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Last updated:  June 21, 2023

1. INTRODUCTION

Cangrade, Inc. (“Cangrade”) values the trust our users place in us when they give us access to their personally-identifiable information (“Personal Information”).  This Privacy Policy (“Policy”) describes how we work to maintain that trust. 

Cangrade has created this Policy in order to outline our collection, use, and sharing of information you provide to us when you access or use Cangrade’ online and/or mobile services and websites (collectively, the “Site”), including, without limitation, Cangrade.com, any Cangrade- mobile site, and any software provided by Cangrade in connection with such services or websites.  For the purposes of this Policy, any references to “we,” “our,” or “us” shall mean Cangrade.  This Privacy Policy covers only information that we collect through the Site, and not any other information collection or processing outside of the Site.

Please note that we reserve the right to review and update this Privacy Policy from time to time.  Accordingly, each time you access or use the Site, you should check the Last Updated legend at the top of this Policy, and review any changes since you last accessed or used the Site.  If you access or use the Site after an updated Privacy Policy is published, you will be deemed to have agreed to the amended Policy.

BY ACCESSING AND USING THIS SITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THIS SITE.

2. INFORMATION THAT WE COLLECT ABOUT YOU

Information Provided by You Upon Creating an Account

When you create and register a user account (“Account”) on the Site, you may be asked to provide or confirm certain pieces of Personal Information, which may include one or more of the following:

1. First and last name
2. E-mail address
3. Educational history
4. Current occupation and title
5. Employment history
6. Demographic information

We may supplement the Personal Information you provide with additional Personal Information we gather from public sources or from third-parties (e.g., consumer reporting agencies) that may lawfully provide such information to us.

You are under no obligation to provide your Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the Site’s features and services. Your information may also be required by a potential employer in order to identify your assessment results with your job application.

Information Provided When You Contact Us

We may collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Site.  We generally collect one or more of the following types of Personal Information when you contact us with a question or comment, or request information from us about our products and services:

1. Name
2. E-mail address
3. Phone Number

Passively Collected Information

When you access and use our Site, we may automatically collect and retain certain types of information, including your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, such as your browser type and version, time zone setting, and operating system and platform. 

When you take our online assessments (the “Assessments”) on the Site, we also collect and retain your “Assessment Data,” which is defined as information and data collected from your responses, including metadata about your real-time user interaction with the Assessments.  After your completion of the Assessments, the Site will review your Assessment Data and generate your specific “Trait Profile,” which contains the Site’s assessment and description of your personality traits.

We also use cookies on our Sites; for more information, please see the Cookies and Other Tracking Technologies That We Use section below.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE

We and our service providers use cookies and embedded scripts in connection with the Site.

• Cookies are small text files that are stored on your computer or device when you visit our Site.  Cookies allow a website to recognize a particular device or browser.  The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website.

• An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.  The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

The above technologies are used in analyzing trends; administering the Site and its features and services; tracking users’ movements around the Site; and to gather demographic information about our user base as a whole.  We may receive reports based on the use of these technologies on an individual as well as aggregated basis.

We use cookies, pixel tags, and similar tracking technologies to remember users’ settings, market products and services to users, and for authentication purposes. For information on how to manage the cookies that are placed on your computer, please visit our Cookie Policy.  The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies; how to have the browser notify you when you receive a new cookie; or how to disable cookies altogether.  Please note that if cookies are disabled or removed, not all features of our Site will operate as intended.

Third-Party Analytics.  We may also use service providers, such as Google Analytics, that may use cookies or other technologies to collect information about your online activities across this and other sites over time for non-advertising purposes such as those described above.  To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/.

4. WHAT WE DO WITH THE INFORMATION WE COLLECT

• General Uses.  We also use the information we collect to manage, analyze, develop, customize, and improve our Site as well as our products and services (including our Assessments).

• Information Provided When You Register an Account and Take Our Assessments.  We may use this information to authorize and administer your access to the Site, verify your identity, authenticate your visits, and provide our products and services to you.  Personal Information with other Personal Information lawfully collected from third parties in order to better market and provide our products and services. 

