Effective Date: March 30, 2023.

1. Introduction and Overview.

This Privacy Policy provides a comprehensive description of how Hive Diversity d/b/a HelloHive (“HelloHive,” “we,” “our,” or “us”) collects, uses, and discloses information about you as well as your rights and choices regarding such information. It applies to any online location that links to this Privacy Policy (the “Service”).

This Privacy Policy does not govern information we process on behalf of the employers we work with. For details about the processing of Employer Data, please see the “Information from Our Partner Employers” section below.

By using the Service or interacting with us offline, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are a Nevada resident, a California resident, or a Virginia resident, please see the additional disclosures at the end of this Privacy Policy.

2. Information Collection.

A. Information You Provide.

We collect information about you when you use the Service, including information you provide when you register an account, update your profile, access our content, make a purchase, participate in a promotion, contact customer support, or apply for internships, jobs, and other opportunities. The categories of information we collect, and have collected in the past 12 months, include:

Contact Data, including your first and last name, email address, postal address, and phone number.

Account Credentials, including your username, password, password hints, and
information for authentication and account access.

Demographic Data, including your age, gender, and country.

Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.

Profile Data, including your profile picture, interests, inferences, preferences, and favorites. When you complete your profile, you have the option to share with us additional information, such as details about your personality, lifestyle, interests, employment and education history, and other self-identified diversity details about you and your background. To add certain content, like pictures or videos, you may allow us to access your camera or photo album, or your other social media profiles. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

Content, including content within any messages you send to us (such as feedback and questions to customer support).

Employment Data, including your employment and education history, extracurricular activities, transcript, writing samples, references, eligibility for employment, status underprotected classifications, and updates to your employment status or other information in your profile.

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

B. Information Collected Automatically.

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect, and have collected in the past 12 months, include:

Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.

Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.

Non-precise Location Data, such as location derived from an IP address or data that indicates a city or postal code level.

The types of tracking technologies we use to automatically collect information include:

Log Files, which are files that record events that occur in connection with your use of the Service.

Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code).

Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, see the “Analytics” and “Your Rights and Choices” sections below.

3. Information from Our Partner Employers.

We provide products and services to our partner employers including candidate placement services, and collect and process information about individuals (including through tracking technologies) at the direction of those employers (“Employer Data”). Employer Data includes data that you choose to share with an employer when you apply to an opportunity (which may include contact data, demographic data, content, employment data, and other information), service use data, device data, and location data, among other information. Our partner employers may also share data with us regarding your application, including your candidacy and application status. Our processing of Employer Data is governed by the terms of our service agreements with our clients, and not this Privacy Policy. In the event that we are permitted to process Employer Data for our own purposes, we will process the Employer Data in accordance with the practices described in this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.

For further information on your rights and choices regarding Client Data, see the “Your Rights and Choices” section below.

4. Information from Other Sources.

We also collect information from other sources. The categories of sources from which we collect information, and have collected from in the past 12 months, include:

Data brokers from which we purchase data to supplement the data we collect. Social networks with which you interact.

Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.

Publicly-available sources, including data in the public domain.

5. Use of Information.

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, and for which we have collected and used information in the past 12 months, include:

Operating and managing our Service.

Performing services requested by you, such as responding to your comments, questions, and requests, and providing customer service.

Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

Preventing and addressing fraud, breach of policies or terms, and threats or harm.

Monitoring and analysing trends, usage, and activities.

Conducting research, including focus groups and surveys.

Improving the Service and other HelloHive websites, apps, marketing efforts, products and services.

Developing and sending advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services.

Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.

Fulfilling any other purpose at your direction.

With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

6. Disclosure of Information.

We disclose information we collect in accordance with the practices described in this Privacy Policy. The categories of parties to whom we disclose information, and have disclosed information in the past 12 months, include:

Service Providers: We disclose information to service providers and contractors to process information on our behalf. Service providers and contractors assist us with services such as data analytics, direct marketing, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.

