Privacy Policy

Thank you for visiting a BOLD LLC and Auxiliant S.à.r.l (“Provider”, “we”, “us”) offering. To help inform our customers (“Customers,” “you” or “your”), we provide this notice (“Policy”) explaining our online information practices and the choices you can make about the collection and use of the data and information you submit (“Information” or “Data”) or we collect through our family of websites that link to this Privacy Policy as well as our other related mobile websites, mobile Provider applications (“mobile apps” or “Provider Applications”), services, browser extensions, tools, and other applications that link to this Privacy Policy (all of these collectively, the “Site”). The Site is operated by BOLD LLC, City View Plaza II, Suite 6000, 48 Road 165, Guaynabo, Puerto Rico 00968. BOLD LLC is the data controller of your Information in the context of the Site.

 

By visiting the Site, you agree that your information will be handled as described in this Policy. Your use of this Site is subject to this Policy and our Terms of Use. Provider’s Terms of Use are incorporated by reference into this Policy.

Privacy Policy Highlights

Please also read our full Privacy Policy

 

Personal Information We Collect

• When you register an account, use our services, download or use any of our mobile apps, use our forum or make a purchase, you voluntarily share certain Information with us, including, but not limited to, your name, email address, address, mobile number, and/or credit card information.

Tracking Technologies

• We use tracking technologies such as cookies to measure usage and provide information that we believe will be of most interest to you.
• We may collect additional information from you if you access our Site through a mobile device (e.g., unique device identifier, device’s operating system, mobile carrier).
• You can also provide us with information when interacting with our content through or linking to third-party social media sites, plug-ins, or applications.

Uses, Retention and Storage

• We and our service providers may store and retain certain information from you for the time and reasons outlined in this Privacy Policy.

Disclosure Information

• By using our Site, you agree that we can share the Information we collect, to the extent permissible by applicable law, with our subsidiaries and affiliates, to our service providers, other entities such as job posting third-party websites and potential  

Your Choices

• You can control how and when you want to receive information from us, you may request deletion of the information we have gathered from you and a copy of the said information. Click here for other information choices.

Access and Review Options

• You can change your information at any time by editing your profile, updating or deleting content that you have posted, or by closing your account.

Update Notifications

• You agree that we can notify you about material changes to this Privacy Policy by posting notices on this Site.

European Economic Area Residents: Special Notice Concerning the General Data Protection Regulation (“GDPR”)

• The Provider complies with GDPR. As such, Provider affords to these data subjects their respective privacy rights to the extent they are applicable.

Residents of the United States: Special Notice Concerning the California Consumer Protection Act (“CCPA”)

• The Provider complies with CCPA as amended by the California Privacy Rights Act and other applicable US state-level data privacy laws. As such, Provider affords California residents and those in states with applicable privacy laws can exercise their respective privacy rights to the extent they are applicable.

Contact

• Questions about this Policy may be sent to privacy@bold.com or as otherwise set forth in this Policy.

Full Privacy Policy

Last Updated: September 5, 2024

1. Scope

Provider is an online destination that provides resume and cover letter building, career tests, salary information, resume and cover letter storage, career enhancing services and other services for individuals seeking to further their career. We do not guarantee employment for any user of the Site. When you use the Site, you are contracting with Provider. By accessing the Site, and the services provided in it or through any of our family of websites that link to this Privacy Policy, including, but not limited to, myperfectresume.com, livecareer.com, and any other Site powered by myperfectresume.com, bold.com, or livecareer.com, you are accessing a Provider offering.

2. Information We Collect About You

Information we collect about you depends on how you use our Site.

(a) Registration, Services and Account Information. You can browse the Site without registering for an account with us in that case we may collect information regarding your device, geolocation data, behavioral, target job and target profile. When you register an account or use certain of our services (including, but not limited to, Site email account(s), Resume Builder, Resume-Check, Resume Guide, Cover Letter Builder, Cover Letter Tips, My Perfect Resume, Resume Review, Resume Writing, Resume Services, Search Jobs), create a profile, create a resume, search for or purchase services, or otherwise engage with our Site, you must provide certain information such as a username and a valid email address, otherwise, you will not be able to create an account. You must also provide payment information such as credit or debit card information, name and billing address in order to purchase services. This information is only associated with your account after you have signed in as a registered user. We will also collect other data you voluntarily provide, such as name, surname, contact data, and information you enter on the Site, when creating documents (for example employment status and education).

