Privacy Policy
This Privacy Policy (“Privacy Policy” or “Policy”) was last modified on September 23, 2022.
AbraSystems LLC (“Abra,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy. This Policy describes:
· The types of information we collect from you or that you may provide when you submit information through this App, our website, via email, phone, or chat, using social media accounts, and other information gathered when you use the Services.
· Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use the App or the Services. When you register an Account with us and each time you log into the App or you use the Services, you agree to the terms in this Policy. This Policy may change from time to time. Your continued use of the App or Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
Except as specifically defined in this Privacy Policy, terms defined in the User Agreement shall have the same meaning herein.
THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT
To provide the Services, we will store, use, and share Personal Information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household, or device (“Personal Information”). In particular, the App and the Services collect the following categories of Personal Information from a User:
Identifiers such as:
Name, date of birth, email address, telephone number, cell phone number, address, profile picture, IP address, MAC address, operating system, device information. YES this information is collected.
Professional or employment-related information such as current or past job history or performance evaluations. YES this information is collected.
Non-public education information such as: education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES this information is collected.
Payment Method Information such as: bank account numbers, credit card or debit card numbers, account details, ACH information, or similar information. YES this information is collected.
To provide the Services (i.e., match Talent with employers), we will also collect inferences drawn from your Personal Information as well as your preferences (e.g. minimum compensation).
The following Personal Information is not currently collected by the App or the Services:
Protected classification characteristics such as: race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO this information is not collected.
Commercial information such as: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO this information is not collected.
Biometric information such as: genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO this information is not collected.
Internet or other similar network activity such as: browsing history, search history, IP address, screen resolution, browser used, operating system and settings, access times, referring URL, information on a consumer's interaction with a website, application, or advertisement. NO this information is not collected.
Geolocation data such as: physical location or movements. NO this information is not collected.
Sensory data such as: audio, electronic, visual, thermal, olfactory, or similar information. NO this information is not collected.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We do not collect Personal Information from you unless you provide it to us voluntarily. You provide us with Personal Information that we collect when creating or modifying your Profile. You may also provide us with Personal Information that we collect if you contact us, whether by chat, email, phone call, or other method. The information that you provide in each case will vary. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers or other sensitive personal data, unless required for the Services.
HOW WE USE AND SHARE YOUR INFORMATION
You authorize us to use the Personal Information we collect to:
(i) provide and improve our App;
(ii) provide the Services;
(iii) solicit your feedback; and
(iv) communicate with you, including about our products and services.
In order to provide the Services, we will share the Personal Information with Clients. When we disclose your Personal Information to a Client, we enter into a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose, except for the purposes set forth in the contract.
Other Users may also view your Personal Information, though you may limit what information is available to other Users.
We receive compensation for the Services, which requires collecting, using, and sharing your Personal Information as provided in this Policy.
We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Personal Information only as necessary to perform their functions and to the extent permitted by law.
We may share some or all of your Personal Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Personal Information may be included in such transaction and transferred in connection with the transaction.
To the extent permitted by law, we may also use or disclose the Personal Information:
(i) to handle and resolve legal disputes, for regulatory investigations, and compliance or to enforce the terms of the User Agreement, this Privacy Policy, or any other agreement or policy governing the App or the Services;
(ii) when required bylaw, court order, or other government or law enforcement authority or regulatory agency; or
(iii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
We may at some time in the future use your Payment Method information to process your authorized payments through the App. In that case, we will share your Payment Method information with a third-party service provider as necessary to process your payment. The third-party service provider will store your Payment Method information; we will not store this information. Storage by the third-party service provider of your Payment Method information is subject to the privacy policies and practices of the third-party service provider and is not subject to the terms of this Privacy Policy. By providing your Payment Method information, you acknowledge and agree to use of such information by the third-party service provider for purposes of processing your payment to us.
THIRD-PARTY LOGIN
If you sign in through LinkedIn or another third-party platform, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that such third-party platform would provide to us through its Application Programming Interface(“API”). Such information may include, without limitation, your first and last name, username, profile picture, headline, unique identifier and access token, and e-mail address. We do not receive or store passwords for your LinkedIn or other third-party platform accounts.