• Information Provided When You Contact Us.  We may use this information to understand and respond to your question or comment.

• Passively Collected Information.  We use passively collected information to monitor and maintain the performance of our Sites; analyze trends, usage, and activities in connection with our services; validate users and ensure their technological compatibility with users; optimize our marketing efforts; and to provide our products and services to you, including analyzing your Assessment Data and developing your Trait Profile.

• Aggregate Data.  We may use aggregate our user’s Personal Information and passively-collected information to create aggregate data which cannot be used to identify you (“Aggregate Data”). For example, Aggregate Data may include data that describes the general demographics, usage, Assessment Data, or other characteristics of a Site’s users.  We reserve the right to use, transfer, and/or sell Aggregate Data about the Site’s users for any lawful purposes.  We also reserve the right to use such aggregate information in collaboration with outside researchers to measure and quantify the effectiveness of our products and services.

• Incumbent Employees. If you were directed to visit the Site, create an Account (or to sign into your existing Account), and take the Assessment by your current employer, then we may use your information to create a talent assessment model for a specific role at your current employer.  In such a scenario, you would be deemed an “Incumbent Employee.” 

• Job Candidates.  If you were directed to visit the Site, create an Account (or to sign into your existing Account), and take the Assessment as part of the job application process for a specific employer, then we may use your information to assess your fit to a specific role(s) at this employer.  In such a scenario, you would be deemed an “Job Candidate.”

• Advertising and Marketing purposes. We may use data to market, provide, and assess the effectiveness of our Sites and products and services, which may include us sending communications to you that are tailored to you and your interests or more generally in nature.

• Other Purpose.  We may use your information for any additional purpose which you separately authorize in the course of accessing and using our Site.

SMS Opt-in

A mobile user might opt-in to receiving transactional or promotional SMS messages by:

• Entering a phone number online,
• Sending an Mobile Originating (MO) message containing an advertising keyword, or
• Filling out a paper form that includes their phone number

5. WITH WHOM WE SHARE THE INFORMATION WE COLLECT

Personal Information of our users is an integral part of our business.  We reserve the right to share your Personal Information with third parties as described below.  We also reserve the right to transfer and/or sell other types of data, including aggregate or de-identified data derived from Personal Information, for lawful purposes in our discretion.  Note that we do not share Personal Information with third parties for their direct marketing purposes.

• Service Providers.  We, like many businesses, sometimes hire other companies (“Service Providers”) to perform certain business-related functions.  Examples include customer service, maintaining databases, data storage, cloud services, and hosting services.  When we employ a Service Provider to perform a function of this nature, we provide it with the information that it needs to perform its specific function, which may include Personal Information and other information that you provide to us via the Site.  These Service Providers are authorized to use your information only as necessary to provide these services to us.

• Legal Requirements.  We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena or similar legal obligation; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety of users of the Site or the public; (d) protect against legal liability; or (e) or as otherwise required or permitted by law.

• Job Candidates.  If you were directed to visit the Site, create an Account, and take the Assessment as part of the job application process for a specific employer, then we share your Personal Information and Trait Profile with this employer and any third party that is pertinent to the employment application process.

• Business Transfers.  As we develop our business, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, dissolution, total or partial sale of assets in bankruptcy or similar event, your Personal Information and other information may be part of the transferred assets.

• Advertising or Analytics Providers. We may use personal information in support of our: (1) advertising and marketing efforts, including to serve interest-based advertisements across the Internet; track and categorize your activity, interests and device(s) used over time on our websites and applications, and on third-party websites and mobile applications; and (2) research and analytics efforts, including to better understand your use our websites and applications to improve those technologies and optimize your experience and interactions. To do this, we may disclose personal information with certain third-party advertising or analytics providers (collectively, “Analytics and Advertising Providers”) through our use of Collection Technologies. These Advertising and Analytics Providers use Collection Technologies on our digital properties to collect and store information about you and your use of the services.
  
