Privacy Policy

Updated September 11, 2024

This Privacy Policy sets out how Arena Talent Inc. (“we,” “our,” “us,“ or “Arena”) collects, uses, discloses, and protects information from or about you that we receive through our website at arenatalent.com (the “Website”) and in connection with our related services and events. We will refer to our Website and related events and services together as the “Services.”

Our Services are available to prospective employers or others who seek to engage a new workforce member in a contract or other capacity (each an “Employer”) and to actual or potential job seekers, including those who visit our Website, register for our Services, or participate in our events (each a “Candidate”).

One of the main features of our Services is to allow for a variety of direct communications between Candidates and Employers (“Direct Communications”), such as the Candidate’s submission of a job application, the Employer’s communication of a decision to the Candidate, and (depending on the Employer’s subscription level) additional one-to-one communication, such as direct messaging. Just as an email service provider like Gmail allows both the sender and receiver of an email message to each keep and manage their own copy, Arena generally lets both the Candidate and the Employer keep and manage their own copy of any Direct Communications.

Broadly speaking, Arena handles two categories of personal data:

Employer Personal Data: These are personal data files that we handle on behalf of a particular Employer and pursuant to that Employer’s instructions. This includes, for example:
- All personal data about the Employer’s recruiting personnel acting in such capacity;
- All personal data in the Employer’s copy of Direct Communications that the Employer sends or receives;
- All personal data that the Employer creates in or provides to the Arena Platform regarding Candidates that is not in a Direct Communication (such as the Employer’s impressions or interviewer notes regarding a Candidate); and
- Any other personal data in an Employer’s external Applicant Tracking System that Arena Talent may process in connection with our agreement with the Employer.
Arena Personal Data: This is all other personal data that Arena handles, including but not limited to:
- Personal data in the Candidate’s copy of Direct Communications that the Candidate sends or receives;
- Candidates’ account and profile information;
- Information about actual and prospective customers of Arena that isn’t mentioned above, such as the email address of personnel of an Employer who are involved in trialing and procuring our Services.

We use, disclose, and otherwise handle Employer Personal Data solely pursuant to our agreement with the relevant Employers, which may be more restrictive than this Privacy Policy. For that reason, Employer Personal Data is subject to the privacy policies and practices of the Employers, and you should read those policies carefully. We are not responsible for the privacy practices of any Employers. If you have any questions about an Employer’s privacy practices, or you would like to make a request regarding Employer Personal Data, please contact the Employer directly.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU CANNOT USE THE SERVICES.

Table of Contents

This Privacy Policy contains the following sections:

Information We Collect About You
How We Use Your Information
Disclosure of Your Information
Online Analytics and Advertising
Security, Retention, and Transferring Your Information
Your Rights and Choices
Links to Third Party Sites
Children’s Privacy
Changes to This Policy
Contact Information

1. INFORMATION WE COLLECT ABOUT YOU

Depending on what areas of the Services you use, we obtain different types of personal data from or about you. We may also collect personal data about non-users.

Information You Provide Directly to Us

We collect information about you when you voluntarily provide it to us when you access or use our Services. This can include information you provide to us when you:

Register to use the Services;
Fill in a form or download documents from us;
Send Direct Communications through the Services;
Correspond with us about or through the Services, including via phone, email or otherwise, such as for customer service purposes;
Subscribe to our mailing lists, newsletters, or other forms of marketing communications;
Respond to or participate in surveys, focus groups, sweepstakes, or contests;
Attend our conferences or events, or otherwise interact with us at other conferences or events; or
Use some other feature of the Services as available from time to time.

Depending on how you use the Services, we may collect the following types of information from you:

First and last name;
Email address;
Postal address;
Log-in credentials to access your account on the Services;
Telephone number;
Professional or employment related information, including any such information on your work history, job title, educational background, and skills;
Other identifying and biographical information, including your portfolio, websites, community group memberships, career goals, personal hobbies, and demographic information;
Diversity-related information you may volunteer to provide us, such as data about race, ethnicity, and sexual orientation;
In accordance with applicable legal requirements, recordings or transcripts of meetings, calls and messages with us, and any other of your requests, questions, and responses to us via forms, or email, or other means;
Payment information, which is collected and processed by our third-party payment processors on our behalf; and
Any other information you choose to provide while using the Services that identifies or can be reasonably associated with you.

If you choose not to provide certain information, we may not be able to provide the Services to you or respond to your requests.

Information We Collect Through Automated Means

When you use our Services, we and our vendors (third parties that perform services on our behalf) automatically collect certain information about your device and how you use the Services. This includes your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, search terms, files you download, domain names, landing pages, pages and features viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information about how you use the Website. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).

