LAST UPDATED: November 2, 2023

Suited Inc. (“Suited”) is committed to safeguarding your information. We understand the importance of privacy and want you to make an informed decision about sharing information with us when visiting our website and using our services.

This privacy policy (“Privacy Policy”) describes the services offered through the Suited website at www.wellsuited.com (the “Site”) and how we collect, use, share, and protect personal information we obtain through the Site. We will refer to the Site and related services offered through the Site as the “Services.” This Privacy Policy applies to all visitors, users, and others who access the Services. Please read the Privacy Policy carefully to understand our practices regarding your information and how we will treat it. By visiting the Site and/or using the Services, you acknowledge that the collection, use, and sharing of your information will take place as described in this Privacy Policy.

So we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean information about an individual that (either by itself or when combined with information from other available sources) allows that individual to be identified, including, your name, address, telephone number, or e-mail address. When we use the phrase “Anonymized Information” in this Privacy Policy, we mean information that does not allow for the identification of an individual or is not associated with or linked to your Personal Information. Anonymized Information does not enable identification of or contact with individuals.

If you have questions regarding the Privacy Policy or about Suited, please contact us by email at support@wellsuited.com.

1. INFORMATION WE COLLECT

We collect information in several ways to match qualified candidates with employers and to enhance your experience with Suited.

INFORMATION YOU GIVE TO US

To create an account, you provide Personal Information including your name, email address, and a password.

We also collect data and Personal Information from you when you provide or upload it to the Services, such as when you fill out a form, submit a resume or other document, or respond to a survey or questionnaire. This can include your mobile phone number, demographic data, resumes/CVs, personality and cognitive ability assessments, background information, location data, current and former employment data, GPAs, and standardized test scores. With respect to “demographic data”, namely information relating to age, gender, and ethnicity, the provision of such information is entirely optional.

We do not collect, and you should not provide to us, data such as protected health information, financial information,  or social security or other government-issued identification number. Further, while we do offer you the option to provide some age-related information (which information permits us to conduct anti-bias testing of the Services), we do not collect and you should not provide to us your full date of birth.

INFORMATION FROM OTHERS

We collect data and information that others provide when they use our Services, including information about you.

Service Provider Information
We may use service providers to log usage data about you and your computer or mobile device, and how you use and interact with the Services, such as when you view or click on ads or perform a search. For example, when you access the Services, we may use log-ins, cookies, device information, and internet protocol (“IP”) addresses to identify you and log your use. We collect this technical data to analyze usage trends and give us more information about how people use the Services to better the user experience.

From Partner Companies
We may receive Personal Information about you if you interact with and/or apply to one or more of the employers or prospective employers having a relationship with Suited (each a “Partner Company”).

COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES

Like many online services, we may use cookies, web beacons, or other similar technologies to collect information depending on the Services you use. These technologies help us make the Services and your experience better. For example, we use cookies to see which of our Services visitors use and we use web beacons to determine whether users open or act on our communications. You can control cookies through your browser or operating system settings, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our Services.

DO NOT TRACK

At this time, we do not have a system to respond to Do Not Track requests.

2. HOW WE USE YOUR INFORMATION

We use the data that we have about you to provide, support, personalize, and make our Services more relevant and useful to you and others. How we use your information will depend on the Services you use.

We may use the information we collect from and about you to: (1) process, facilitate, and administer your account; (2) provide and deliver services that you request; (3) allow you to search for Partner Companies; (4) allow you to interact with and/or apply for employment at Partner Companies; (5) communicate with you, including about our Services and policies, to provide customer support, to send marketing communications, and to respond when you contact us; (6) create Anonymized Information; (7) operate, maintain, and improve our Services; (8) to deliver ads; and/or (9) to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity. To the extent we deliver marketing emails, you may change your communication preferences to opt out of marketing emails, but please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

Please note that our Services involve evaluating your candidacy for a job by considering the information you provide through our Site. Our platform helps our Partner Companies understand you as an individual by using machine learning to analyze your profile and match it with attributes shown to drive success at those Partner Companies and/or in their industry.

If you do not provide the information requested, we may not be able to provide some or all of the Services you have requested, as the information required (1) for contacting you is necessary for us to keep in touch with you and provide the Services; and (2) to complete a profile and assessment is necessary for our prediction models to evaluate your employment candidacy.

Please note that the demographic questions on gender, ethnicity, and age are optional; they include the option not to supply such information.

3. HOW WE DISCLOSE INFORMATION

Candidates use the Services to connect with Partner Companies. We make this possible by disclosing your information to one or more of our Partner Companies, at your direction and with your consent according to your account settings. We may disclose your information (1) exactly as you provide it to us; (2) in a manner consolidated but not substantively altered by us; or (3) as an input into the service we provide to Partner Companies to generate a proprietary result or score through our technology’s analysis of your information versus confidential information provided by or on behalf of such subject Partner Company. Each of the foregoing may be disclosed by us as described in the following paragraph, and the forms of your information described in (1) and (2) in the preceding sentence, as well as any of your information inputted to as described in (3), are considered your Personal Information. In addition, we may share with third parties Anonymized Information that we create from the information we collect from and about you – that is, information we strip of your name, contact information, and/or any other information that could permit you to be identified as an individual. Anonymized Information is not considered your Personal Information.