  Our Advertising or Analytics Providers include, for example:
  
  Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
  
  For additional information about our use of Collection Technologies and the Advertising or Analytics Providers that we use, please visit our Cookie Policy.

• Other Third Parties.  We may disclose your information to other third parties with your prior express consent.

You hereby consent to our sharing of your Personal Information and other information for the above purposes.

EU Residents – International Transfers of Personal Information.  The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) in reliance on a variety of compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses.  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.  By submitting your Personal Information, you agree to this transfer, storing, or processing.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. 

6. YOUR DATA PRIVACY RIGHTS

In accordance with applicable law, you may have the right to:

• Access to and Portability of Your Personal Information, which includes the right to: (1) confirm whether we are processing your Personal Information; (2) confirm the categories of your Personal Information that we process; and (3) receive an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format.
• Correct Your Personal Information. In some cases, we may provide self-service tools that enable you to do so.
• Delete Your Personal Information.
• Opt-Out of Your Personal Information Being Used for Certain Purposes, such as: (1) when we are relying on our own or someone else’s legitimate interests to process your personal information, except if when can demonstrate compelling legal grounds for the processing; (2) direct marketing; (2) targeted advertising; (3) the “sale” of your Personal Information (as that term may be defined by applicable law); and (4) certain profiling activities that result in legal or similarly significant effects on you.
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

To exercise the Privacy Rights identified above, as they may apply to our information practices, or if you have questions about your privacy rights or would like to appeal a decision made concerning a privacy request you submitted, please contact us by sending an email to support@cangrade.com.

Only you or someone legally authorized to act on your behalf may make a verifiable request regarding your personal information. To verify your request, we must collect certain pieces of information about you that confirm your identity. We will use such information for verification and compliance purposes only.

7. YOUR CHOICES REGARDING YOUR ACCOUNT INFORMATION

Choice

You are not required to create an Account to gain access to many services and features of the Site.  If you use the Site’s personalized services and features (e.g., the Assessments, the ATS and Trait Profile), you will need to create an Account and enter Personal Information, which we will treat as described in this Privacy Policy.

Our Opt-out Policy

We may send you notifications and communications using the email address and/or phone number you provided to us when you registered your Account.  To stop receiving some or all email and/or phone communications from us, you can use your Account settings to edit your preferences.   Alternatively, you can use the “unsubscribe” mechanism provided in the communication. 

We will also send you service-related email and/or phone announcements on rare occasions when it is necessary to do so.  For instance, if our service is temporarily suspended for maintenance, we might send you an email or text message.  You do not have an option to opt out of these emails or text messages, which are not promotional in nature.  If you do not wish to receive these announcements, you have the option to deactivate your account.

Accessing, Correcting, and Updating Your Information

You may access, correct, and update most of your Personal Information under the Account Settings tab of your Account profile.  You may also email us at support@cangrade.com with information necessary for us to process your request.  We will respond to your request within a 30 days.  We may need to verify your identity before granting access to Personal Information in our custody or control. 

Deactivating Your Account

You may deactivate your account by sending a deactivation request in Privacy Requests area under Account Settings. You may also deactivate your Account emailing us at support@cangrade.com with the email address.  

A deactivated Account does not mean that all of the information associated with your Account is expunged from our systems, although such information will now no longer be readily available to you. We will respond to your request within a 30 days.

Deleting Your Information

You may delete your account by sending a deletion request in Privacy Requests area under Account Settings. You also may request to delete your Personal Information by emailing us at support@cangrade.com with information necessary for us to process your request.  Note that any deletion request will be subject to our Retention Policy below.  We will respond to your request within a 30 days.

Downloading Your Information

You may download your personal data by sending a data request in Privacy Requests area under Account Settings. You also may request to download your Personal Information by emailing us at support@cangrade.com with information necessary for us to process your request.  Note that any deletion request will be subject to our Retention Policy below.  We will respond to your request within a 30 days.

