Privacy policy

Last Updated: 8/1/2018

Introduction

Restless Bandit, Inc. ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you interact with us through the website www.restlessbandit.com or its related domains and subdomains (our "Website"), (including without limitation, by requesting a demo, by applying for a position with the Company, by posting your resume or other professional  or personally identifiable information to the company's Website, or by posting a comment or materials to any blog or other interactive part of the Website) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect:

- On this Website.
- In email, text and other electronic messages between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including the following:

- Information by which you may be personally identified, such as your name, professional work history, postal address, email address or telephone number ("personal information");
- Information that is about you but individually does not identify you, including, without limitation, information about your internet connection, the equipment you use to access our Website and usage details.
- If you are an Employer, as defined in our Terms of Use, this information may include, but is not limited to your Federal Employer Identification Number (EIN), Business Registration information, or other documentation to verify your business entity.

We collect this information:

- Directly from you when you provide it to us, including, without limitation, information that you provide by (1) filling in forms on our Website and uploading data to our Website, (2) registering to use our Website, (3) uploading your personal information to the Website, (4) responding to questions on the Website, (5) subscribing to our service of job alerts or requesting further services, (6) entering a contest or promotion sponsored by us, (7) reporting a problem with our Website, (8) responding to surveys that we might ask you to complete to better identify job opportunities for you, (9) performing search queries on the Website, or (10) otherwise corresponding with us.

- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies from third parties--for example, our business partners.

You can opt-out of including your resume in the Resume Database, as defined in the Terms of Use on our Website, at any time by (1) adjusting the settings in your account and we will remove your resume from the Resume Database, (2) unsubscribing from our communications to you by clicking on "unsubscribe" in any email from us to you, or (3) requesting removal of your personal information from our Website by contacting us at help@restlessbandit.com. Unless required by law or in party to a legal action, we will remove your personal information as soon as practically possible.

The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.

2. Technologies in Data Collection
The technologies we use for this automatic data collection may include, without limitation:

- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs). Web beacons permit the Company, for example, to count users who have visited certain pages or opened an email, and for the collection of other related website statistics, such as recording the popularity of certain website content and verifying system and server integrity. By disabling browser cookies, unique information associated with web beacons will also be disabled.
- Third Party Cookies. Our partners, affiliates, service providers, and agents use cookies to make it easier for you to access and navigate our site and for online behavioral advertising and related data collection, use and disclosure. This may result in such third parties placing cookies on your browser, sending their own cookies to your cookie file and using such cookies to target   advertising on other sites and services. The specific use of cookies by our partners, affiliates, service providers, and agents is   not covered by our privacy policy. We do not have access or control over these cookies.

3. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

- To present our Website and its contents to you.
- To provide you with job opportunities.
- To fulfill any other purpose for which you provide the information.
- To provide you with notices, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website.
-  In any other way we may describe when you provide the information, including without limitation, sharing it with third parties offering products, services or positions that may be of interest to you.
- For any other purpose with your consent.

4. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Other than specifically provided herein, we do not sell your personal information to third parties.

We may disclose personal information that we collect or you provide, as described in this Privacy Policy:

- To our subsidiaries, affiliates, or their or our successors or assigns.
- To Employers located in the United States specifically for the purpose of providing you job opportunities, if you have not unsubscribed from our Resume Database.
- To contractors, service providers, and other third parties we use to support our business, provided such parties provide at least the same level of privacy protection as is required of the Company.
- To fulfill the purpose for which you provide the information.
- For any other purpose disclosed by us when you provide the information.
- With your consent.

We may also disclose your personal information:

- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our "Terms of Use" and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Restless Bandit, Inc., our customers or others. This includes, without limitation, exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- If Restless Bandit is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Website of any change in ownership or uses of your personal information, as well as, any   choices you may have regarding your personal information.

5. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not   function properly. If you choose to continue to browse the Website without changing your cookie settings, you hereby consent to the use of cookies as described herein. If you wish to prevent the collection of data by Google Analytics, you may use the opt-out browser add-on developed by Google for this purpose, as further described in applicable materials made   publicly available by Google.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt out by following instructions provided in the relevant email or form. If we have sent you a promotional email, you may send us a return email asking to be omitted from  future email distributions or click the "unsubscribe" link located at the bottom of the email.

6. Transmission of Your Information

By submitting your information to the Company, you acknowledge and agree that the technical processing and transmission of your information may involve (a) transmissions over various networks, including the transfer of this information to the United States and/or other countries for storage, processing and use by the Company, its affiliates, and their agents; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Accordingly, you agree to permit such parties to make such transmissions and changes.

7. Security

Restless Bandit is committed to protecting the information you provide us. Restless Bandit implements and maintains administrative, physical, and technical safeguards reasonably designed to protect the information we collect from loss, misuse, and unauthorized access or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website you can contact us at help@restlessbandit.com.

8. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page prior to the change becoming effective. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

9. Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, register on the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address or any user name you may use. If we learn we have collected or received personal information from a child under 13 we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at help@restlessbandit.com.

10. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: help@restlessbandit.com

Restless Bandit, Inc.
33 New Montgomery St.
Suite 1500
San Francisco, CA 94105
+1 (415) 966-3084

11. COPYRIGHT POLICY

REPORTING CLAIMS OF COPYRIGHT INFRINGEMENT

We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from the website www.RestlessBandit.com or its related domains and subdomains (the "Website") infringe your copyright, you may request removal of those materials (or access thereto) from the Website by submitting written notification to our Copyright Agent (designated below). In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) ("DMCA"), the written notice (the "DMCA Notice") must include substantially the following:

- Your physical or electronic signature.
- Identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the   Website, a representative list of such works.
- Identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material.
- Adequate information by which we can contact you (including your name, postal address, telephone number and, if available,  email address).
- A statement that you have a good faith belief that use of the copyrighted material is not authorized by the copyright owner, its   agent or the law.
- A statement that the information in the written notice is accurate.
- A statement, under penalty of perjury, that you are authorized to act on behalf of the copyright owner.

Our designated Copyright Agent to receive DMCA Notices is: Restless Bandit, Inc.
Attn: Copyright Claims
33 New Montgomery St.
Suite 1500
San Francisco, CA 94105

If you fail to comply with all of the requirements of Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.

Please be aware that if you knowingly materially misrepresent that material or activity on the Website is infringing your copyright, you may be held liable for damages (including costs and attorneys' fees) under Section 512(f) of the DMCA.

COUNTER-NOTIFICATION PROCEDURES

If you believe that material you posted on the site was removed or access to it was disabled by mistake or misidentification, you may file a counter-notification with us (a "Counter-Notice") by submitting written notification to our Copyright Agent to receive DMCA Notices (identified above). Pursuant to the DMCA, the Counter-Notice must include substantially the following:

- Your physical or electronic signature.
- An identification of the material that has been removed or to which access has been disabled and the location at which the   material appeared before it was removed or access disabled.
- Adequate information by which we can contact you (including your name, postal address, telephone number and, if available,   email address).
- A statement, under penalty of perjury, by you that you have a good faith belief that the material identified above was   removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled.
- A statement that you will consent to the jurisdiction of the Federal District Court for the judicial district in which your address
 is located (or if you reside outside the United States for any judicial district in which the Website may be found) and that you   will accept service from the person (or an agent of that person) who provided the Website with the complaint at issue.

Completed Counter-Notices should be sent to our designated Copyright Agent to receive DMCA Notices at the contact information provided above. The DMCA allows us to restore the removed content if the party filing the original DMCA Notice does not file a court action against you within ten business days of receiving the copy of your Counter-Notice.

Please be aware that if you knowingly materially misrepresent that material or activity on the Website was removed or disabled by mistake or misidentification, you may be held liable for damages (including costs and attorneys' fees) under Section 512(f) of the DMCA.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Restless Bandit, Inc. (“Restless Bandit”) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Restless Bandit is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List.

Restless Bandit is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Restless Bandit complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Restless Bandit is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Restless Bandit may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms and Conditions, GDPR document, or in any other contractual document between you and us.

GDPR

The European Union's General Data Protection Regulation (GDPR) will take effect on May 25, 2018, and Restless Bandit is proud that our privacy team is well ahead to meet and exceed this deadline and its requirements.  While GDPR is focused on Europe, we believe all Restless Bandit data subjects have the same rights and deserve these top-level protection standards. We respect your privacy and consider your personal information sacred.

The GDPR extends the reach of the European Union's data protection laws and establishes many new requirements for organizations that fall under its governing umbrella.  And we are happy to report that, while the regulation is focused on the European Union, many companies, including Restless Bandit, have updated systems and processes globally to ensure compliance and to ensure that all of our users receive the same protections.

In compliance with the Privacy Shield Principles, Restless Bandit commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Restless Bandit at: gdpr@restlessbandit.com

Restless Bandit has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

FAQ For Candidates

Why did I receive a Restless Bandit email? Companies around the world use Restless Bandit to reconnect with former applicants about current job openings. In addition, Restless Bandit partners with many job boards, staffing firms, and individual headhunters to seek out top talent for open roles.

How do I request a copy of my data? Please forward the Restless Bandit email you received to GDPR@restlessbandit.com to request a copy of your information.

How do I delete my information from your system? Please forward the Restless Bandit email you received to GDPR@restlessbandit.com to request that your information be deleted.

How do I update my data? If the email you received did not include a link to update your information, please forward the Restless Bandit email you received to GDPR@restlessbandit.com to inquire about the process for updating your information.

