Last modified on August 28, 2023
At Localized, Inc. (“Localized,” “we,” “us,” or “our”), we connect university students and recent graduates with industry experts and employers and help our users access career knowledge.
1. IMPORTANT INFORMATION AND WHO WE ARE
- Full name of legal entity: Localized, Inc.
- Email address: email@example.com
- Postal address: Localized, Inc. 5425 Wisconsin Avenue, Suite 600 Chevy Chase, MD 20815
THIRD-PARTY LINKS AND FUNCTIONALITY
2. THE DATA WE COLLECT ABOUT YOU
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the ability to identify the individual has been removed (anonymous data). We may collect, use, store and transfer the following categories of Personal Data about you:
- “Identity Data” includes first name, middle name, last name, username or similar identifier, title, any video or photographic images captured during video/web conferences or webinars via Zoom, and any information about yourself that you upload when you use our Services.
- “Contact Data” includes your email address.“Contact Data” includes your email address. While we do not request phone numbers from users, we may do so in the future.
- “Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services.
- “Profile Data” includes your username and password, languages spoken, photos, links to social media accounts, interests and work and educational history, your interests, preferences, organizations to which you belong, feedback, survey responses, and any other data you choose to include on or upload to your profile.
- “Usage Data” includes information about how you use our website, products and services.
- “Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.
AGGREGATED AND ANONYMIZED DATA
We may collect or generate aggregated and/or anonymized data and use the aggregated and/or anonymized data for any purpose, including to analyze the effectiveness of our Services, to improve and add features to our Service, and for any other lawful purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not request any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect Personal Data by law, or under our Terms of Service, and you fail to provide that data when requested, we may be unable to provide you with some or all of the Services.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We will only collect and process your Personal Data where we have a lawful basis to do so. Lawful bases include consent (where you have given consent), contract (where processing is necessary for our provision of services under a contract with you), and the “legitimate interests” of Localized or third parties such as users or Institutions. Legitimate interests include compliance with applicable law, mitigation of security threats, and effectuation of business operations, including mergers and acquisitions. Legitimate interests can only function as a lawful basis for the collection and processing of your Personal Data where such interests are not outweighed by your rights and freedoms. We collect data from and about you including through:
You may give us your Identity Data, Profile Data, or Contact Data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes Personal Data you provide when you:
- create an account on the Website, App, or Enterprise App (either for yourself or on behalf of a university or an institution, including a non-profit, refugee association, university, college or company (each, an “Institution”, and collectively, “Institutions”);
- subscribe to or use our Services, including by logging in and creating or editing a profile and/or by creating, joining, or participating in a public or private event, organization or channel or applying for a job;
- request that we send you marketing information;
- enter a competition, promotion or survey; or give us feedback or contact us.
AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you interact with our Services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs, and other similar technologies.
For example, we may monitor the number of people that use the Services, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Services (e.g., Google Chrome, Microsoft Edge, etc.), and geographical location information. In particular, the following information may be created and automatically logged in our systems:
- Log Data: Information that your browser automatically sends whenever you visit the Services (“Log Data”). Log Data includes your IP address, browser type and settings, the date and time of your request, and how you interacted with the Services.
- Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
We will receive Personal Data about you from various third parties, including as set out below:
- analytics providers such as Google, Segment and Heap [based outside the EU], who help us analyze how users use the Services and enhance your experience when you use the Services
- marketing platforms who host our data for us, such as Mailchimp;
- search providers such as Algolia [based inside the EU];
- teleconferencing software providers such as Zoom;
- partner universities and other Institutions share Personal Data regarding students with us – including, depending on the Institution, names, city or country of residence, email addresses, majors, and/or GPA – to allow us to provide Services to these students;
- and identity and contact information from third party providers (if an individual has authorized that provider to provide such information to us) such as LinkedIn, Meta, Apple, Google, and Microsoft.
4. HOW WE USE YOUR PERSONAL DATA
We may use your Personal Data in the following ways:
- To register you as a new user. We’ll use your Identity, Contact, and Profile Data, including to protect all our users from Bots, spammers or trolls. By signing in with an identity, you can be held accountable for your actions.
- To facilitate your use of the Services. We’ll use your Identity, Contact, and Profile Data, including to allow you to create and manage your profile, connect with Institutions, attend events, connect with experts and apply for jobs.