(b) Information to Respond to Your Requests. You may give us contact information (for example, your email address) so we can respond to your requests Details of how you can opt-out of receiving communications from us are detailed in the section headed Accessing, Reviewing, and Changing Your Personal Information.

(c) Third party log-in. We may collect some basic information when you access the Site with third-party login credentials such as your name, user name, and your email address.

(d) User Interaction Information. We can also receive other information (e.g., content viewed and information about the advertisements within the content you have been shown or have clicked on, etc.) from your interaction with our Site. To the extent permissible by law of the country of your residence, you agree that we can share your interaction information with, or obtain information about your interaction from, analytics providers, advertising partners, third-party partners, and social media sites      until you withdraw your consent for the purpose of providing or improving our services. Certain information that we may have access to from third-party services providers may be controlled by your privacy settings on that service and by managing your consent. Information that can be passed to analytics providers and advertising partners can be via cookies and tracking technologies. Please see our Cookies and Tracking Technologies Policy for information, including your choices in relation to some of these technologies.

(e) Information from other Sources. To the extent permissible by law of country of your residence, the information we collect can be combined with publicly available information.

 (f) Mobile Information. By agreeing to this Policy you consent that we may collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location and mobile number).

(g) Browser Extensions Privacy Notice and Information We Collect. Provider offers certain browser extensions, including but not limited to the “Apply Tool”, that are all available in certain web browsers such as Google Chrome. When you download a browser extension, we automatically collect certain information from your device or web browser. We automatically collect information from location storage associated with your web browser, including your browsing behavior for career searching activity. We can also automatically record your interactions with certain webpages by accessing local storage associated with your web browser. Each browser extension was made to automatically interact with third-party websites, so we can also collect some information about you when you visit those websites including, clickstream data, operating system being used, the URL of the site you have come from and move to after your visit, data relating to your activities on third party websites (including IP addresses and URLs) via tracking technologies (such as cookies and measurement software), the date and time of your visit and your server’s IP address, the geo-location of your device, and the type of payment you use. We collect this information for statistical purposes to find out how our website and each browser extension is being used. We use this information to evaluate and, hopefully, improve your experience. As an example, when you visit a webpage that supports the autofill function, we can record metadata generated by your web browser that identifies one or more autofill fields that you interact with. In this example, we can also access local storage associated with your web browser to determine information which can be or has been entered into an autofill field. We use your information to facilitate your completion of job applications across the internet, on our websites and third-party websites and to provide advertising and/or other content that we believe can be of interest to you based upon your browsing behavior on the internet.

3. Uses, Retention and Storage

We process your information for the following purposes and legal bases:

(a) Operate our Site and Provide You with Our Services. We use the Information we collect to (i) respond to your questions and requests; (ii) provide customer service (e.g., to fulfill product and service orders made by you, give you information about your account to resolve disputes, problems with your account/profile or the Site, administer a contest, sweepstakes or promotions, or to provide information to third parties at your request such as potential employers, job matching services or third party websites, or other career related services); (iii) personalize your experience by providing content on the Site, including targeted advertising or job-related advertising, that we believe can be of most interest to you; (iv) improve the Site, and; (v) provide you with a safe, efficient, and customized experience. and (vi) share it with third parties that help us deliver career enhancing tools and a wider set of services to help in your career development.

(b) Analyze and Aggregate Non-Personal Information. We use aggregate information about our users and non-personal information to analyze Site and user behavior and prepare aggregated reports.

(c) Prevent Fraud and Comply with the Law. We use information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, establish, exercise or defend a legal claim, and enforce our Terms of Use. We also use information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint handling procedure.

