Privacy and Data Handling Policy
Short summary: Please allow ProsperCare LLC (“ProsperCare”) to emphasize the principles that underpin our data privacy and security. These positions are the precursors to trust in any relationship. We recognize that you will only be successful in your mission and ProsperCare will only be successful helping you, if we build trust together. It is our mission to be your trusted steward of data so that we are enabled to better serve people and connect them to opportunities which will help everyone honorably achieve their goals. This mission is fulfilled by continuous learning from data that drives key insights which requires aggregating and using certain data, some of which is provided by you. Accordingly, we take our role as steward of the data and insights with the highest level responsibly. For that reason, we have created the detailed policy set forth below.
- Introduction to ProsperCare Services
Most of the information that we collect occurs on our platforms (“Platforms”) and from related applications, and potentially as well, from data suppliers and partners, and occasionally from our Clients. To learn more about the information that we collect (as opposed to the information we use in providing our services), please go to the Section titled “The Information We Collect On Our Platforms.”
To learn about your messaging and marketing choices and how to opt out of our databases, please go to the below section titled “Your Choices.”
- The Information That We Receive and Use
ProsperCare receives information from candidates, clients and from third parties that it trusts. It uses this information to provide our Services and to create insights to improve our offerings. The types of information we receive or maintain for any purpose (all of which is referred to in this Policy as the “Information”) may include any or all of the following:
- Contact information such as first, middle and last name, email address, and telephone number;
- Information related to candidates expressed interest in certain job roles, such as their work history, education, certifications, etc.;
- Information related demographics, or other personal traits and characteristics;
- Information derived from location information (such as data and unique identifiers “UID” collected, for example from mobile app publishers);
- We may sometimes combine elements of the above information, or work with other companies that provide us the expertise to understand our customers, clients, and others and who better target their messaging; and
- We may also collect certain information when you visit our website, https://prosper.care/privacydata/ as described in the section title “The Information We Collect on Our Platforms.”
- Our Services, and How We Use Information
We use and make available Information for a variety of purposes, but primarily to provide, improve and maintain our Services. For instance, we may use the Information we receive for the following purposes:
- We help our Clients to understand their Candidates and potential Candidates and tailor and target messaging campaigns and communications. These communications and may be delivered across multiple channels, including mobile and social media. We may provide this assistance simply by delivering Information to Clients, or we may provide additional analytics services;
- We may enhance our efforts, or to help Clients measure the effectiveness of their efforts (online and offline), such as by determining which messages are most likely to be seen or opened by which types, or which types of messages are most likely to lead to action on the part of Candidates;
- We may use Information to help us or our Clients match common identities or characteristics across different channels, such as (just for example) to use an email list to market to those same target candidates through social media or other channels;
- We sometimes create data segments – categories of people (or device users) grouped together based on similar inferred interests or preferences (“Data Segments”). These may sometimes be “modeled” by drawing inferences and finding commonalities among large datasets. The Data Segments could be matched to a person, household, or an online identifier; for instance, we may categorize a person or household as having particular interests, or being a member of a certain profession.
- We may provide other data services involving any of the above data components.
- Sometimes, we may use Information and Data Segments to help Clients (including other data platforms) perform “cross-channel” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels.
The above is not necessarily an exhaustive description of the ways we may use Information or offer our services. However, we always try to use Information in responsible ways and to work with legal and responsible providers, and to help us and our Client communicate in ways that are relevant and useful.
- The Information We Collect On Our Platforms
Our Platforms, including our Website, are principally directed to those who may wish to use our services, but we of course welcome potential Clients, Candidates, consumers and others interested in our Services. When you access us through our Platform or contact us by email, we may collect the following information:
- Personal Information. If you provide Information through our Services or Website, such as to request more details or download materials, sign up for a newsletter, event or service, or log in to a service or application we provide, we may request and you may provide certain Information to us. We may use that Information for any business purpose, including to administer your account and provide you services, to send you surveys, communications or emails, to respond to your inquiries, and to send marketing and Services updates. We may also use it to analyze how customers are using our Platforms or Services.
- Passively Collected Information. Like many other companies, we may collect information automatically when you visit our various Platforms or use our Services. This may include:
- The type of browser and operating system you have used to access the Website, a time-stamp, and other browser or device information;
- Your IP address (which is a number automatically assigned to your computer when you access the Internet and can be used to derive your general geographic location);
- Your clickstream data and any URL referral information (such as any Website or social media platform that referred you to our Platforms);
- What part(s) of our Platforms you visit, click and view, and how long you view it;
- A unique identifier, which we may associate with a cookie, device ID or similar technology.
