to confirm you are unsubscribed from the service. Unsubscribing from the Text2Apply service after you have completed your application will not stop Project Guild from sharing your application with the Employer listed in the Job Ad. You may resume the Text2Apply service and any incomplete application at any time by texting the word “START” to the telephone number provided in the Job Ad. You may also text “HELP” at any point to receive a text message with instructions on how to receive more information about the Text2Apply service and on how to unsubscribe. PLEASE NOTE THAT DUE TO THE CONVERSATIONAL NATURE OF THIS SERVICE AND THE UNRESTRICTED FORMAT OF SMS TEXT MESSAGES, Project Guild CANNOT GUARANTEE IT WILL HONOR AN UNSUBSCRIBE REQUEST MADE BY TEXT MESSAGE UNLESS IT IS LIMITED TO THE SINGLE-WORD “STOP”. Project Guild EXPRESSLY MAKES NO REPRESENTATION AND DOES NOT GUARANTEE THAT IT WILL RESPOND TO ANY OTHER FORM OF REQUEST BY TEXT MESSAGE TO UNSUBSCRIBE FROM THIS SERVICE. YOU MAY ALSO CONTACT US BY SENDING AN EMAIL TO TEXT2APPLY @ Project Guild.COM (remove spaces when sending email) OR SUPPORT.Project Guild.COM FOR MORE INFORMATION AND TO UNSUBSCRIBE. 2.3 Any Other Personal Data Project Guild May Receive from Third Parties Any Personal Data that Project Guild may obtain from other third-party sources will be processed by Project Guild in accordance with this Privacy Policy and all applicable laws. 2.4 Storage of Your Information Project Guild stores your personal data until it is no longer necessary to provide our services, or until you ask us to delete your personal data. We may also be required to retain certain information in order to comply with local laws. If you create an Project Guild account, your information may be collected and stored in a manner that connects to your account email address. Project Guild may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, email address, or zip code. For example, while using a mobile device to access Project Guild, Project Guild may provide a Software Engineer with relevant job postings that are located within the same zip code as where this activity is taking place. The collection of this data is solely used in accordance with the purposes outlined in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Project Guild may also store the information detailed in this section 2 of the Privacy Policy on its equipment or the equipment of third parties that Project Guild has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules. 2.5 What Personal Data is Required Project Guild will indicate to you at the point of provision as to whether or not particular Personal Data provided by you is required in order to provide particular Project Guild services or features to you. Where Personal Data that is required is not provided by you then the particular feature or service may not be available to you. 2.6 The Legal Basis on Which Project Guild Collects Your Personal Data Project Guild collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here. – Performance of a Contract Some of the Personal Data processed by Project Guild is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement. An example of this would be where Project Guild sends a Software Engineer’s application to an Employer. – Legitimate Interest A second ground relied upon by Project Guild for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Project Guild. Such legitimate interests will include where Project Guild sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. A further example would be where Project Guild shares your Personal Data with Project Guild affiliates as detailed in section 4.12 below. Project Guild will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you. – Compliance with a Legal Obligation A third ground relied upon for certain types of processing is that it is necessary in order to allow Project Guild to comply with a legal obligation. An example of this would be where Project Guild is required to retain business records for fixed periods of time in order to comply with local legal requirements. – Consent Finally, in certain limited situations, Project Guild relies on your consent in order to process your Personal Data. Where Project Guild requires your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. For example, your consent will be sought where you provide your location when you provide it yourself on the Project Guild Apps to help you find more relevant Job Listings (including from the location service on your mobile device when you grant permission to an Project Guild App), when you submit a photo to Job Spotter that includes the provision of the location data of where the photo was taken, or in certain instances where you initiate a marketing message such as a job alert with Project Guild (detailed in section 4 of this Privacy Policy). You can withdraw your consent, as detailed in section 10 of this Privacy Policy where applicable, or by sending an email to privacy-dept @ Project Guild.com (remove spaces when sending email). 