(d) Marketing & Communications. We use your information to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services as described at the time when we collect the information from you, or to contact you for other purposes authorized by law. If you have chosen to participate in some of our career building Services, the information you share with us can be provided to third parties such as (i) resume editors, (ii) employers or recruiters who can contact you about career opportunities, (iii) employers or other individuals or companies  seeking candidates, and/or (iv) other career service providers.

(e) Mobile Data. When you access the Site on a mobile device, we can use the information collected for any purpose set forth in this Privacy Policy. For example, we can use this information to provide you with location-based services, such as advertising, search results, and other personalized content.

To the extent permissible by applicable law, we retain Information for as long as it is necessary to fulfill the purpose(s) for which it was collected, our business purposes, and/or to comply with the applicable laws and regulations.

4. Disclosure

Information we collect can be shared with:

(a) The Provider Corporate Family. We may  disclose the information we collect about you with the Provider’s corporate family (our affiliates and subsidiaries). If we  disclose your information with them, their use and disclosure of your information will be subject to this Policy.

(b) Service Providers. We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, bill collection, payment processing, and site analytics and operations as detailed in Section 8 below).  For a full list of processors and sub processors please contact us by sending email to privacy@bold.com.

(c) Additional Services Requests. On the Site, you can express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request. In order to provide our Services we may share your Information which may involve in some cases a monetary compensation to third parties which help us deliver career development services to you. Your information may be shared with third parties such as CV editors, employers, recruiters or job posting third-party websites, third parties in the career building industry or that are looking to enter into that industry, or other third parties who are interested in receiving information that we collect about you in the Site. You have the option to opt-out from this type of sharing at any time by modifying your settings on your account or contacting our Customer Service team. You may also publish your information by making use of our digital resume tools. In that case, your information may be seen by third parties that use our resume database search engine or through other publicly available search engines, such as Google and Bing.

(d) Legal and Law Enforcement. We may disclose information that we collect if we believe that such action is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

(e) Change of Control. We may share your information if there is a bankruptcy proceeding, if substantially all of our assets are transferred to another company, or if we merge with or acquired by another business entity. If any of these events take place, we will make reasonable efforts to request that the new service provider follows this Privacy Policy with respect to your information.

(f) Ad Networks. On the Site, we work with third parties to serve advertisement, provide us with data collection, reporting, ad response measurement and site analytics and assist with delivery of relevant marketing messages and advertisements. These third parties can view, edit or set their own tracking technologies/cookies.

(g) Analytics Providers. We may disclose information we collected through our Site to our analytics providers such as Google Analytics, to evaluate usage of our Site, and to help us improve our services, performance and user experiences.

(h) To Protect Us and Others. We may share your information where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of our Terms of Use, or this Policy, or as evidence in litigation in which we are involved.

(i) Aggregate and De-Identified Information. We may share information that has been aggregated and de-identified with third parties for marketing, advertising, research, or similar purposes.

(j) Your Consent. By agreeing to this Privacy Policy, we have obtained your consent, when required, for the disclosure of the information we collect.

5. Accessing, Reviewing, and Changing Your Personal Information

Registered users can review and change the Information at any time by accessing their accounts on the Site (through the My Account and My Settings tabs). You should promptly update your information if it changes or becomes inaccurate.

6. Your Choices

EU users: please refer to Section 9 below for your statutory rights under the GDPR.

(a) Opting Out of Promotional Messages. You can choose not to receive our promotional communications by clicking the “My Account” tab and clicking the “My Settings” and “Preferences” tabs. You can also click the unsubscribe link in the footer of any email or newsletter you receive. You can also email us at privacy@bold.com.

(b) Update/Delete or Change Your Resume or Cover Letter. To change or delete your resumes or cover letters that you have uploaded to our site, login to your account and click “Resume” and “Cover Letter” tabs and select edit or delete.

(c) Site Privacy Settings. Information that you disclose while participating on the Site may be public and subject to redistribution by us and any third party that reviews your profile or information that you post. You can change your privacy preferences at any time by login into your account and clicking on My Settings. You can also set your preferences for other Provider services as set forth in Section 5 or by contacting us as set forth in Section 17. Please be aware that Provider is not responsible for the uses, disclosures or copies of your public postings on or through the Site that you make public and that are downloaded by third parties.