Our Retention Policy

We may retain your information for as long as your Account is active or as long as necessary to provide you with our services, comply with our legal obligations and regulatory requirements, preserve and protect our rights as allowed by law, resolve disputes, maintain security, prevent fraud and abuse, and enforce our agreements (including our End User Agreement).

Upon your request to delete information associated with your Account, our retention policy differs depending whether you last took  the Assessment as a Job Candidate:

• If you took the Assessment as a Job Candidate: If you were directed to visit the Site, create an Account (or sign into your existing Account), and take the Assessment as part of the job application process for a specific employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of 2 years following the end of the hiring cycle of which you took part. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the 2-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this 2-year anniversary, then we will process your request upon 10 business days of receipt.
• If you took the Assessment as an Incumbent Employee: If you were directed to visit the Site, create an Account (or sign into your existing Account), and take the Assessment as directed by your current employer, then, in accordance with our obligations and requirements under local law, we must retain your information for a period of 2 years following the end of the hiring cycle of which you took part. As a result, if you request deletion of any information prior to this 2-year anniversary, we must wait until the 2-year period has passed, after which we will process your deletion request. If you request deletion of any of information after this 2-year anniversary, then we will process your request upon 10 business days of receipt.

Even if we are obligated to retain certain information, once you deactivate your Account or request to deletion of your Personal Information, your Personal Information will cease being visible to third parties through our Site.  

As discussed above, we may aggregate our user’s Personal Information and other information to create de-personalized Aggregate Data which cannot be used to identify you.  We will retain such Aggregate Data even after any Personal Information deletion requests have been processed. 

9. NOTICE AT COLLECTION FOR CALIFORNIA RESIDENTS

If you are a California resident, this section applies to you in addition to the rest of the Privacy Notice.

Categories of Personal Information Collected and Sources

The “What We Do With The Information We Collect” section of this Privacy Notice identifies the categories of Personal Information we may have collected in the preceding 12 months. The “Cookies And Other Tracking Technologies That We Use” section identifies the sources from which we obtain such information. We do not collect, use, or disclose “sensitive personal information,” as that term is defined by California law.

Purposes for Collection

We collect and use personal information for the business or commercial purposes described in the “What We Do With The Information We Collect” section above.

Categories of Personal Information Disclosed and Categories of Recipients

We may have disclosed any Personal Information collected in the preceding 12 months to our Service Providers for purposes consistent with this Notice. We may also disclose any Personal Information we collect: (1) to our Service Providers; (2) for compliance, fraud prevention, or safety purposes; (3) to employers as part of the job application process, (4) as a result of a Business Transfer; or (5) based on your consent or instruction, all of which are also described in the “With Whom We Share The Information We Collect” section above.

We may have disclosed the following categories of personal information in the past twelve months for our business or commercial purposes to the Categories of Recipients listed below.

California Privacy Rights

Subject to certain limitations, California residents have the following rights regarding their personal information:

• Request to Know. You have a right to request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose, share, or sell personal information, and the specific pieces of personal information that we have collected about you.
• Request to Delete. You have a right to request that we delete personal information that we have collected about you, subject to certain exceptions.
• Request to Correct Inaccurate Personal Information. You have a right to request that we correct inaccurate personal information that we may maintain about you.
• Request to Opt-Out of the “Selling” or “Sharing” of Your Personal Information. Our use of Collection Technologies may be considered a “sale”/ “sharing” under California law. You can exercise your right to opt-out of the “sale” or “sharing” of your personal information by either:
  • Modifying Your Cookie Preferences. When you visit one of our websites that collects personal information through Collection Technologies, you will be presented with a banner that offers you a choice about whether to accept or reject our use of cookies and similar tracking technologies, the use of which may constitute a “sale” or “share” of personal information under applicable law. If you wish to amend your choices, you can do so by clicking the paperclip icon found in the bottom left footer of our website. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access our sites, you will need to renew your cookie management choices.
  • Global Privacy Control. You may exercise your opt-out right by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Please note that even after opting out, your use of our websites may still be tracked by us or our Service Providers.