We may collect or store the above information by using web beacons, and similar technologies, and may target or retarget messaging to you using those device identifiers, or similar technologies. We may combine any information including Information you provide to us.
See below under “Your Choices,” to see how you can, at any time, unsubscribe from our emails by accessing the “opt out” or “unsubscribe” (or similar) link we provide in the footer of the emails we send about our own Services. Keep in mind, however, that even if you delete your account, we may retain your Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements and policies, and take other actions permitted by law. Note that even if you unsubscribe or opt-out, we may still send you communication updates related to your prior use of our Services.
- How We Work With and Share Data With Third Parties
- Agents and Service Providers: We may share the Information with agents and service providers who work on our behalf to help us provide our Services to Clients. These parties may, for instance, host, analyze, model, maintain or otherwise handle the information we receive and use in providing our Service.
- Partners: We may share the Information with business and data partners or with Clients, to help provide our or their services to clients, for instance to combine or connect data, build or model datasets, send marketing or communications, analyze data or ad campaigns, or perform billing and collection services.
- Corporate transfers: If ProsperCare or its significant assets are purchased by another entity, our Information will likely be transferred to that entity, including for due diligence prior to any such potential purchase.
- Affiliates, Parents and Subsidiaries: We may share some or all of the data in our possession with affiliated or subsidiary companies, including our corporate investors and board members.
- As Required by Law or to Protect Any Party: ProsperCare may disclose data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to government requests, government or civil subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or our safety or that of a Client or any other party.
- Data We Collect on Our Platforms. We use Information that you provide to us on our Website or Platforms to market our Services and we may use this data for our business purposes. For instance, if you provide us with your name and email address, we may put you into our customer database and send you information about our company, our Services, or events or offers aligned with your previous interests.
This section provides more information about that which we, our Clients and our business partners may use, and how they work.
- Pixels or web beacons. Pixels or web beacons may also communicate information from your Internet browser to a web server. Pixels can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the Web beacon, the IP address of your computer, and the URL of the web page from which the Web beacon was viewed.
- Identifiers (“ IDs”). Unique identifiers may be associated with a device, e.g., iOS “IDFAs” and Android “IDs.” We or our partners may link these IDs to applications you use, precise location information, or your IP address, in order to better target communications or messaging, or to gain insight about users’ locations or traffic patterns.
We sometimes work with third parties to provide or complement our Services. These partners may set and access their own pixel tags and similar technologies on your device. These partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these IDs. Some of these partners may also associate online IDs (or other device identifiers) in order to associate use identities across browsers, devices, or technologies.
Please note that we have no control over the technologies, such as the cookies and pixels, that our partners or Clients use.
- Your Choices
Opting Out of Our Services. You may send an email to us at email@example.com, and reference ‘My Data Privacy’ to opt out of Our Services. If you do so, please include the following information in your email: (a) first and last name, and (b) Your phone number on file with us. You may also provide us with other names by which you are known — which may help us to opt you out even if we have not yet acquired your current information. If you decide to opt out in this way, we will stop using data in our database to help our customers send or tailor ads and content to you, including through email, direct mail or online display marketing. We will retain the information you provide to us in order to perform this suppression.
Please note that opting out in this way will not remove you from our Clients’ databases, only data in our own database – so other companies that we work with may still send messages, offers and content to you. We may also retain certain information for products that involve risk, compliance or anti-fraud measures.
- Opting Out of Online Targeting. We may sometimes work with third party ad platforms that employ “interest based advertising,” to targeted to perceived user interests gained across websites and over time. If you wish to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we recommend visiting the opt-out information offered by clicking here to direct to the Network Advertising Initiative.
- Opting Out of Mobile Targeting. You may consult your mobile device’s “settings” to learn how to opt out of or decline mobile “cross-app” messaging, which is the mobile equivalent of “interest-based messaging” described above.
The Information that we receive and retain is generally stored on servers in the United States. If you are reviewing this Policy or accessing our Services from another country, the privacy laws in the United States may be different from or less protective of the laws in your country, or in the country in which the Information originated. Please don’t send us Information if you don’t have the right to do so, or if you have concerns about U.S. privacy laws.
If you have questions or concerns about ProsperCare privacy efforts or data products, please contact us at:
5871 Glenridge Drive, Suite 450
Atlanta, GA 30328
Updated: November 10, 2020