(d) Administrative/Transactional Messages for Registered Users and Subscribers Cannot Be Turned Off. As we provide an online service, you cannot opt-out of administrative or transactional emails (for example emails about your transactions or policy changes) for your registered account. If you are a Visitor and would like to opt out from receiving transactional emails click here.

(e) Deletion of Your User Content/Account. You may request that we delete your account and/or certain personal identifiable information we have collected from our systems. You can do so by clicking here by utilizing any of the options made available to you by us throughout the Site for this purpose, or by sending us an email at privacy@bold.com. When you request that your account or that your personal identifiable information is deleted, your resume and profiles will be deleted and no longer available to you or visible to others. However, if the information you provided was previously accessed by others, we will not be able to delete the information from their systems. When you delete your information, we will retain logs of your information along with an archival copy of your information, which is not accessible by you or third parties but which might be used by us for recordkeeping and internal purposes, including enforcing this Policy. To the extent permitted by applicable law, we may retain information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or subscription is terminated or suspended, we may maintain information to prevent re-registration.

(f) Third-Party Ad Network Opt-Out. We may use third-party network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information about you, if you granted your consent.

(g) Other Data Options. Unless otherwise required by the laws of the country of your residence, you may request: (i) a copy of the of the specific pieces of personal identifiable information that we have collected about you in the last 12 months from the date of your request, and; (ii) that we disclose certain information about how we have handled your personal identifiable information in the prior 12 months. You can make such requests, if you have created an account with us, by logging into your account and clicking here, by utilizing any of the options made available to you by us throughout the Site for this purpose, or if you have not created an account, by sending us an email at privacy@bold.com.

(h) SMS. If you opt-in to our SMS alert service, you acknowledge that message or data charges may apply. If you wish to not continue with the SMS alert service, you may opt-out by replying “STOP” to the SMS text you received or contact our customer service team by any of the options available here . Please allow 3 to 5 business days to process your request.

(i) Timing and Third Parties. We will endeavor to comply with your requests as soon as reasonably possible but please note that changes requested of us are not always effective immediately. Additionally, in certain situations, and subject to applicable law, Provider will not be able or obliged to comply with part or all of your individual requests. Please note that we have the right to refuse and/or charge a monetary fee for requests which are manifestly unfounded or excessive.

7. Information You Share on the Site

(a) Public Information. If you participate in Provider services (e.g., resume posting, profile creation, Job Alerts, Digital Resume) that permit you or Provider on your behalf to post your Information on Provider’s searchable databases or  third-party sites (e.g., websites, bulletin boards, personal URLs) by posting information or content (such as by posting photos, creating a Digital Resume or participating in online forums or communities), or when you interact with our Site through social media sites, plug-ins or other sites or applications, depending upon your privacy settings, the information posted will be publicly available and searchable by individuals.  Provider reserves the right to aggregate and /or share that information with third parties to perform our Service. We may not be able to prevent the further use of this Information. You will be able to set your privacy preferences and determine how Public or Private you prefer your account, if you have any questions make sure to contact us. Please also remember to refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices.

(b) Other services. If you use the Site, Provider can create a universal application derived from the information you provide on the Site that will be visible to potential employers and others with immediate needs for prospects  or work with us to provide you with tools to enhance your career as well as visitors to the Site. Therefore, your Site Profile and/or Digital Profile (“Profile”) will be publicly viewable. You can elect to have your Profile restricted by editing your settings preferences on your Dashboard and change your settings from visible to anyone searching on the site, as well as other search engines such as Google and Bing, or featured on other Profiles (“Public”) to only visible to you (“Unpublish” or “Private”) as well as have only some of these features enabled. You agree that employers, other third parties viewing your information and/or Provider may use the contact information you have provided to contact you and you understand that this consent is not a condition to having access to the Site or Provider services.

(c) Scores, ratings and other tools. As part of the Site offering you may interact with tools that provide matching, check and recommendation mechanisms regarding the information you have provided in the system when creating your resume. These tools are computer based algorithms that have been created to help you in your career finding journey and do not ensure that you will get a job offering. When you make use of these tools you also agree and understand that Provider cannot ensure that you will get contacted by an Employer or receive a job offering, even when your resume has received a high “strength” number.  Your use of these tools is completely at your own risk and provides no warranties whatsoever.