We may disclose the Personal Information we collect from and about you (1) with Partner Companies, at your direction and with your consent based on your account settings; (2) for legal and safety purposes, including in response to lawful requests by public authorities to meet national security, law enforcement, or other requirements; (3) with a new owner if the ownership or control of all or part of our Services changes; and/or (4) with third parties we contract with to perform functions related to the Services (“Service Providers”). Service Providers will have access to your Personal Information needed to perform their business functions, but may not use or share that Personal Information for purposes outside the scope of their functions related to the Services.

Please note, we will rely expressly on your direction and consent with respect to the disclosure of your Personal Information, including but not limited to disclosure of Demographic Information (the provision of which is entirely optional), to one or more Partner Companies. This consent can be withdrawn at any time, but once the information has been passed to a Partner Company, that information cannot be retrieved.

We do not sell or share your Personal Information except as provided in the preceding paragraph and we do not use or disclose your Personal Information for ad targeting by third parties.

Please also note that following the supply of information listed in (3) above, we may produce the result or score through our technology, and store the information, as well as the results and scores, acting in the capacity as service provider or data processor for the relevant Partner Company, and subject to the direction and control of such Partner Company in the processing and use of such information.   Such information is therefore not subject to this policy, and the relevant Partner Company should be contacted in relation to such material.

4. LINKS TO OTHER SITES

The Services may contain links to other third-party sites. Any information you provide on those sites is subject to that third party’s privacy policy. Our Privacy Policy does not apply to such sites, and we are not responsible for the privacy and security practices and policies of those third-party sites.

5. CHILDREN

The Services are not directed to children and children are not eligible to use the Services. We do not collect or maintain Personal Information from individuals we actually know are under 16 years of age, and no part of the Services is designed to attract individuals under 16 years of age. If we later learn that a user is under 16 years of age, we will take steps to remove that user's Personal Information from our databases and to prevent the user from utilizing the Services.

6. RETENTION

As part of our Services for Partner Companies, we regularly build and update predictive models which are used by Partner Companies to evaluate your employment candidacy. Every time a model is built or updated, we must reevaluate your employment candidacy using the new model and the information you have provided through the Site. Therefore, we retain the information you provide as long as you have an active account with Suited.

If you request to delete your account, we will retain your information for a period of one (1) year to allow you to reinstate your account in case you change your mind and so that we may ensure compliance with our Terms of Service. After a period of one (1) year, your information may be anonymized by removing your Personal Information. Your Personal Information will then be deleted and any Anonymized Information will be included in our statistical database.

If you do not log in to the Suited Site for a period of five (5) years, we will consider your account inactive and your information will be anonymized by removing your Personal Information. Your Personal Information will then be deleted and the Anonymized Information will be included in our statistical database.

7. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to protecting the security of your Personal Information. While we take steps to help ensure the integrity and security of our network and systems, including employing certain physical, administrative, and technical security measures, we cannot guarantee our security measures.

8. INTERNATIONAL DATA TRANSFERS

Suited is headquartered in the United States, and our Site and Services are hosted in the United States. We have Partner Companies and Service Providers both in the United States and in other countries, including outside the European Economic Area (“EEA”). Note that by entering into the Terms of Service, to the extent you consent to us sharing your information with Partner Companies outside of the United States, you are instructing us, as part of our contract with you, to transfer your Personal Information, on your behalf, to those Partner Companies in accordance with this Privacy Policy. Also, your Personal Information may be transferred to and processed in other countries where our Service Providers operate. This means that when we collect your Personal Information, we may process it in any of these locations. We employ all appropriate technical and organizational measures in connection with such transfers to ensure a level of security for your Personal Information that is appropriate to the risk.

9. NOTICE TO california CONSUMERS

Statutory Category(ies) of Personal Information

Source of Personal Information

Purpose of Collection

Categories of Third Parties to Whom We May Disclose the Personal Information

Identifiers (e.g., contact information)

Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, education, employment history)

You

To process, facilitate, and administer your account

To provide and deliver services that you request

To you to interact with and/or apply for employment at Partner Companies

To communicate with you, including about our Services and policies, to provide customer support, to send marketing communications, and to respond when you contact us

