Privacy Policy - September 2012

This Privacy Policy (“Privacy Policy”) for 360Candidate, Inc. (“360Candidate,” “we,” “us,” or “our”) was developed consistent with our commitment to combine the highest-quality products and services with the highest level of integrity. This Privacy Policy explains how we collect, use, and disclose your information.

By using the internet website at www.360candidate.com (the “Website”), and the services available through the Website or otherwise provided by 360Candidate (collectively, the “Services”), you are accepting the policies and practices set forth in this Privacy Policy. Each time you use or access the Website or the Services or provide us with information, you agree that you are consenting to our use and disclosure of the information that you provide, as described in this Privacy Policy. This Privacy Policy is incorporated into our Terms and Conditions. If a term is capitalized and not defined in this Privacy Policy, it is defined in the Terms and Conditions.

If you do not agree to this Privacy Policy, you should not use the Website or the Services. We may modify this Privacy Policy from time to time and post those modifications here. Your continued use of the Website and the Services after any such modification constitutes your acceptance of the modification.

1. Collection of Information. We obtain information from and about you in a number of different ways, including:

(a) General Information. Some information (“General Information”) is gathered automatically when you access the Website and the Services, including your Internet protocol address, type of web browser used, type of operating system, the domain name of your Internet service provider, and other similar information. This General Information does not identify you personally. We also use Cookie Information (as defined below), clear GIFs, and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your use of the Website and the Services.

(b) Personal Information. Some information that may be identifiable as yours information (“Personal Information”) is not gathered automatically when you access the Website and the Services. If you wish to provide Personal Information, you must do so voluntarily, and may do so in a number of different ways. The following are some of the kinds of Personal Information that we collect from you:

(i) Registration Information. When you create your account (either a Recruiter Account, a Candidate Account or a Reference Account) with us at the Website, you will be asked for certain Personal Information. While using the Website and the Services, you will be asked for additional Personal Information.

(A) For Recruiters. Registration Information may include your name, company’s name, mailing address, email address, company’s logo, credit card number, phone number, and other information. Personal Information may include information about the position you are trying to fill, your opinions about Candidates, your colleagues, and their opinions, and your communications with Candidates.

(B) For Candidates. Registration Information may include your name, mailing address, email address, phone number, and other information. Personal Information includes your profile, along with whatever information or links you include in your profile and your communications with the Recruiter.

(C) For References. Registration Information may include your name, mailing address, email address, phone number, and other information. Personal Information includes your reference and your communications with the Recruiter.

(ii) Third Party Information. When you register at a third party website, such as Facebook, LinkedIn, Twitter, Google+, and similar websites, and provide Personal Information to such third parties, we may obtain and use such information in providing the Services.

(iii) Email Information. When you send us email messages, we may retain the content of your email messages, together with your email address and our response to you.

(c) Cookies. Cookies are small pieces of data that are stored by a user’s web browser on the hard drive of a user’s computer. Cookies can “remember” what information (“Cookie Information”) a user accesses on one web page to simplify subsequent interactions with that website by the same user / computer, or can use that Cooke Information to streamline transactions on related websites. The Cookie Information that we use does not capture your individual email address or any personally identifying information, but does permit us to send new services, promotions, or other such responses to you or assist your use of the Website. We may also set Cookies when you register or when you acquire goods or services from the Website, and may do so without notice to or permission from you or any third party. Third party websites which are accessible from the Website via links, banner ads, or “click-throughs” may also use Cookies, and we shall have no responsibility whatsoever for such Cookies.

2. General Use and Disclosure of Information. We use and disclosure your information as follows:

(a) General Information. We use General Information to understand Website demographics and content preferences, to analyze trends, to administer the Website and the Services, and to help improve the Website and the Services. We use such General Information without notice to, or permission from, you or any third party. In particular, we may provide aggregate information about our customers, sales, Website traffic patterns, and related information to our affiliates or third parties.