3. Limitations of Use 3.1 Where a Software Engineer Wants to Close a Software Engineer Account When a Software Engineer closes an account, the Software Engineer will no longer have access to any of the data we make available under that account name, including but not limited to, search history, job search preferences, saved jobs, jobs the Software Engineer has applied to, job alerts, resume, and any other data associated with the account. If the Software Engineer uses the same email address to set up a new account, this data from a previous account will not become available to the Software Engineer again. Please also note that closing your Software Engineer account may result in you losing access to all Project Guild products and the ability to utilize the “Log in with Project Guild” feature found on certain third party sites. Project Guild reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from the Project Guild systems, although it will not be readily available under the Software Engineer’s original account name. When the Software Engineer presses the close account button on the dashboard, Project Guild will begin to process that instruction within 24 hours and will have completed the operation within 40 days. If a Software Engineer wishes to access or delete their Personal Data held by Project Guild, they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules. 3.2 Where an Employer Wants to Close an Employer Account Employers may close an account at any time by contacting Project Guild Customer Support. Please note that Project Guild must preserve business records pertaining to that account to comply with its obligations under law. Alternatively, if an Employer agent wishes to access or delete their Personal Data held by Project Guild, they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules. 3.3 Where a Software Engineer Wants to Delete a Job Application If a Software Engineer wants to delete a job application performed on Project Guild’s Site, they are advised to contact the prospective Employer directly to request deletion of their application. For job applications which you, the Software Engineer submit through Project Guild (including the use of an Project Guild Apply button) to an Employer, (with related materials submitted), please note: 1) that your applications and materials may be controlled by an Employer; 2) we may direct you to that Employer for Personal Data deletion requests where that Personal Data is held by that Employer; and 3) Project Guild depends on the Employer or the Employer’s agent to provide Project Guild with the correct destination for all applications. 3.4 Where the Employer Contact Details Provided to Project Guild Are Incorrect In the event that the electronic destination provided to Project Guild is incorrect, your application materials will not be sent to the intended recipient of the application. Project Guild has no liability for such applications. If you do not wish to send your application materials in this manner, you should send them directly to the Employer. 3.5 @Project Guildmail Addresses When communicating through Project Guild’s message relay system, you will see an email address with an @Project Guildemail.com or @Project Guildmail.com ending. You understand that you retain no ownership rights in these email addresses, which are specific to Employers’ Job Listings, but are owned by Project Guild. However, Project Guild’s relay system will show the name associated with your account or job application in the “To:” or “From:” field. Please also note that since these message proxy and relay services depend on the functionality of third-party providers, there may be technical delays on the part of those email service providers. 3.6 Minimum Age of our Users The Site is not for use by anyone under the age of 16. However if local laws provide for an alternative minimum age for Project Guild to lawfully provide the services in the Site to you, then that shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use Project Guild under the supervision of your parent, legal guardian or responsible adult. Project Guild adopts a range of measures to try to ensure that we do not accept individuals who do not meet the minimum age and any other applicable age requirements. If you do not satisfy these age requirements, please email privacy-dept @ Project Guild.com (remove spaces when sending email). 4. Purposes, Uses and Disclosures of Information We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Project Guild associates Personal Data with your Project Guild Profile in order to perform the activities described in this Privacy Policy. Project Guild uses such information to help Software Engineers find jobs and to help Employers find candidates. In order to do this we use your Personal Data to: 1) provide our services, products and features to you, to help Software Engineers find jobs and Employers find candidates; 2) to measure and improve those services, products and features; and 3) to protect our users and provide them with customer support. More detail on these purposes, uses and disclosures of your information is set out below. 4.1 Creating an Account, Sending You Job Alerts and Other Promotional Materials If and to the extent permitted by applicable law, Project Guild may use your contact information to (i) create an account; (ii) send you job alerts; and (iii) send you information about Project Guild, including promotional materials. Project Guild may use third-party partners to perform these activities on Project Guild’s behalf. A job alert is defined as an email sent to you that you sign up for containing Job Listings in response to a search query you have run (“Job Alert”). Job Alerts may also include jobs that Project Guild recommends for you, Project Guild Targeted Ads, companies you may be interested in following, or other actions you may want to take on the Site. Project Guild may adjust the frequency of job alerts based on your interactions with job alerts. Project Guild may also share your information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you. Such advertisements will only relate to Project Guild’s services, products, and features, all of which focus on helping Software Engineers find jobs and Employers find candidates. If you wish to opt out of receiving any marketing messages from Project Guild please see section 10.3 of this Privacy Policy. If you are an Embox user, information provided through Embox, such as updates made regarding candidate statuses, will not be shared with third-parties for advertising purposes. 