Online Privacy Policy

Last updated June 2023

Thank you for choosing to be part of our community at PureSpectrum Inc. (“Company”, “we”, “us”, or “our”).

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@purespectrum.com

This notice is specifically aimed at website visitors, our Clients and Suppliers.  If you are a responder, we will provide you with detailed information about the processing of your data when you access our systems.

When you visit our website https://purespectrum.com/, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as https://purespectrum.com/), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services“.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

 

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; current and former address; phone numbers; email addresses; business email; business phone number; and other similar data.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


Information automatically collected

In Short:   Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

 

HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
  • To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • Fulfil and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
  • Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To deliver services to the user. We may use your information to provide you with the requested service.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

LAWFUL BASIS FOR PROCESSING DATA?

In Short:  We only process your data with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

We may process (or share data) based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short:  We only share information with the following third parties.

We may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

In addition to the above we may disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

Web and Mobile Analytics
Google Analytics

Website Hosting
WordPress.com

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short:  We may transfer, store, and process your information in countries other than your own.

Our servers are located in United States. If you are accessing our Services from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHO WILL YOUR INFORMATION BE SHARED WITH?” above), in and other countries.

These countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.  You can contact us on the address below if you would like further information about the controls we adopt.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at privacy@purespectrum.com.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

We respect the rights that individuals are granted through their local Data Protection legislation.  Where these rights exist for you, you may exercise these over the data we hold by contacting us at the address below.  These rights may include:

  • The right to be informed about the processing of your personal information and to know what data we hold
  • The right to correct or rectify the information we hold
  • The right to access your data and rights of data portability
  • The right to be forgotten
  • The right to withdraw any consents you have previously given to us, such as for direct marketing communications
  • The right to opt out of the sale of your data (pursuant to the California Consumer Protection Act of 2018 “CCPA” and Virginia Consumer Data Protection Act “VCDPA”))
  • Right to non-discrimination as a result of exercising your rights
  • Rights to object or have human intervention in fully automated decisions
  • Right to complain to a local Privacy and Data Protection Regulatory body
  • Additional rights as described below related to the China Personal Information Protection Law (“PIPL”) described below

If you have questions or comments about your privacy rights, you may email us at privacy@purespectrum.com

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

■  Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

■  Contact us using the contact information provided.

DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when PureSpectrum Inc. believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that PureSpectrum Inc. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information PureSpectrum Inc. will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

Notice to California, Virginia, Connecticut, Utah and Colorado Residents

Pursuant to your applicable state’s privacy laws and regulations (the “Applicable Law”), (including the California Consumer Protection Act of 2018 (“CCPA”) for California residents), and subject to certain exceptions and limitations, you can contact us to exercise the rights described below with respect to certain personal information that we hold about them. To the extent those rights apply to you, they are described below. We also sometimes collect and process certain personal information on behalf of our customers. You should contact those customers to exercise any rights you may have with respect to that personal information.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide you with details about the personal information we collect, use, disclose and sell. You can submit a verifiable consumer request by emailing privacy@purespectrum.com. We reserve the right to verify your identity to our satisfaction, including by asking you to provide certain personal data that will help us identify you and connect you to personal data we have collected.

You are entitled to receive the following:

  • The categories of your personal information that we have collected in the preceding 12 months
  • The categories of sources from which that information was collected
  • The business/commercial purpose for the collection or selling
  • The categories of third parties with whom we share personal information
  • The specific pieces of personal information we have collected about you (subject to some exceptions)

Because we have disclosed or sold (as those words are defined in the applicable state law) personal information to third parties in the last 12 months, you are also entitled to receive:

  • The categories of personal information that we have disclosed or sold in the past 12 months

Right to Request Deletion of Personal Information

You have the right to request deletion of the personal information we have collected about you (subject to some exceptions). You can submit your request as described above, and we reserve the right to conduct the verification described above.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive unlawful discriminatory treatment from us for the exercise of your privacy rights under the applicable state law.

Right to Opt-Out of Sale of Personal Information

You have the right to opt-out of the sale, sharing or transferring of your personal information by us. You can submit a verifiable consumer request by sending an email to privacy@purespectrum.com.

List of Categories of Personal Information to be Collected and May Have Been Sold or Disclosed

Categories of Personal Information Collected

We collect personal information and sensitive data from research participants during participation in a survey and other market research activities.

  • Your age
  • Your Gender
  • Your income
  • Zip or Postal Code
  • Race
  • Ethnicity
  • Marital Status

While we will not ask for any directly identifying data, such as your name, email address, physical address or phone number, we will collect additional information from you that will be project specific.  This data will be dependent on the individual project but may include protected or more sensitive data such as:

  • Health or medical information
  • Educational information,
  • Political beliefs
  • Religious beliefs
  • Professional or employment-related information, including occupation trade union membership
  • Sexual orientation
  • Other demographic information

 

In addition, we will obtain data from the following sources to better understand your compatibility with projects that you may wish to participate in and to protect our business

  • Geo Location
  • IP Address
  • Device Details which includes collecting Information about your device (e.g., device operating system, the other applications on your device, device network provider, device type, time zone, network status, browser type, browser identifier and other information that alone or in combination may be used to uniquely identify your device)

All of the information above was collected for the purposes described in this Privacy Policy

Categories of Personal Information that May Have Been Sold

We have sold all of the above categories of personal information in the last 12 months.

Categories of Personal Information that Were Disclosed

We have disclosed all of the above categories of personal information in the last 12 months.

Notice to Residents of the Peoples Republic of China

Your Rights Under the China Personal Information Protection Law (“PIPL”)

Pursuant to the China Personal Information Protection Law (“PIPL”), and subject to certain exceptions and limitations, residents of the Peoples Republic of China can contact us to exercise the rights described below with respect to certain personal information that we hold about them. Relatives of deceased persons about whom we hold personal information may, for their own lawful and legitimate interest, exercise these rights.  To the extent those rights apply to you, they are described below. We also sometimes collect and process certain personal information on behalf of our customers. You should contact those customers to exercise any rights you may have with respect to that personal information.

Right to Consent to the Collection of Personal Information and Sensitive Personal Information

We will obtain your voluntary consent to the collection, processing, storage, and sale of your Personal Information.  By providing that consent you are agreeing to the terms of this privacy policy.

 

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide you with details about the personal information we collect, use, disclose and sell. You can also request to correct or complete the information we hold about you.  You can submit a verifiable consumer request by emailing privacy@purespectrum.com. We reserve the right to verify your identity to our satisfaction, including by asking you to provide certain personal data that will help us identify you and connect you to personal data we have collected.

Right to Limit or Object to Processing Your Personal Information.

You are entitled to restrict or object to the processing of your personal information and to withdraw consent to the collection of your personal information, but if you do limit or object to the processing of your personal information, we will not be able to offer you survey opportunities.

Right to Request Deletion of Personal Information

You have the right to request deletion of the personal information we have collected about you (subject to some exceptions). You can submit your request as described above, and we reserve the right to conduct the verification described above.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive unlawful discriminatory treatment from us for the exercise of your privacy rights under PIPL.

Right to Opt-Out of Sale of Personal Information

You have the right to opt-out of the sale, sharing or transferring of your personal information by us. You can submit a verifiable consumer request by sending an email to privacy@purespectrum.com.

 

DO WE MAKE UPDATES TO THIS POLICY?

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at privacy@purespectrum.com or by post to:

PureSpectrum Inc.

31416 Agoura Road Ste 210

Westlake Village, CA 91361

United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right in this regard – please see  Section 10 above for more information.