8. Tracking Technologies (Cookies)

Depending on your country of residence, when you first accessed this Site you may have been prompted to set your cookie setting preferences.  Your cookie settings will be saved in accordance with privacy laws. Otherwise, when you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site including, but not limited to, video-viewing, site views, key stroke data, mouse movement, scrolling, clicks, and typing (“usage information”). We use tracking technologies (including cookies, unique device identifiers, web beacons/GIFs, embedded scripts, e-tags/cache browsers, cross-device tracking) to collect usage information.  More information about cookies can be found on our Cookie Policy. We can use tracking technologies for a variety of purposes, including:

(a) Necessary. We can use tracking technologies required for system administration, to prevent fraudulent activity, improve security or allow you to make use of shopping cart functionality. We are not required to obtain your consent to tracking technologies that are operationally necessary.

(b) Performance and personalization. We can use cookies or other tracking technologies to assess the performance of the online services, including as part of our analytic practices to improve the content offered through the online services. For example, as set forth in detail in our  Cookies and Tracking Technologies Policy, we use Google Analytics and Inspectlet to perform site analytics.

(c) Analytics. We can use tracking technologies to tell us, for example, whether you have visited the Site before or if you are a new visitor and to help us identify the features in which you have the greatest interest.

(d) Advertising. We can use tracking technologies to deliver content, including ads, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content as well as track the content you access (including video viewing). Further information on this, and your opt-out choices, is in the “Your Choices” section above.

We can also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.

Tracking technologies, such as cookies, are mainly alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. When you visit the Site, we and our business partners may use tracking technologies to enhance your online experience or customize our offerings. For some customers a privacy settings option will be available to set your cookie preferences. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster login process. A few additional important things you should know about our use of tracking technologies (cookies):

• We can offer certain features that are available only through the use of tracking technologies.

• There are two types of cookies: session cookies and persistent cookies. We use both session and persistent tracking technologies. Tracking technologies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You may be able to decline tracking technologies if your browser permits, although doing so can interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.

• We encode and protect the tracking technologies that Provider sets, so that only we can interpret the information stored in them. You can encounter tracking technologies from our third-party service providers, that we have allowed on our Site that assist us with various aspects of our Site operations and services, such as Google Analytics.

• You can also encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another user, there can be a cookie placed by that web page).

• Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

For more information about the use of cookies and similar technologies on our Site please review this Privacy Policy and our Tracking Technologies Policy

 
9. Notice to Residents of the European Economic Area

Provider complies with the General Data Protection Regulation (“GDPR”). As such, Provider affords to all European data subjects their respective data privacy rights to the extent they are applicable including:

(i) right to rectify inaccurate data;

You have the right to obtain from us, the rectification of inaccurate personal information. Considering the purposes of the processing, you have the right to have incomplete personal information completed, including by means of providing a supplementary statement. You may perform this right my login in to your general account settings or by any of the means provided on our Contact Us page.

(ii) right to erasure (deletion of your personal information);

You have the right to request erasure or deletion of the personal information collected by us, only when:  the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; or you withdraw consent on which the processing was based, and where there is no other legal ground for the processing; or you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes; or when  the data has been unlawfully processed, or the personal data has to be erased in compliance with a legal obligation . If you would like to exercise your deletion rights you can do so by clicking here or by sending an email to privacy@bold.com.

(iii) right to restrict processing of your personal information;

You have the right to restrict the processing of your personal data if (i) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data (ii) the processing is unlawful and you oppose the erasure of the personal data, and request the restriction of their use instead; (iii) we no longer need the personal data for the purposes of the processing, unless the processing is required by you for the establishment, exercise or defense of legal claims;

(iv) right of data portability;

You have the right to receive the personal data given to us through the site in a commonly used and machine-readable format – if it was collected in an automated way, and the legal bases of processing was your consent or a contract (for example, if you accepted our terms of service). You may also request us to transfer your information to another provider or controller of data, where technically feasible.