To collect this information, we and our vendors may use Internet server logs, local storage, cookies, tracking pixels, and other similar technologies (collectively, "cookies") to track, measure, and analyze the behaviors and usage patterns on our Services. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

As we adopt additional technologies, we may also gather information through other methods. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. If you elect not to accept cookies, some functionality and areas of the Services may be restricted. To learn how to manage your cookies, please follow the instructions from your specific browser. If you access the Services via a mobile device, refer to the manufacturer’s instructions.

For more details, please see the “Online Analytics and Advertising” section below.

Information We Collect from Other Sources

We may collect information about you from other sources, including marketing vendors, survey providers, other websites and services, data enhancement services, social media, conferences, and other industry events, or for other purposes that we explain to you at the time of collection, to the extent permitted by applicable law. We use this information to supplement the information that we collect directly or automatically from you. We combine this information for the purposes explained in the next section of this Privacy Policy, including to understand your possible interests and provide more relevant experiences for you and improve our Services, analytics, and advertising.

When you “like” or “follow” us on social media sites (e.g., LinkedIn), or use a social media site to login to our Services, we may collect some information from or about you including your name, email address, and any comments or content you post that are relevant to us (for example, if you tag us in a comment or comment on one of our posts).

2. HOW WE USE YOUR INFORMATION

We use your data for the following purposes (including through the use of artificial intelligence and large language models and tools operated by us and/or our vendors):

Provide you with the Services and operate, maintain, and administer the Services;
Respond to your requests, communicate with you about the Services, and provide you with customer service;
Contact you by email, postal mail, or phone with or about special events, news, alerts, updates, information, promotions, surveys or contests relating to the Services or other services that may be of interest to you, in accordance with applicable law;
Customize the content you see on the Services;
Engage in analysis and research about use of the Services, improve the Services, and develop new services;
Deliver relevant advertising to you, including to let us and our advertising partners personalize the content and advertising you see on the Services and elsewhere online or in apps;
Measure the effectiveness of our advertising;
Secure the Services and resolve technical issues being reported;
Comply with any procedures, laws, and regulations which apply to us;
Establish, exercise, or defend our legal rights; and
With your consent or at your direction, for any other purpose.

Aggregate/De-Identified Information. We may aggregate and/or de-identify any information we collect through our Services so this information can no longer be linked to you or your device (“De-Identified Information”). We may use De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.

Combined Information. We may combine the information we collect through the Services with information that we receive from other sources, both online and offline. We may use this combined information subject to this Privacy Policy.

Legal Bases for Information Use. In applicable jurisdictions, we rely on the following legal bases to use your information as set out in this Privacy Policy (as relevant given the type of information and the context and purpose for using it):

Where we need to perform the contract we are about to enter into or have entered into with you for the Services;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal or regulatory obligation; or
Where we have your consent to process your information in a certain way.

3. DISCLOSURE OF YOUR INFORMATION

We may disclose the information we collect to the following categories of recipients:

Employers. If you are a Candidate, we may disclose your information to Employers who have job opportunities available or interest in placing job candidates.
Affiliates and subsidiaries. We may disclose your information within the Arena family of companies.
Vendors and service providers. We may disclose your information to third parties that perform services for us, which may include mailing or email distribution, payment processing, data enhancement, data storage, security, fraud prevention, web hosting, analytics, legal, or consulting services. Vendors and service providers may host or any other aspect of our business, potentially including any mechanism through which we or our users send or receive communications, such as email systems, call centers, websites, applications, or components of any of them. Vendors and service providers engaged in this manner may collect information from you directly when you communicate or interact with us.
Advertising partners. We may allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services. These technologies deliver tailored content and advertising to you on other websites and applications you use, as explained further in “Online Analytics and Advertising” below.
Joint marketing partners. We may disclose your information to another entity that jointly offers a service or product to you with us. These entities may collect information from you directly, as well.
Third parties in connection with a business transaction. We may disclose your information to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, including for the purpose of determining whether to proceed with a transaction or business relationship.
Law enforcement, regulators, and other parties for legal reasons. We may disclose your information to third parties as required by law or if we believe in good faith that we need to disclose the information to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our agreements, including terms applicable to the Services; (c) protect the security or integrity of our Services; and/or (d) exercise or protect the rights, property, or personal safety of Arena, our agents and affiliates, our customers, or others.
Otherwise with your consent or at your direction. We may also disclose your information whenever you consent to or direct such disclosures. For example, if you use our Services to send a job application to an Employer, we send it to that Employer. If you use our Services to post a message to other users or to the public, we may do so.

4. ONLINE ANALYTICS AND ADVERTISING

Online Analytics. We may use third-party web analytics services, such as those of Google Analytics, on our Services. These analytics services help us do many things, including collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; take measures to prevent fraud; and provide certain features to you. To prevent Google Analytics from collecting your information for analytics in certain browsers, you may install the Google Analytics Opt-out Browser Add-on on those browsers by clicking here.