4.2 Giving You Relevant Search Results and Recommended Jobs In order to optimize our services, products and features for you, Project Guild may use your previous search and browsing history (e.g. the jobs you click on), or application materials and answers to screener questions, to identify you and determine relevant search results and provide you with recommended jobs or reach out to you about jobs you may be interested in. We may also use profile data to tailor your experience on the Site, to show you content that Project Guild thinks you may be interested in, and display content according to your preferences. Project Guild may return different results for the same search query and has full discretion with respect to the job listings it presents in response to any particular search. 4.3 Your Contact Information When you give Project Guild contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that Project Guild may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that Project Guild may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your Project Guild account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you may provide to Project Guild or that Project Guild may otherwise obtain from third-party resources. 4.4 Your Resume Information Your information, including Personal Data, gets placed on the Site when you upload or edit a resume, which becomes part of your Project Guild Profile. Project Guild reserves the right to charge third parties a fee for accessing your information, including Personal Data, as part of Project Guild’s services. At your direction, Project Guild may also send your resume to third parties if you choose to apply for a job listing. The extent to which your information is made available to third parties depends on the privacy settings you choose on Project Guild, in accordance with this Privacy Policy. When a Software Engineer creates a profile on Project Guild, their resume is set to public by default, and the Software Engineer may change their resume privacy settings at any time. This is detailed below. – Private Resumes Private resumes are only made available to those to whom the Software Engineer has initiated an application or provided their resume. Where this occurs, you make your resume, your name and other Personal Data that you place on your resume available to third parties. Those third parties may be interested in you as an employee, and may forward your resume to other third parties. – Public Resumes Public resumes are available to anyone with access to Project Guild’s resume search application and may be accessed by other Project Guild users, in order to increase the visibility of that resume and help Project Guild find you a job. A public resume is also available to anyone accessing the associated URL, and to Employers whose Company Page you are following. Where this occurs, you make your resume, your name and other Personal Data that you place on your resume available to third parties. Those third parties may be interested in you as an employee, and may forward your resume to other third parties. If you post a public resume, this may be crawled by, and displayed through search engines when someone searches for your name. This means that third parties can view the Personal Data contained in your resume and you may receive unsolicited contact from parties unaffiliated with Project Guild and for whom Project Guild has no responsibility. If you post a public resume on Project Guild, please note that although Project Guild expressly prohibits the scraping of its Site any resume you post publicly is public information and the content may be copied by a third party in violation of these terms. For public resumes, you also authorize Project Guild to remove your name from your public resume, in certain instances. Project Guild may also change the display of your resume from public to private in certain instances to maintain the quality of the resume database. If you have a public resume, Project Guild may use information from your resume to auto-fill all or parts of a form or application. For example, if you use Project Guild Chat, your name from your resume may appear in the messages. Please note that Resume Search has not launched in all markets. If you are located in a market where Resume Search has not yet launched, setting your resume to public will make it available to anyone who visits the associated URL. Resumes set to public will become searchable upon the launch of Resume Search in your market. – Changing Your Resume Privacy Settings When you place your resume on Project Guild, it will be public by default. You may adjust this at any point by editing your privacy settings on Project Guild. Where you adjust your resume from public to private, Project Guild does not warrant how often third-party search engines will update their caches, which may continue to contain your resume information. Additionally, Employers who have saved your resume while it was public may continue to have access to your resume even after you have adjusted it to private. 4.5 Matching Software Engineers With Employers You acknowledge that Project Guild may determine whether the words of your resume or any other individuals’ resume match the words of certain job descriptions, and vice versa, in order to improve the Site or any other Project Guild product or service (including by displaying or otherwise making available potentially relevant job descriptions and resumes to Software Engineers and Employers). Project Guild may also provide information collected pursuant to this Privacy Policy, including Personal Data, to Employers that may be interested in contacting you. By applying to a job, answering screener questions, providing your contact information to show interest in a job, or by replying to a message from an Employer, you agree to the disclosure of your information to that Employer. Project Guild may also provide the results of any Project Guild Assessments you complete to Employers, where you agree to such provision at the time of taking such an assessment. Project Guild may also use information provided to Project Guild via your Project Guild Resume to pre-populate application information for you and for similar purposes. If you have an Project Guild account or an Project Guild-hosted resume, you agree that Project Guild may contact you or suggest you or your public resume to Employers that might be interested in a person who matches your behavior on Project Guild. In addition, if you are located in the United States and you set your Resume to public, this means that Project Guild may share all of the aforementioned information about yourself with recruiters working for or on behalf of Employers. If you do not wish to share such information, you may set your Resume to private. 