To create Anonymized Information

To operate, maintain, and improve our Services

To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity

Partner Companies

Service Providers

Authorities/Law Enforcement

Business transferees

Characteristics of protected classifications under California or federal law

Sensitive personal information

You

To process, facilitate, and administer your account

To provide and deliver services that you request

To you to interact with and/or apply for employment at Partner Companies

To create Anonymized Information

To operate, maintain, and improve our Services

Partner Companies

Service Providers

Authorities/Law Enforcement

Business transferees

Education information

You

To process, facilitate, and administer your account

To provide and deliver services that you request

To you to interact with and/or apply for employment at Partner Companies

To create Anonymized Information

To operate, maintain, and improve our Services

Partner Companies

Service Providers

Authorities/Law Enforcement

Business transferees

Inferences

You

Automatic collection

To process, facilitate, and administer your account

To provide and deliver services that you request

To you to interact with and/or apply for employment at Partner Companies

To create Anonymized Information

To operate, maintain, and improve our Services

To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity

Partner Companies

Service Providers

Authorities/Law Enforcement

Business transferees

Professional or employment-related information

You

Partner Companies

To process, facilitate, and administer your account

To provide and deliver services that you request

To you to interact with and/or apply for employment at Partner Companies

To create Anonymized Information

To operate, maintain, and improve our Services

To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity

Partner Companies

Service Providers

Authorities/Law Enforcement

Business transferees

Internet or Network Information

Geolocation information

You

Automatic collection

To process, facilitate, and administer your account

To provide and deliver services that you request

To operate, maintain, and improve our Services

To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity

Service Providers

Authorities/Law Enforcement

Business transferees

As a California resident, you may have the following rights provided by the California Consumer Privacy Act (CCPA):

  • Information: You can request the following information about how we have collected and used your Personal Information during the past 12 months: categories of Personal Information we have collected about you; categories of sources from which the Personal Information has been collected; the business or commercial purpose for collecting your Personal Information; the categories of third parties with whom we have shared your Personal Information; and the specific pieces of Personal Information we have collected about you.
  • Access Data: You may have the right to receive a copy of Personal Information we have collected about you over the past 12 months.
  • Request Deletion of Data: You may request that we delete information we have collected about you.
  • Non-discrimination: You may have the right not to be discriminated against for exercising any of these rights.

Opt-out rights. We do not sell or share your Personal Information for purposes of CCPA, so we don’t have an opt out.

10. NOTICE TO USERS IN THE EU AND UK

The EU General Data Protection Regulation, the UK General Data Protection Regulation (both referred to collectively as “GDPR”) and associated legislation and regulations provide rights to certain individuals located in the European Union and the United Kingdom.

We, Suited, is the controller of your Personal Information covered by this Privacy Policy for purposes of GDPR. The following legal bases apply to the ways in which we use individual’s Personal Information set out in sections 2 and 3:

  1. We process Personal Information on the basis of our performance of our contract with the individual, or in order to create such a contract. Our contract with the individual requires us to collect their data, in the form of answers provided to our questionnaire, and to transfer the same as set out in this policy and the Terms of Service.
  2. We will rely on the individual’s direction and consent with respect to (1) the processing of Demographic Information (as defined above) (the provision of which is entirely optional), and (2) the disclosure of Personal Information, including but not limited to Demographic Information, to one or more Partner Companies. This consent can be withdrawn at any time, but once the information has been passed to a Partner Company, that information cannot be retrieved.
  3. We also process the information provided by an individual in our legitimate interests in: (a) ensuring our business is conducted legitimately and to a high standard; (b) ensuring that accounts created comply with the user terms; and (c) marketing our Services.

We do not make any decisions about you by automatic means.

In addition, if you are based within the EU or the UK, in certain circumstances you may also have the following rights (subject to exemptions under applicable local laws) in relation to your Personal Information which we control:

  1. Right to access: the right to request certain information about, access to and copies of certain of the Personal Information about you that we are holding (please note that you are entitled to request one copy of the Personal Information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
  2. Right to rectification: the right to have your some of your Personal Information rectified if it is inaccurate or incomplete;
  3. Right to erasure / “right to be forgotten”: where the processing of your information is based on your consent, and such consent is withdrawn, or where the Personal Information is no longer required for the purpose for which it was collected, the right to request that we delete or erase your Personal Information (however, this will not apply if where we have legitimate interests in retaining limited information to prevent account abuse, if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
  4. Right to restriction of use of your information: the right to stop us from using your Personal Information or limit the way in which we can use it;
  5. Right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
  6. Right to object: the right to object to our use of your Personal Information including where we use it for our legitimate interests or for marketing purposes.
  7. Right to lodge a complaint about us to a supervisory body in your country of work or residence (for instance, the Information Commissioner’s Office in the UK).

11. CHANGES TO OUR PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we make any changes, we will change the Last Updated date above. We also may provide additional notice, as applicable, depending on the type of change. If you object to any changes, you may stop using the Services. Your continued use of the Services after we publish or otherwise provide notice about our changes to the Privacy Policy means that you have read and understood the updated Privacy Policy.

Questions regarding this Privacy Policy and/or requests in relation to any of the data rights described above should be sent to: support@wellsuited.com.