If you receive email from us, we may use analytics tools, such as clear GIFs, to capture data such as when you open the email or click on any links or banners in the email. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Tailored Online Advertising. In using the Services, we work with certain third-party advertising technology partners such as ad networks and ad servers. We allow these third parties to place cookies or other similar technologies on the browser of your device to collect information about you (see “Information We Collect Through Automated Means” above). These third parties may use this information to serve relevant content and advertising to you as you browse the Internet, and may access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity.

The following websites provide more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising: the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices. On these websites, you can opt-out of receiving tailored advertising from companies that participate in the programs on these websites. We do not control these opt-out links and we do not control whether our advertising partners participate in these programs. We are not responsible for any choices you make using these programs or links or their continued availability or accuracy.

5. SECURITY, RETENTION, AND TRANSFERRING YOUR INFORMATION

Security. We implement various technical and organizational measures to protect your information from being accidentally or unlawfully accessed, destroyed, lost, misused, changed or damaged. However, no method of data transmission over the Internet or data storage is ever fully secure or error-free. Please keep this in mind when providing any information to us.

Retention of your information. We will retain your information until after we determine we no longer need it for the purposes for which we collected it. This includes the purposes of our legitimate business interests and satisfying our legal or reporting requirements. Information may persist in copies made for backup and business continuity purposes for longer than the original copy of the information.

International transfers of your information. The information Arena collects may be transferred to and stored in countries where we and our third-party service providers have operations, including the United States. The applicable data protection laws in these countries may differ from those in your country of residence. Arena complies with legal requirements for protecting the movement of data across borders, including through the use of European Commission-approved Standard Contractual Clauses. For more details about the measures we use, you can contact us as described at the end of this Privacy Policy.

6. YOUR RIGHTS AND CHOICES

Marketing Communications

As legally permitted, we may send you marketing communications regarding our Services or the services of third parties that we believe will be of interest to you. You can ask us to stop sending these communications at any time using the opt-out instructions provided in the communication or by contacting us using the information in the “Contact Information” section below.

Please note that even if you opt out, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you cannot opt out of certain administrative or transactional emails from us, such as emails confirming your requests or providing you with updates to our Privacy Policy or other terms.

Rights Regarding Your Information

Depending on where you live, applicable law may give you the right to make requests related to your personal data. You may have the right to ask us to:

obtain confirmation of whether we hold personal data about you, and receive information about how it is used and disclosed;
obtain a copy of your personal data, and in some cases, receive it in a structured, commonly used and machine-readable format, or have it be transmitted to a third party in such form;
update, correct or delete your personal data;
object to the use or disclosure of your personal data;
withdraw consent previously provided for the handling of your personal data (without affecting the lawfulness of prior use and disclosure of the information); and
obtain a restriction on the use of your personal data.

For example, individuals whose personal data is subject to the General Data Protection Regulation (GDPR) have a right to opt out of our handling of their personal data for direct marketing purposes.

Many of the rights described above are subject to limitations or exceptions under applicable law.

If you wish to exercise any of these rights, or raise a complaint on how we have handled your personal data, please contact us as described at the end of this Privacy Policy. Individuals also have a right to file a complaint with the relevant supervisory authority, but we invite you to kindly first give us an opportunity to address your concern.

If you are a Candidate and you have questions about how your information is processed in connection with the services we provide to an Employer or want to exercise any of your rights regarding information collected by the Employer, please contact the Employer directly.

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (DNT) signals, we do not respond to them at this time.

7. LINKS TO THIRD PARTY SITES AND FEATURES

Our Services may contain links to or integrate with third party websites, features, and other services. If you follow a link to any of these third parties or use such an integration, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or practices. These third parties or integrations may also disclose information to us about your activities on their services. Before you submit any information to any third parties, please check their privacy policies.

8. CHILDREN'S PRIVACY

Our Services are not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 18. If a parent or guardian becomes aware that their child has provided us with personal data without their consent, they should contact us as described below. If we become aware that we have received personal data regarding a child under the relevant age threshold, we will take steps to delete this information from our files under circumstances where the law requires deletion of the information.

9. CHANGES TO THIS POLICY

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible on the Services and update the “Last Updated” date at the top, so you should review the Privacy Policy periodically. We will provide further notice if legally required. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

10. CONTACT INFORMATION

Please feel free to contact us if you have any questions about this Privacy Policy or our practices, or if you are seeking to exercise any of your statutory rights. You may contact us at legal@arenatalent.com or at our mailing address below:

Arena Talent Inc.
Attn: Privacy
8 The Green, #10887
Dover, DE 19901