4.6 Sending Messages on Project Guild Project Guild provides two-way message proxy and relay services to the users of our Project Guild products (“Relay Service”), including: Project Guild Resume, Project Guild Apply, Post a Job, Project Guild Chat, Project Guild Onboarding, private calling, and other electronic communication services whether in the form of phone, text, video or audio. By utilizing any Relay Service, you acknowledge that you are asking Project Guild to send these messages on your behalf. This includes your resumes, cover letters, applications, messages, questionnaire answers, responses, offer letters and other materials. We process, monitor, review, store and analyze such content, including via automated means, for data analysis, quality control, enforcement of the Site Rules and other Project Guild policies, content moderation, and to improve the Site or any other Project Guild product or service. Examples of such improvements would be improving the open rate of messages by optimizing their delivery, optimizing our search results, improving Job Listings, permitting applicants to manage their applications after transmitting them to Project Guild, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. Project Guild may (but is not obligated to) notify you in such an event. By using a Relay Service or otherwise providing User Content through the Site, you agree to this activity and acknowledge that this activity is necessary for maintaining the quality of the Site and for providing the Relay Service. 4.7 Sending You Text Messages About Employer Appointments Project Guild may offer you the opportunity to receive a text message from Project Guild when an Employer has scheduled an interview or event with you or responded to your application via Project Guild’s email relay. In such an event you will enter your phone number on the Project Guild consent form and by entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. Project Guild will only send you a text message reminder for such interviews or messages through Project Guild’s email relay, and you agree to accept such text messages on your cell phone including messages sent by automated telephone dialing system. To unsubscribe at any time, reply to the text with STOP or contact Project Guild Customer Support. 4.8 Facilitating telephone relay system between Software Engineers and Employers Where applicable, Project Guild may offer Software Engineers and Employers the option to avail of a telephone relay system to facilitate contact for the purpose of submitting applications, conducting job interviews or other communication related to a Job Listing. Such a system uses masked or proxy telephone numbers to protect users, and is only available to users who select it on the Site. No recording of conversations or messages is performed through this relay system, although data relating to whether a call was answered and call duration may be gathered. Such functionality is provided to Project Guild by third party service providers, such as Twilio. 4.9 Preventing Fraud and Spam Project Guild may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and Project Guild’s service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. Project Guild may investigate and disclose information from or about you or your use of Project Guild if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Site; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements. For example, Project Guild is subject to the investigatory and enforcement powers of the Federal Trade Commission in the United States, the Data Protection Commission of Ireland, and many other regulatory bodies. We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users. – Preventing Fraud and Spam in Messages Project Guild also reserves the right to drop messages from our relay system that Project Guild determines do not adhere to Site Rules or any of the terms of this agreement. Project Guild further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming Project Guild or its users, or otherwise conducting fraudulent activity on Project Guild by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to Project Guild. Project Guild also reserves the right to turn over any information gathered via such investigations to the police or other third party if Project Guild has a good faith belief that you are using the Site in violation of these terms. Project Guild reserves the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the Employer agents associated with that email address on the relevant Job Listing. 4.10 Facilitating Payment If you provide credit, debit or other payment card and related details to us in order to make a payment, Project Guild will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information). Any credit card and related billing and payment information that you provide to Project Guild may be shared by Project Guild with companies who work on Project Guild’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Project Guild and servicing your account. 