(b) Personal Information. As described in more detail in Section 3 below, we generally use and disclose your Personal Information as follows:

(i) For Recruiters. We will disclose the information about the position you are trying to fill to all Candidates, as well as certain aspects of your Personal Information; provided, however, that your credit card information will not be disclosed to any Candidate. We will also use and disclose your Personal Information to notify you about important changes to the Website, the Services, or our business, new services, and special offers you may find valuable. By using the Website and the Services, you agree to receive this information from us. If you do not want us to send you emails or otherwise contact you, you can always opt out of communications by clicking on the unsubscribe links provided when we contact you. We may retain information derived during the process for our internal analytical purposes, and may publish the results of such analysis without disclosing any Personal Information.

(ii) For Candidates. We will disclose your Personal Information to help you apply for certain job opportunities and recruiters who are looking at candidates to fill certain job opportunities. We will also use and disclose your Personal Information to notify you about important changes to the Website, the Services, or our business, new services, and special offers you may find valuable. By using the Website, you agree to receive this information from us. If you do not want us to send you emails or otherwise contact you, you can always opt out of communications by clicking on the unsubscribe links provided when we contact you. We may retain information derived during the process for our internal analytical purposes, and may publish the results of such analysis without disclosing any Personal Information.

(iii) For References. We will disclose your Personal Information to recruiters who are looking at candidates to fill certain job opportunities. We will also use and disclose your Personal Information to notify you about important changes to the Website, the Services, or our business, new services, and special offers you may find valuable. By using the Website, you agree to receive this information from us. If you do not want us to send you emails or otherwise contact you, you can always opt out of communications by clicking on the unsubscribe links provided when we contact you. We may retain information derived during the process for our internal analytical purposes, and may publish the results of such analysis without disclosing any Personal Information.

(c) Cookie Information. We use and disclose Cookie Information to improve our Website and better serve you and our other customers, and may do so without notice to, or permission from, you or any third party.

3. Use and Disclosure of Personal Information.

(a) For Recruiters.

(i) We will disclose certain Personal Information to Candidates who applied for positions you post and References who are providing references for Candidates. By using the Website and the Services, you grant us the right to disclose this certain Personal Information to the applicable Candidates and References. Please note that we do not have any control over how a Candidate or Reference uses and discloses your Personal Information, including information you provide directly to that Candidate or Reference. You acknowledge and agree that we will not have any liability for any actions of any Candidate or Reference. You should know that Candidates or Reference to whom we may disclose your Personal Information may share your Personal Information with others.

(ii) In addition, we may disclose your Personal Information (A) if such disclosure is made to comply with the law or an order issued by a court or an authorized administrative agency, respond to a subpoena, legal process, warrant, court order, or to protect our rights or property, prevent a crime, or protect the personal safety or rights of others; (B) to our service providers, vendors, or other third parties for the purpose of providing services on our behalf, including, without limitation, customer service (help), credit card processing, information technology services, and hosting services; (C) as part of a merger or consolidation, or part of the sale of all or substantially all the stock or assets of the business to which the information pertains; and (D) as part of a disposition in a bankruptcy proceeding in a transaction approved by the bankruptcy court.

(iii) Please be aware that when you voluntarily display or distribute Personal Information on the Website or in other ways, that information can be collected and used by others. This may result in unsolicited messages from third parties. We cannot be responsible for Personal Information you voluntarily display, disclose, or distribute on the Website or in any other way.

(b) For Candidates.

(i) We will disclose your Personal Information to recruiters whose jobs you have applied for, References who you have asked to provide a reference, and recruiters who are looking at candidates to fill certain job opportunities. By using the Website to apply for a job, you grant us the right to disclose your Personal Information to the applicable recruiters and Reference. Please note that we do not have any control over how a recruiters or Reference uses and discloses your Personal Information, including information you provide directly to that recruiter or Reference. You acknowledge and agree that (A) we do not evaluate any recruiter’s or Reference’s privacy practices, and (B) we will not have any liability for any actions of any recruiter or Reference. You should know that recruiters or References to whom we may disclose your Personal Information may share your Personal Information with others.