The list below summarizes the categories of Personal Information disclosed that may be considered “selling” or “sharing” under California law. Each category of Personal Information may have been “sold” or “shared” in the last 12 months to our Advertising or Analytics Providers for the purposes outlined in our Cookie Policy. We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

Categories of Personal Information Sold or Shared

• Personal identifiers
• Protected classifications under California or federal law
• Geolocation data
• Internet activity data
• Professional or job-related information
• Sensory data
• Inferences
• Request to Limit Use and Disclosure of Sensitive Personal Information. California law allows California residents to limit the use of their Sensitive Personal Information to those uses which are necessary to perform the services or provide the goods reasonably requested. As noted above, however, Cangrade does not collect sensitive personal information.
• Right to No Discrimination. You have a right not to receive discriminatory treatment for the exercise of your privacy rights.

Exercising Your California Privacy Rights

• How to Submit a Request to Know, Request to Delete, or Request to Correct. You may submit a Request to Know, a Request to Delete, or a Request to Correct by: (1) emailing us at: support@cangrade.com; (2) by writing to us at: Cangrade Inc., 9 Munroe Avenue, Watertown MA 02472; or (3) by contacting us at (888) 254-8394.
• How to Submit a Request to Opt-Out of “Selling” or “Sharing”. You may submit a Request to Opt-Out by following the instructions outlined above in the “Request to Opt-Out of the ‘Selling’ or ‘Sharing’ of Your Personal Information” section.
• Authorized Agent. You may designate an authorized agent to submit a request on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that you verify your identity directly with us.
• Verification. Once you submit a request, we will verify that you are the consumer to which the request pertains by matching certain data points (e.g., name, email address and/or telephone number) with information we maintain. Depending on the type of request you submit, we will attempt to match either two or three of these data points to the information maintained in our systems. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request. We may also reach out to you for additional verifying information for requests requiring a higher degree of verification because of the type or sensitivity of the request.

California Shine the Light

California residents may request information concerning the categories of personal information, if any, we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please contact us at: support@cangrade.com

Do Not Track Disclosures

Some browsers offer a “Do Not Track” privacy preference. Generally, when a user turns on the Do Not Track Signal, their browser sends a message to websites requesting that the user not be tracked. Our websites currently do not respond to “Do Not Track” signals.

Alternative Format

If you have a disability that prevents or limits your ability to access this notice, please contact us at support@cangrade.com. We will work with you to provide this notice in an alternative format.

10. MISCELLANEOUS

Other Websites.  Our Site may contain links to third-party owned and/or operated websites or mobile applications.  We do not own nor control these third-party websites or mobile applications, and accordingly assume no responsibility for the information practices of those sites or apps.  We suggest that you review their privacy, security, and data collection and distribution policies, if any, prior to providing such websites or apps with any information.

Blogs and Public Features of the Sites.  Our Site may contain features, e.g. blogs, chat rooms, community forums, sharing functions, etc., that permit you to upload, post, transmit, display, perform, or distribute content and information, including your Personal Information.  Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control.  You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.

Single Sign-On.  You can create an Account using sign-in services such as LinkedIn or various ATS platforms.  This service will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form.  Please note that your relationship with LinkedIn, or any other third-party ATS platform or website is governed solely by your agreement with such third-party website.

Security.  The security of your Personal Information is important to us.  We take commercially reasonable steps to help protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.  For example, we use one or more of secure socket layer (SSL) encryption, firewalls, and self-updating anti-virus software.  Your Personal Information will be stored in the United States and will be subject to laws applicable in that country.  However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services.  Please create a unique password for your Account and do not share your password with anyone else.

Minors.  Visitors under 18 years of age are not permitted to use and/or submit their Personal Information at the Site.  We do not knowingly solicit or collect information from visitors under 18 years of age.  We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. 

Contacting Us.  The Contact Us link on the Site contains an e-mail link that allow you to contact us directly with any questions or comments that you may have.  If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at support@cangrade.com, (888) 254-8394, or at:

Cangrade, Inc.
9 Munroe Avenue, Watertown MA 02472