4.11 Automated Processing of Your Personal Data In order to optimize the performance of the Project Guild Site and services for users, Project Guild performs automated processing of Personal Data evaluating certain specific aspects relating to a user, in particular to analyze or predict aspects concerning a user’s personal preferences or interests in terms of Project Guild’s Site and services. Where it occurs, such processing is carried out if it is necessary for the performance of our agreement with our users, to allow Project Guild to provide its services to Software Engineers and Employers, including analyzing applications and resumes on behalf of Employers, or in other cases on the basis of a user’s consent. For example, in certain cases such processing allows Project Guild to match Software Engineers with Employers effectively, to provide Software Engineers with job alerts and recommended jobs that the Software Engineer is likely to be more interested in, to send particular Software Engineer applications to an Employer, to display search results, or to perform certain spam and fraud detection activities to protect our users. Such processing is subject to the safeguards detailed in this Privacy Policy to protect the privacy of our users, and you may contact privacy-dept @ Project Guild.com (remove spaces) to contest any decision generated by said automated processing. 4.12 Sharing your Information with Project Guild Affiliated Entities and Websites Information shared by you with Project Guild may be shared with any Project Guild affiliated entity, no matter where located, to provide you with services, to improve the Site and optimize functionality on the Site, and other purposes as described in this Policy. In particular, such sharing strengthens Project Guild’s ability to help people find jobs and employers find good candidates. The services provided to you and the functionality of the Site could not be provided without such transfers. If you do not wish your information to be transferred in this way you should not use this Site. For the purposes of this Policy, “affiliates” means any entity that directly or indirectly, controls, is controlled by, or is under common control of or with an Project Guild entity, now or in the future. “Control” for these purposes means having a majority of shares or the right and ability to direct management. And this includes Project Guild affiliated entities located outside the European Economic Area (“EEA”) or Switzerland. Such data sharing with Project Guild affiliates will be performed for a number of specific reasons. – Improved Services It provides Software Engineers with more personalized and improved content, performance, features and services on Project Guild and its affiliates’ sites. For example, Project Guild and its affiliates use your previous search and browsing history (e.g. the jobs you click on), IP address, or your resume or profile information, to determine relevant search results, job alerts, display and moderate career insights, such as company reviews, job listing salary data, interview tips and more. Such sharing is also performed to facilitate improved data analysis, testing, research, and service improvement. It also allows employers to have better insight into the performance of their job postings. For example, we may share data related to user clicks on their job postings which in turn allows them to understand how their job posting may or may not be achieving their goal of attracting candidates. By providing employers with the information they need to better utilize our platform, they can provide stronger job postings. – More Employers, More Job Listings and More Software Engineers Such data sharing allows Software Engineers to access an even broader database of Job Listings and Employers, and for Employers to access more Software Engineers. For example, this allows Project Guild to recommend jobs or employers on Project Guild or on websites of Project Guild affiliates. It also facilitates applications and the display of job listings from the Project Guild Site to Project Guild affiliates’ websites and vice versa. Project Guild or an Project Guild affiliate is able to recommend an Project Guild Software Engineer (and that Software Engineer’s resume or resume extract) to an Employer hosted by Project Guild or to an Employer hosted by an Project Guild affiliate. Equally, an Project Guild affiliate is able to recommend a job listing hosted by an Project Guild Employer to a Software Engineer hosted by an Project Guild affiliate. Project Guild and its affiliates can also share Employer data (such as account information and behavioral data) to provide a better experience to those Employers. – Better Security for Users Such data sharing allows Project Guild and Project Guild affiliates to process your Personal Data for the purpose of improving user security and internal operations, troubleshooting, and detecting and preventing fraud and spam. 4.13 Transfers of Information to Employers Project Guild sends Software Engineer Personal Data to Employers on the instruction of Software Engineers. Such transfers are performed in the course of the job search, application and interview process. This is further described in sections 2 and 4 of this Privacy Policy. Such Personal Data will be processed in accordance with these terms and those of the relevant Employer. Software Engineers that apply to jobs through Project Guild that are outside their own country may involve sending their Personal Data to countries with lower levels of data protection. Employer account holders agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules. 4.14 Transfers of Information to Software Engineers Project Guild sends certain Employer-related information to Software Engineers. This includes publishing Job Ads, Company Pages, and salary information. Project Guild may also provide information to Software Engineers about an Employer’s activity and responsiveness on Project Guild in order to help Software Engineers evaluate employment opportunities. This may include the Employer representative’s name, the Employer’s city/state location, and whether the Employer has engaged with other Software Engineers or viewed other Software Engineers’ resumes. As an Employer, when you use Project Guild (for example by posting a Job Ad or contacting a Software Engineer through the Project Guild Resume Program) you agree that Project Guild may provide this information to Software Engineers. 