FAQ For Employers

What if a candidate has requested a copy of their data? Please email GDPR@restlessbandit.com for a copy of all data on file for that candidate. Be sure to include the candidate’s email address.

What if a candidate has requested that their information be updated? Please invite the candidate to update their profile directly in your ATS. (These updates will then be synced to Restless Bandit.)

What if a candidate has requested that their information be deleted? Please email GDPR@restlessbandit.com to inform us of requests for data deletions. Be sure to include the candidate’s email address.

Data Security Standards

Restless Bandit falls into the GDPR category of data processor. Our customers and partners are the controllers with respect to the data collected and stored on Restless Bandit. Restless Bandit mirrors the data stored in our customers' applicant tracking systems ("ATS"), Human Capital Management ("HCM") systems, and Candidate Relationship Management ("CRM") systems, and our customers and partners ultimately determine the purposes and means of the processing of personal data. Data subjects (job seekers) who submit their resume and/or job application own their data. Our customers and partners work with data subjects to determine when to process personal data, how to process personal data, and when to delete personal data - all of which is mirrored in Restless Bandit.

As of April, 2018, each of our ATS, HCM, and CRM partners have stated that they are GDPR compliant. This list includes, but is not limited to, Taleo, Workday, iCIMS, Jobvite, Bullhorn, IBM Kenexa, Avature, and Smashfly. Please refer to their websites for their positions and statements on GDPR. Processors must comply with the measures outlined in Article 32, which require controllers and processors to implement "appropriate technical and organizational measures to ensure a level of security appropriate to the risk," including:encryption of personal data; ensuring the continuous confidentiality, integrity, and availability of processing services; restoring data in a timely manner; regularly testing, assessing and evaluating the effectiveness of technical measures to ensure data and data transmission security.Restless Bandit meets all four requirements. Further, Restless Bandit maintains an independent SOC II, type II certification and has been in good standing since receiving our first certificate in mid 2017. Within this certificate Restless Bandit ensures that:Each customer's data is stored in its own dedicated database, and encrypted with a key unique to that customer.

We connect with our customers' HR systems using Transport Layer Security 1.2 for HTTPS encryption, which is authenticated by AES-256 bit encryption. We implement industry best-practice standards (such as TLS 1.2 and AES-256) to encrypt and protect all interactions with our web applications. All data at rest, from databases to file systems to caches, is encrypted using AES-256, managed through Amazon Web Services Key Management Service. All passwords are hashed and salted using industry-standard techniques, such as bcrypt.

Restless Bandit runs on Amazon Web Services (AWS) cloud infrastructure, which meets rigorous international security standards: https://aws.amazon.com/compliance. On March 26th, 2018, Amazon stated that all AWS services are GDPR ready: https://aws.amazon.com/blogs/security/all-aws-services-gdpr-ready

We are also proud to announce that by May 25th, 2018, Restless Bandit will be EU-U.S. Privacy Shield certified. Under the EU-U.S. Privacy Shield Framework, Restless Bandit will continue our long-standing commitment to maintaining adequate safeguards and controls around personal data so that corporations large and small know that they are doing business with a trusted organization.

Administered by the International Trade Administration (ITA) within the U.S. Department of Commerce, the Framework requires compliance around matters such as informing individuals of their rights to their personal data, outlining our own liability and having further transparency in our privacy notice. Joining the Privacy Shield Framework is a voluntary action, but it is an important one because it is a legal commitment, enforceable under U.S. law.

The Right of Erasure and to Object
GDPR confers a right to consumers (data subjects) to be forgotten, which is discussed in Article 17 as the right of erasure. Controllers must erase personal data upon the request of the data subject to which it pertains or when "the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed." As the data controller, our ATS / HCM / CRM partners' customers decide the point in the application/hiring process at which they no longer have a legitimate interest in retaining a candidate's personal data. As mentioned above, Restless Bandit simply mirrors the data in our partners' databases. However, upon request from either a data subject or controller, Restless Bandit will delete any data in our systems within 72 hours.

Data Subject Consent / Right to Object
Article 21 of GDPR grants data subjects a right to object to their personal data being processed for direct marketing purposes and/or profiling. If a candidate makes this objection, they may unsubscribe from Restless Bandit communications, and we will not send further messages. Restless Bandit also adheres to the United States CAN-SPAM laws which require that each email include a clear unsubscribe method, a physical address (in our case 33 New Montgomery, Street, 15th FL, San Francisco, CA USA 94105), a phone number, and other corporate information.

Our Mission

FIND THE BEST-MATCHED LATENT CANDIDATES IN YOUR TALENT UNIVERSE

How we work

our work process

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The team

Best crew ever

Geovanny DuBuque

Creative Director

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Raven Durgan

Chief Exectutive

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Erwin Schultz

Web Designer

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