(v) right to withdraw consent,

When you have provided consent to the processing, you may withdraw it at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. This includes your right to withdraw consent to the sharing of your data for monetary compensation with a third party. You can exercise this right by sending a request to privacy@bold.com.

(vi) right to object;

When you object, we will no longer process your personal data unless we can demonstrate compelling, legitimate grounds for the processing that override your interests, rights and freedoms. Where your data is processed for direct-marketing purposes, you have the right to object at any time to the processing of your data for such marketing.

(vii) right to access and to obtain a copy of personal data;

You have the right to obtain from us confirmation as to whether or not your personal data is being processed, and, where that is the case, we will provide you with access to the personal data. If you registered an account on our Site, you can access certain of your personal data within your account. For obtaining copy of other information not available through the site please use link or contact our customer service with your specific request for assistance. If you do not have an account on our Site, please send us an email to privacy@bold.com with your request and one of our agents will make its best efforts to verify whether we have any of your personal data.

(viii) the right not to be subject to a decision based solely on automated processing;

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affect you. This will not apply if the decision: (a) is necessary for entering into, or performance of, a contract between you and us; (b) is authorized by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or is based on your explicit consent.

You also have the right to lodge a complaint with the competent data protection supervisory authority (Article 77 of the GDPR). You can file this complaint both at your place of residence, at your place of work or at the place of the data protection breach you are complaining about. You may also file a complaint with the supervisory authority at our place of representative in Luxembourg.

You can exercise any of these rights by contacting us at privacy@bold.com. Also if you have registered an account on our Site, you can request data access or request data deletion  by clicking this link. In order to safeguard your personal information from unauthorized access, we can ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

We take appropriate measures to ensure adequate protection of the privacy rights of EEA data subjects with respect to personal information that we transfer outside the EEA to a country that is not subject to an adequacy decision by the EU Commission. Please refer to Section 14 for more information about storage and international transfers.

In certain situations, and subject to applicable law, Provider will not be able or obliged to comply with part or all of your individual requests. Please note that we have the right to refuse and/or charge a monetary fee for requests which are manifestly unfounded or excessive, for example due to their repetitive character. If you have unresolved concerns, you have the right to complain to an EU Supervisory Authority. The representative is Auxiliant S.à.r.l. 1A, rue Thomas Edison, L-1445 Strassen, Luxembourg.

We have appointed a Data Protection Officer. You may contact the Data Protection Officer by sending an email to dpo@bold.com.

Providing your information to us is optional, but it can impact our ability to offer the Service to you. For example, if you do not provide your complete personal information, we will not always be able to respond to your request in a timely manner.

We process your information for the following purposes and legal bases:

(a) Operate our Site and Provide You with Our Services. We use the Information we collect as it is necessary for the performance of a contract between you and us in particular to (i) respond to your questions and requests; (ii) provide customer service (e.g., to fulfill product and service orders made by you, give you information about your account to resolve disputes, problems with your account/profile or the Site, administer a contest, sweepstakes or promotions, or to provide information to third parties at your request such as potential employers, job matching services or third party websites, or other career related services); (iii) personalize your experience by providing content on the Site, including targeted advertising or job-related advertising, that we believe can be of most interest to you. Furthermore, we use the information we collect to (iv) improve the Site and; (v) provide you with a safe, efficient, and customized experience;  this is our legitimate interest within the meaning of art. 6(1) f of GDPR.

(b) Analyze and Aggregate Non-Personal Information. We use aggregate information about our users and non-personal information to analyze Site and user behavior and prepare aggregated reports. This is our legitimate interest within the meaning of art. 6(1) f of GDPR.

(c) Prevent Fraud and Comply with the Law. We use information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, and for the purposes of the following legitimate interest: to establish, exercise or defend a legal claim, and enforce our Terms of Use. We also use information in response to requests by government or law enforcement authorities, or in response to complaints where we are under a legal or regulatory obligation to adhere to a complaint handling procedure.