4.15 Transfers of Information to Service Providers We may use third parties to perform services in connection with our operations, to improve the Site and our services, products, and features, to protect our users and better understand their needs, and to optimize the services and the users’ experiences. These service providers may have access to Personal Data in the course of providing these services, which may involve transfers of such Personal Data to other countries. Such transfers are only made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable and necessary. – Improving our Services These third parties may provide data points including how much time you spend on specific pages, which links you choose to click, and data that helps determine user preferences. This information enables us to build and maintain our services with user feedback. These third parties may use cookies and other technologies to collect data on your behavior and devices such as the device type, browser information, and preferred language. An example of one of these third parties is Hotjar. To opt-out of Hotjar’s cookies, please see the link in our Cookie Policy. – Maintaining Quality and Protecting Users Project Guild may transfer your Personal Data in limited situations to certain third-party vendors that assist Project Guild with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors Project Guild uses for fraud detection purposes. Examples of those vendors include: SiftScience, Emailage, and PerimeterX. Another example would be vendors Project Guild uses to prevent accounts being created using account credentials that have been publicly disclosed. An example of such a vendor is: SpyCloud. – Facilitating Payments Project Guild may also share any credit card and related billing and payment information that you provide to Project Guild with companies who work on Project Guild’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Project Guild and servicing your account. Examples of those vendors include: CVENT. – Installing or Using an Project Guild App In order to provide you with certain services and support ad attribution, limited user data may be shared with certain service providers when you install, download or use an Project Guild App. This may include your IP address or other unique identifier, and event data related to the installation of the Project Guild App. This may be done for a variety of purposes, including facilitating user log-in through third party accounts. It may also assist Project Guild to understand and optimize our users’ complete customer journey by helping us: (i) understand how users arrive to Project Guild; (ii) better measure the performance of our ads; and (iii) understand where a user has accessed Project Guild through different devices. When you download or install an Project Guild App, you acknowledge and accept that your Personal Data may be transferred to these service providers. You also agree to Project Guild’s Cookie Policy, Privacy Policy and Terms of Service, and are informed that you may avail of your rights at any time, as detailed in section 10 of this Privacy Policy, including the right to object to the legitimate interest use of your personal data for marketing purposes. Examples of the types of technologies that may support this behavior include pixels, javascript snippets, or cookies. – Storage Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. 4.16 Transfers of Publicly Available Information When users post content on Project Guild in a manner that is intended to make that content publicly available and searchable by individuals, Project Guild reserves the right to aggregate and share that information with third parties. For example, if an Employer posts a job on Project Guild, Project Guild may share that job posting or information contained within that job posting with third parties, at Project Guild’s discretion and subject to agreement between Project Guild and any such third parties. Project Guild also reserves the right to share information aggregated from public sources in this capacity. 4.17 Third-Party Sites You Link to from Project Guild You may also use certain third-party sites or services that you link to from Project Guild’s Site. In such cases, all information you provide to a third party is provided to that third party and not to Project Guild, and is subject to the third-party’s privacy policy and terms of service. Please see section 8 of this Privacy Policy titled Links to Third-Party Sites for more information. 4.18 Transfers of Personal Data for individuals in the EU (including the European Economic Area (“EEA”)) and Switzerland Please see sections 11 of this Privacy Policy for information related to this. 5. Additional Uses and Disclosures of Non-Personal Data In addition to the other uses and disclosures of information set forth in this Privacy Policy, and notwithstanding anything in this Privacy Policy to the contrary, we may use and disclose, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined. 6. Security Project Guild seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Project Guild’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. Please see the following page for more information. Please see section 11 of this Privacy Policy for liabilities pertaining to the transfer of Personal Data of individuals in the EEA and Switzerland. 