- To register your Institution. If your organization or university is a Localized subscriber, we may use your Identity, Contact, and Profile Data to serve such Institutions, including to provide them with the data they need and enable us to offer students and alumni access to experts, career content, and potential employers.
- To share with your Institution. We’ll use your Identity, Contact, and Profile Data to serve Institutions, including to provide them with the data they need, and allow us the ability to offer students and alumni access to experts, career content and potential employers.
- To allow you to create, join or participate in a public or private channel or group, career fair, conference, organization, event or to apply for a job or connect with experts. We’ll use your Identity, Contact, and Profile Data to facilitate your ability to create, join, or participate in a channel/group, conference, career fair or event and to ensure proper recommendation, match and appropriate level of visibility to other users.
- To administer and protect our business and this website, (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). We’ll use your Identity, Contact, and Technical Data, including to run our business, provide administration and IT services, and provide network security.
- To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you. We’ll use your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data, including to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. We’ll use your Technical and Usage Data, including to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to develop new services, and to inform our marketing strategy.
- To make suggestions and recommendations to you about goods or services that may be of interest to you. We’ll use your Identity, Contact, Technical, Usage, and Marketing and Communications Data, including to develop our products/services and grow our business.
- Where we need to comply with a legal obligation, exercise a legal right, or protect Localized or others. We may use your Personal Data, including to prevent or investigate fraud, criminal activity, or misuses of our Services; in the context of a business reorganization or group restructuring exercise; to comply with law, subpoena, or other legal process; to assist government enforcement agencies, where reasonably necessary to ensure compliance with applicable law; or to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
- 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.
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our Services and you have not opted out of receiving that marketing.
We do not share your Personal Data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you unsubscribe from our marketing lists you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
Cookies are small pieces of text used to store information on web browsers. We use HTTP (first-party) cookies to capture the following information to enhance our user experience:
- Session management: keeping you logged in, identifying your roles and permissions (i.e. admin or expert; what organization you belong to);
- Device identification: to determine the user browser and device uniqueness;
- Notifications: Allowing you to receive real-time notifications by means of Google Firebase.
- Analytics: Allowing Google Analytics and Segment to help us analyze how users use the Services and enhance your experience when you use the Services.
Given most of our cookie usage is user preference based, we use permanent cookies. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.
Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
5. SHARING AND DISCLOSURES OF YOUR PERSONAL DATA
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, ecommerce services for institutional subscriptions, order fulfillment services, event management services, email communication software and email newsletter services, advertising and marketing services, customer relationship management and customer support services, consultant and advising services, and web analytics services (for more details on the third parties that place cookies through the Service, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data, and to limit their use and other processing of your Personal Data to the performance of their services for us.
- Potential Employers: As part of our efforts to match users with career opportunities, we may share Personal Data, including your contact information and curriculum vitae, with businesses in search of talent. We will only share Personal Data with potential employers as part of our services to users, and only to the extent reasonably required for such purposes.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Passwords are encrypted, and all communications exchanged between you and our servers are protected by SSL encryption. We may change or add new security measures from time to time, as we deem appropriate.
Unfortunately, the transmission of any information via the Internet is not completely secure, and you use the Services at your own risk. We cannot control the actions of other Localized users with whom you may choose to share information. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to detect and respond to any suspected personal data breach.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of providing the Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, protecting against fraud, enforcing our agreements, and satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your Personal Data: see “Your Legal Rights” below for further information. In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
If you reside in Canada, the EEA, or certain other jurisdictions you may have the right to exercise certain privacy rights available to you under applicable data protection laws, including one or more of the rights listed below. We will process your request in accordance with applicable data protection laws, provided that may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.
You may have the right to:
- Request access and/or portability to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. In limited circumstances, you may also have the right to request that we send you or another third party a copy of your Personal Data in a structured, commonly used, machine-readable format.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.
- You also have the right to email firstname.lastname@example.org to request to delete your Personal Data or ask us to remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will notify you of, if applicable, at the time of your request.
- Object to processing of your Personal Data and/or to stop sending you marketing communications. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Withdraw consent at any time if we rely on your consent to process certain of your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Make a Complaint at any time to your local data protection authority about our collection and use of your Personal Data. We would, however, appreciate the chance to address your concerns before you approach your data protection authority, so please contact us in the first instance. If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.