ANONYMIZED AND AGGREGATED INFORMATION
In an ongoing effort to better understand our Users, the App, and our products and services, we may analyze certain information in anonymized and aggregate form to operate, maintain, manage, and improve the App and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
HOW WE PROTECT YOUR INFORMATION
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee and do not guarantee the security of our databases or the databases of the third parties with which we may share such Personal Information, nor can we guarantee that the Personal Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
COOKIES AND APP TOKEN
The App does not place cookies on your device or use cookies to track you outside of the App. However, the App does use an application token(“Token”) when you log into your Account. The App uses the Token to know it is you when interacting with the App and Services. The App is session-limited, meaning that it expires after a certain period of inactivity, unless you renew the Token before it expires, or you log out. A Token will remain on your device after your session in the App expires (or you log out) until you clear your cache/cookies or the Token is overwritten by other data. A new Token is issued for each login session on the App. The App’s ability to issue a Token is critical to its function, so, if you do not agree to the use of a Token, do not use the App.
APP STORES; EXTERNAL WEBSITES
Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, such as Personal Information and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.
MINORS
The App and the Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from minors. If we become aware that a minor is attempting to submit Personal Information, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us Personal Information, please contact us so we can delete it.
CHANGES TO THIS POLICY
We may modify this policy at any time and without prior notice. We will notify you of major changes to how we use your Personal Information prior to implementing them. We may notify you about such a material change by email or prominent notice on our App. By using the App or the Services after we post these changes, you indicate you accept them.
CALIFORNIA RIGHTS WITH RESPECT TO PERSONAL INFORMATION
Shine the Light law. Pursuant to California Civil Code Section1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
Do Not Track Signals. Other than as disclosed in this Policy, neither the App nor the Services track users over time and across third-party websites to provide targeted advertising. Therefore, the App does not operate any differently when it receives Do Not Track (“DNT”) signals from your browser or device.
California Consumer Rights. If you are a California consumer, as defined by the California Consumer Privacy Act of 2018, you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under California law. Any Personal Information we collect is collected for the commercial purpose of effectively providing our Services to you, as well as enabling you to learn more about, and benefit from, our Services. You may exercise each of your rights as identified below, subject to our verification of your identity.
A. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
B. Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible to provide our Services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
C. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy
D. Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete)your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
E. Non-Discrimination. If a California data subject exercises his or her rights under California law, including the CCPA, we shall not discriminate against that California resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action
F.Exercising your rights. If you are a California resident who chooses to exercise the rights listed above, you can:
1. Submit a request via email at privacy@abra.io.
2. Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.
Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request. We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. We may deny your deletion request if retaining the information is necessary for us, our Clients, or our service providers to:
· Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or other wise perform our contract with you.
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
· Debug products to identify and repair errors that impair existing intended functionality.
· Exercise free speech, right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
· Comply with a legal obligation.
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
USERS IN THE EUROPEAN UNION (“EU”) AND AROUND THE WORLD
The App and Services are controlled, operated, and administered by AbraSystems LLC from its office in Florida, United States of America and this Policy is provided in accordance with and subject to applicable U.S. law and the laws of the State of Florida, without respect to its conflicts of law principles. If you are based outside the United States and decide to use the App from your location outside of the United States: (i) you hereby agree to be subject to this notice and waive all privacy-related rights in other jurisdictions that conflict with U.S. law or this Policy and (ii) you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere. You should not provide us with any Personal Information unless you consent to the application of United States law and, where applicable, Florida law, and to the use and disclosure of your information in accordance with the terms of this Policy.
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, AbraSystems LLC operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.
Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.
The Data Controller is:
NAME: AbraSystems LLC
ADDRESS: 2400Maitland Center Parkway, Suite 217, Maitland FL 32751
EMAIL ADDRESS: privacy@abra.io
You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:
· Access. You may email us at privacy@abra.io to request a copy of the personal data our App databases currently contain in respect to you.
· Automated Processing and Decision-Making. You may email us at privacy@abra.io to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
· Correction or Rectification. You can correct what personal data our App database currently contains by accessing your account directly, or by emailing us at privacy@abra.io to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
· Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to privacy@abra.io. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
· Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to privacy@abra.io. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
· Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to privacy@abra.io. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
· Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through the App and the Services by notifying us via email at privacy@abra.io. Using the same email address associated with your Account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties. Withdrawing consent may mean that the App and/or the Services are no longer available to you.
· Erasure. If you should wish to cease use of the Services and have your personal data deleted from the App, then you may submit a request by emailing us at privacy@abra.io. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties. Erasure may mean that the App and/or Services are no longer available to you.
· Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.
HOW TO CONTACT US OR MAKE A COMPLAINT?
AbraSystems LLC controls the processing of Personal Information on its App and in connection with the Services. To exercise your rights, or if you have questions about our privacy practices or need assistance with exercising or understanding your privacy choices, please contact us using one of the following:
Write
258 Southhall Lane, Suite 130 Maitland, FL 32751
Attention
Support/Privacy