7. Cookies “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our Cookie Policy for further information regarding Project Guild’s use of Cookies. – Do Not Track Requests We do not respond to the browser “Do Not Track” (DNT) signal if enabled by the user in their web browser. When we set or read cookies on non-Project Guild sites that have integrated our job search and display features, we do so, for example, to provide a personalized job search experience to users on those sites. We do not share any information about your use of Project Guild with those third parties. When third parties that we have integrated into Project Guild sites (as described in the Project Guild Cookie Policy) set or read their own third-party cookies, they may or may not respond to the DNT signal. 8. Links to Third-Party Sites The Site may make available links to other websites. When you click on such links, you may leave our Site. Your web browser may also disclose to the third party site the URL of the Project Guild page you clicked from, and this URL may include search terms and filters you used on Project Guild. The Site may also make available Company Pages, which may contain information provided by third-party Employers. WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE. 9. Acquisitions and Other Reorganizations Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in Project Guild’s business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by Project Guild of such third parties. 10. Exercising Rights With Respect to Personal Data Project Guild users that provide their Personal Data to Project Guild may avail of the rights detailed below. 10.1 The Right to Rectify Your Personal Data Project Guild users are able to edit and update most of their Personal Data held by Project Guild on the Site, and if you have any queries or complaints we encourage you to contact us here. Alternatively, if you do not wish to do this you may make a formal request to have Project Guild rectify any inaccurate Personal Data on your behalf by sending an email to privacy-dept @ Project Guild.com (remove spaces when sending email) from the email address associated with your account. 10.2 The Right to Object to or Restrict the Processing of Your Personal Data If you have any queries or complaints about how we process your Personal Data we encourage you to contact us here. Alternatively, if you do not wish to do this you may make a formal request to object to, or restrict, processing of your Personal Data by Project Guild. For example, you have the right to object to the legitimate interest processing of your Personal Data by Project Guild for marketing purposes. In order to do so please send an email to privacy-dept @ Project Guild.com (remove spaces when sending email) from the email address associated with your account. 10.3 Opting Out of Marketing Messages and Withdrawing Consent If you no longer want to receive marketing materials from us based upon your Personal Data, there are a number of options available to you. If you wish to opt out of a particular marketing email from Project Guild, you may do so by clicking “unsubscribe” (or an equivalent action) where applicable. Please note that this will only opt you out of that particular marketing message. If you wish to adjust all your job alerts, you can click on “edit this job alert” (or an equivalent action) to adjust your subscriptions. You can also access and adjust your subscriptions (for job alerts, recommended jobs, and other notifications) from your account dashboard, or contact Project Guild Customer Support to do so. In addition, you may opt out of all marketing messages or withdraw your consent from any consent-based processing by sending an email to privacy-dept @ Project Guild.com (remove spaces when sending email). In your message, please detail which activities from which you wish to opt out or withdraw your consent. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws. Finally, please note that we may still send other messages to you, such as administrative messages. 10.4 The Rights of Access to and Portability of Your Personal Data Project Guild users are able to access most of their Personal Data held by Project Guild on the Site, and if you have any queries or complaints we encourage you to contact us here. Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by Project Guild. In order to do so, please send an email to privacy-dept @ Project Guild.com (remove spaces when sending email) from the email address associated with your account, and paste the following sentence in your email: “I am requesting to access my personal data.” Project Guild will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties. If you have interacted with Project Guild using more than one email address, please send a subsequent from the additional email addresses so that we may provide this personal data as well. 10.5 The Right to Delete Your Personal Data Project Guild users are able to edit and update most of their Personal Data held by Project Guild on the Site, and if you have any queries or complaints we encourage you to contact us here. Alternatively, if you do not wish to do this, you may make a formal request to delete your Personal Data held by Project Guild. In order to do so, please email to privacy-dept @ Project Guild.com (remove spaces when sending email) from the email address associated with your account, and paste the following sentence in your email: “I am requesting to delete my personal data.” Once your request has been confirmed, Project Guild will initiate the necessary steps to execute this exercise, including the deletion of your Project Guild account. Where the deletion request relates to Personal Data that you previously requested be made public on Project Guild (e.g. a Software Engineer posting a public resume), we will make reasonable efforts to inform any other controllers of this request. If you have interacted with Project Guild using more than one email address, please send a subsequent from the additional email addresses so that we may delete this personal data as well. PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with Project Guild using the same email address. If you simply wish to close your account, please click the “close my account” button in your account page. Additionally, if you use Project Guild Apply for an application or take any other action on the Site using the same email address associated with your deletion request, you may not receive certain communications associated with those actions from Project Guild or other Project Guild users. 