(ii) In addition, we may disclose your Personal Information (A) if such disclosure is made to comply with the law or an order issued by a court or an authorized administrative agency, respond to a subpoena, legal process, warrant, court order, or to protect our rights or property, prevent a crime, or protect the personal safety or rights of others; (B) to our service providers, vendors, or other third parties for the purpose of providing services on our behalf, including, without limitation, customer service (help), credit card processing, information technology services, and hosting services; (C) as part of a merger or consolidation, or part of the sale of all or substantially all the stock or assets of the business to which the information pertains; and (D) as part of a disposition in a bankruptcy proceeding in a transaction approved by the bankruptcy court.

(iii) Please be aware that when you voluntarily display or distribute Personal Information on the Website or in other ways, that information can be collected and used by others. This may result in unsolicited messages from third parties. We cannot be responsible for Personal Information you voluntarily display, disclose, or distribute on the Website or in any other way.

(c) For References.

(i) We will disclose your Personal Information to Recruiters who the applicable Candidates have applied for a job and recruiters who are looking at candidates to fill certain job opportunities. By using the Website, you grant us the right to disclose your Personal Information to the applicable Recruiters. Please note that we do not have any control over how a recruiter uses and discloses your Personal Information, including information you provide directly to that recruiter. You acknowledge and agree that (A) we do not evaluate any recruiter’s privacy practices, and (B) we will not have any liability for any actions of any recruiter. You should know that recruiters to whom we may disclose your Personal Information may share your Personal Information with others.

(ii) In addition, we may disclose your Personal Information (A) if such disclosure is made to comply with the law or an order issued by a court or an authorized administrative agency, respond to a subpoena, legal process, warrant, court order, or to protect our rights or property, prevent a crime, or protect the personal safety or rights of others; (B) to our service providers, vendors, or other third parties for the purpose of providing services on our behalf, including, without limitation, customer service (help), credit card processing, information technology services, and hosting services; (C) as part of a merger or consolidation, or part of the sale of all or substantially all the stock or assets of the business to which the information pertains; and (D) as part of a disposition in a bankruptcy proceeding in a transaction approved by the bankruptcy court.

(iii) Please be aware that when you voluntarily display or distribute Personal Information on the Website or in other ways, that information can be collected and used by others. This may result in unsolicited messages from third parties. We cannot be responsible for Personal Information you voluntarily display, disclose, or distribute on the Website or in any other way.

4. Deleting your Personal Information. We are committed to giving you control over your Personal Information. You may access the Personal Information you provide to us, and may modify or delete that information, by logging into to your account and editing it. We will delete your Personal Information if you request that we delete it, but we may retain General Information that was derived from your Personal Information, and we may also retain your Personal Information in our backup files for a period of time. Please remember, however, that if we have already disclosed some of your Personal Information in accordance with this Privacy Policy, we cannot access that Personal Information any longer and cannot force the deletion or modification of that Personal Information by the parties to whom we have made those disclosures.

5. Storage and Security. We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. Even though we have taken and will continue to take steps to ensure that your Personal Information is not intercepted, accessed, used, or disclosed by unauthorized persons, you should know that we cannot fully eliminate security risks associated with Personal Information. You assume all responsibility and risk for your use of the Website and Services and the information you post or access through the Website.

6. Links to Other Web Sites. This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

7. Children. We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Website or Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Services, please contact us, and we will endeavor to delete that information from our databases.

8. International Privacy Laws. If you are visiting the Website from outside the United States, please be aware that you are sending information (including Personal Information) to the United States where our servers are located. We will hold and process your Personal Information in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country.

9. Changes to Company's Privacy Policy. The Website, Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

10. Access to Information; Contacting Company. To keep your Personal Information accurate, current, and complete, please update through the Website and Service. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about this Privacy Policy or our information practices. If you have any questions or comments about 360Candidate or this Privacy Policy, you may contact us at: support@360Candidate.com.