(d) Marketing & Communications. We use your information as it is necessary for the performance of a contract between you and us in particular  to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services as described at the time when we collect the information from you, or to contact you for other purposes authorized by law. If you have chosen to participate in some of our career building Services, the information you share with us can be provided to third parties such as (i) resume editors, (ii) employers or recruiters who can contact you about career opportunities, (iii) employers seeking candidates, and/or (iv) other career service providers.

(e) Mobile Data. When you access the Site on a mobile device, we can use the information collected for any purpose set forth in this Privacy Policy. For example, we can use this information to provide you with location-based services, such as advertising, search results, and other personalized content. This is our legitimate interest within the meaning of art. 6(1) f of GDPR To the extent permissible by applicable law, we retain Information for as long as it is necessary to fulfill the purpose(s) for which it was collected, our business purposes and/or to comply with the applicable laws and regulations. This includes but is no limited to the purposes stated in the previous paragraphs of this Section 9.

(f) Profiling. We use your data to create your professional profile corresponding to your skills, education, experience, interests and preferences. Then, based on the profile created we suggest you how to complete your profile and encourage you to use our other services. We may also suggest you job offers which correspond to your profile, and recommend your profile to employers, which we believe may be looking for candidates with similar to yours experience and  qualifications. Based on your Information we may also provide you with targeted ads.

Please refer to Section 3 for more information about data retention.

10. Notice to United Kingdom (“UK”) residents

Provider complies us the UK General Data Protection Regulation (“UK GDPR”) and affords UK residents their rights in accordance to law. All rights listed on Section 9 shall apply to UK residents respectively. If you are a UK resident and have any questions please contact us by sending an email to legal@bold.com.

11. Third Parties

Our Site can contain links to other third-party websites and Provider can provide products and services that share information with third-party sites for your job search. We are not responsible for the privacy practices or the content of these third-party sites so it is important to familiarize yourself with their privacy policies before providing your Information.

12. Information Security

We maintain appropriate technical, physical, and administrative security measures designed to protect the security of your information against loss, misuse, unauthorized or accidental access, disclosure, copying, use or alteration. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, we cannot guarantee its absolute security. If you would like to contact our Data Protection Officer, please send an email to dpo@bold.com.

13. Children’s Privacy

The Site is a general audience site and it is not intended for children under the age of 16. We do not knowingly collect information via our websites, applications, services, or tools from users in this age group. Our websites are equipped to block the registration of a minor under 16 years old. If you become aware that a child under 16 has provided us with information, please contact us immediately so we can delete such information from our system.

14. Storage and International Transfer

As we operate internationally, and many of our computer systems are currently based globally, for the purposes set out in this Privacy Policy your Information can be stored and processed elsewhere by us, our affiliates or an unaffiliated service provider. The data protection and privacy regulations do not always offer the same level of protection as in other parts of the world, such as the European Economic Area (“EEA”). Nonetheless, we have ensured that our service providers and affiliates have been subjected to strict contractual provisions in their contract with us, including Standard contractual clauses, to guarantee that an adequate level of data protection for your data is met. When you create an account/profile or otherwise provide us with your information, you consent to the collection, storage, use of some tracking technologies as described above, and/or processing of your information, including personal information, in the United States and other countries. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests by any of the means provided in our Contact Us page.

15. Notification Regarding Review and Updates

From time to time and at least once every twelve (12) months we review this Privacy Policy and we may choose to update its terms. The Privacy Policy posted at any time or from time to time via the Site shall be deemed to be the Privacy Policy then in effect. You agree that we can notify you about material changes in the way we treat your Information by placing a notice on the Site. You should check the Site frequently for updates. In addition, we have provided the Privacy Policy Highlights section to offer a summary of the main points of our Full Privacy Policy for your convenience. In the event of a conflict between the Privacy Policy Highlights and the Full Privacy Policy, the Full Privacy Policy will control.

16. UNITED STATES RESIDENTS

Various state regulations require that we provide certain information to consumers about how we handle personal information that we have collected from them.  “Personal information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

(a) Categories of Personal Information that We Collect and Disclose.