Affiliates: We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes. We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as data analytics, direct marketing, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.

Employer Partners: We disclose information to employers in connection with the services we provide to them. For example, we disclose information to those employers in order to submit a candidate’s application, maintain and administer your accounts, and otherwise comply with the law. We may also disclose information that is aggregated or de-identified with employers, which does not identify you individually. Our employer partners are independent entities and their processing of information is subject to their own privacy policies.

Partners: We disclose information to our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.

Promotions: Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we disclose information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.

Public Forums: We disclose information you make public through the Service, such as information in your profile or that you comment within the Service. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.

Merger or Acquisition: We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Security and Compelled Disclosure: We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.

Facilitating Requests: We disclose information at your request or direction.

Consent: We disclose information with notice to you and your consent.

Notwithstanding the above, we may disclose information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) except as prohibited by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.

7. Other Parties.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.

Some examples include:

Links: Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. Those other services may use cookies or other technologies to collect information on your use of the Services.

Brand Pages and Chatbots: We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Service.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they disclose to us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

8. Analytics.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service.

As indicated above, vendors and other parties may act as our service providers, or incerta in contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

9. Analytics.

A. Account Information.

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you are a California resident, please see the additional disclosures at the end of this Privacy Policy.

B. Tracking Technology Choices.

Cookies and Pixels: Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Do Not Track: Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.

10. Analytics.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

Please note that this opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

11. Communications

E-mails: You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.

Text Messages and Calls: You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of calls.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

12. Children

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The Service is intended for general audiences, and is not directed to users under 16 years old. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at info@hellohive.com. We will remove the personal information in accordance with COPPA. Data Security.

13. Acknowledgement

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

14. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.

15. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.

16. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By email:
info@hellohive.com

By mail:
135 West 58th Street, Suite 4C
New York, NY 10019

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at info@hellohive.com.

17. Additional Disclosures for Nevada Residents.

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at info@hellohive.com.

18. Additional Disclosures for California Residents.

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights California residents.

A. Notice of Collection.

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

Identifiers, including name, postal address, email address, and online identifiers (such as IP address).

Customer records, including phone number, billing address, and credit or debit card information.

Characteristics of protected classifications under California or federal law, including gender.

Commercial or transactions information, including records of products or services purchased, obtained, or considered.

Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.

Non-precise geolocation data.

Employment and education information.

Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the “Information Collection” section above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to manage our Service.  Where we use aggregated information that does not identify you individually, it is no longer personal information.

We do not “sell” or “share” your personal information as those terms are defined by CCPA.

We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.

B. Right to Know, Correct, and Delete.

You have the right to know certain details about our data practices. In particular, you may request the following from us:

The categories of personal information we have collected about you;

The categories of sources from which the personal information was collected;

The categories of personal information about you we disclosed for a business purpose or sold or shared;

The categories of third parties to whom the personal information was disclosed for a business purpose or sold or shared;

The business or commercial purpose for collecting or selling or sharing the personal information; and

The specific pieces of personal information we have collected about you.

In addition, you have the right to correct or delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our Online Form or email us at info@hellohive.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

We acknowledge that you may have rights under the CCPA/CPRA in connection with the personal information we process on behalf of employers. If personal information about you has been processed by us as a service provider on behalf of an employer and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of the employer on whose behalf we processed your personal information. We will refer your request to that employer, and will support them to the extent required by applicable law in responding to your request.

C. Retention.

We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

D. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

E. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

F. Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

For general inquiries, please also feel free to email us at info@hellohive.com

19. Additional Disclosures for Virginia Residents.

These additional rights and disclosures apply only to Virginia residents. Terms have the meaning ascribed to them in the Virginia Consumer Data Protection Act (“VCDPA”).

You have the following rights under the VCDPA:

• To confirm whether or not we are processing your personal data
• To access your personal data
• To correct inaccuracies in your personal data
• To delete your personal data
• To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format
• To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you

To exercise any of these rights, please submit through this Form. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request.

If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [INSERT E-MAIL] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

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