10.6 Some Limitations Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of Project Guild confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by Project Guild and only imposed to the extent permitted by applicable law. 11. Personal Data from Individuals in the EEA and Switzerland 11.1 Privacy Shield Principles and Framework Project Guild Ireland transfers certain Personal Data to Automate My Startup Incorporated in the U.S.. Automate My Startup Incorporated, including its subsidiary Prehire, Inc., complies with the EU-U.S. Privacy Shield Framework (which applies in all EEA countries) and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union (including all EEA countries), the United Kingdom, and Switzerland to the United States. Project Guild has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity, and Purpose Limitation, Access, Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. 11.2 Principle of Onward Transfer In the context of an onward transfer of data to a third party, a Privacy Shield organization has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Project Guild shall remain liable under the Principles if its agent processes such Personal Data in a manner inconsistent with the Principles, unless Project Guild proves that it is not responsible for the event giving rise to the damage. 11.3 GDPR Protections Project Guild Ireland’s transfers made according to the Privacy Shield Framework are performed based on agreements that also incorporate the protections and requirements provided for under Chapter V (and Article 28, where appropriate) of the GDPR. This incorporates EU data protection requirements to ensure adequate protection of such personal data transfers. 11.4 Independent Dispute Resolution For Individuals in the EU and Switzerland In compliance with the US-EU (applicable in all EEA countries) and Swiss-US Privacy Shield Principles, Project Guild commits to resolve complaints about your privacy and our collection or use of your Personal Data. Individuals in the EEA or Switzerland with inquiries or complaints regarding this Privacy Policy should first contact Project Guild at: Project Guild Privacy Program, Director of Privacy, Automate My Startup Incorporated, 6433 Champion Grandview Way, Building 1, Austin, TX, 78750, USA, or by emailing privacy-dept @ Project Guild.com (remove spaces when sending email). Project Guild has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a nonprofit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. There may be a possibility, under certain limited conditions, for individuals in the EEA or Switzerland to invoke binding arbitration before the Privacy Shield Panel. 12. General Inquiries and Complaints 12.1 Contacting Project Guild You may contact Automate My Startup Incorporated at 6433 Champion Grandview Way, Building 1, Austin, TX, 78750, USA, and you may contact Project Guild Ireland Operations Limited at 124 St. Stephen’s Green, Dublin 2, Ireland; or you may contact either company via our Site contact form. If you would like to contact Project Guild’s Data Protection Officer, please send an email to privacy-dept @ Project Guild.com (remove spaces when sending email). 12.2 Complaints If you believe your data protection rights have been infringed by Project Guild, you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction. For example if you are in the EEA, Project Guild’s main establishment in the EEA is Project Guild Ireland Operations Limited in Ireland, and it is regulated by the Irish Data Protection Commission, in which case you should consult this link for these purposes. If you are in the EEA or Switzerland and have a complaint with respect to transfers and processing performed in accordance with EU-US (applicable in all EEA countries) and Swiss-US Privacy Shield Principles then you may avail of independent dispute resolution, as detailed in section 12 of this Privacy Policy. 13. Your California Privacy Rights Under California’s “Shine the Light” law (Civil Code section 1798.83), California residents have certain rights regarding the disclosure of their Personal Data to third parties for their own direct marketing purposes. Project Guild’s policy is not to disclose your Personal Data to third parties for the third parties’ direct marketing purposes if you have exercised your option to prevent that information from being disclosed to third parties for those purposes. If you wish to not have your personal information shared for those purposes, you may request that Project Guild delete your Personal Data by following the steps outlined in Section 10 of this Privacy Policy. Other residents: You may make a verified request to Project Guild regarding your Personal Data. While Project Guild does not sell your Personal Data, you can nonetheless make a formal request to delete your Personal Data held by Project Guild. This process is detailed in Section 10 of our Privacy Policy, which also describes the designated address information for making requests to Project Guild regarding your Personal Data.