We may collect and disclose for a business purpose the following personal information from users:(1) name, contact information and identifiers (real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers); (2) customer records (electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, employment, employment history); (3) protected classifications (characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information) only when voluntarily provided by the customer; (4) purchase history and tendencies (commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); (5) usage data (internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding consumer’s interaction with an Internet website, application, or advertisement); (6) geolocation data (precise geographic location information about a particular individual or device); (7) employment history (professional or employment-related information); (8) education information (information about education history or background), (9) Audio/Visual: audio, electronic, visual, thermal, olfactory, or similar information, and; (10) profiles and inferences (inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).

The list above does not address our handling of personal information that is subject to an exemptions under law.

(b) Consumer Rights. State laws grant consumers certain rights and imposes restrictions on particular business practices as set forth below.

(1) Do Not Sell or Share my Personal Information. The California Consumer Privacy Act (CCPA) affords all California residents the right to opt out of the selling or sharing of their personal information. CCPA identifies personal information as information that identifies, relates to, or could reasonably be linked to a person or his/her household. Provider uses your personal information to perform the contract and provide our Services. When you use our Services, we may drop data collection tools (i.e. cookies, web beacons, and other similar technologies) and share some of your digital activity information with third parties in order to receive information about the performance of our marketing campaigns and the usage of our web sites and applications. Details about how we use your information and for what purposes can be found on our Privacy Policy. You may request us to stop sharing your personal information and we will honor your request for at least 12 months before asking you to opt back in. You have the right to exercise this right personally or through an authorized agent, who will have to provide the necessary evidence to confirm his/her agent status. Your request will be subject to an identification process, and we will not fulfill your request unless you have provided all the information required.

To make a Do Not Sell or Share my Personal Information request, please submit your information using the form available here or by contacting us at privacy@bold.com and following the instructions.

Other US state residents that have Do Not Sell or Share My Personal Information effective regulations, please note that Provider will also honor your Do Not Sell or Share my Information request(s), in compliance with these state privacy regulations.

Our sites detect and comply with the Global Privacy Control (“GPC”) signal for applicable US jurisdictions. By using our website, you acknowledge and agree that we will process your browser’s GPC signal in accordance with the applicable state law requirements. Specifically, we process the GPC signal as a request to not share your information with our advertisers. If a GPC signal is detected from your browser, we will not display a cookie banner during your visit and instead, we will automatically apply the relevant privacy settings to your data according to applicable regulations and pursuant to our Privacy Policy.

(2) Requests for Copy, Correction, Deletion and Right to Know. Subject to certain exceptions, and as a California consumer, you have the right to make the following requests: at no charge, up to twice every 12 months:

(i) Deletion. You have the right to request deletion of personal information that we have collected about you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).

(ii) Copy. Consumers have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months.

(iii) Right to Know. Consumers have the right to request that we disclose certain information about how we have handled personal information in the prior 12 months, including the:

• categories of personal information collected
• categories of sources of personal information
• business and/or commercial purposes for collecting and selling their personal information
• categories of third parties/with whom we have disclosed or shared their personal information
• categories personal information that we have disclosed or shared with a third party for a business purpose.
• categories of personal information collected
• categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party

(iv) Right to Correct. You have the right to request a correction of any inaccurate personal information we hold about you.

(c) Submitting Requests. You can submit a copy, deletion and right-to-know request online by sending a request through your account in case you are registered in the Site, by emailing us at privacy@bold.com, by utilizing any of the options made available to you by us throughout the Site for this purpose, or by contacting us at the toll free number in Contact Us.

(d) Incentives and Discrimination. The CCPA and similar state laws, prohibit discrimination against California consumers for exercising their rights under the CCPA and similar state laws and imposes requirements on any financial incentives offered to California consumers related to their personal information. Businesses may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of the consumer’s data.

17. Contact Us

The Site is controlled and operated by Provider. Whether you access the services through any of our family Sites, you may contact Provider by any of the means in the Contact Us section on the Site. If your questions are not answered online, you can email us at privacy@bold.com, write to us at Auxiliant S.à.r.l, 1A, rue Thomas Edison, L-1445 Strassen, Luxembourg or to BOLD LLC at City View Plaza II, Suite 6000, 48 Road 165, Guaynabo PR 00968.