1.   Introduction

This Privacy Policy describes the types of information gathered by Curate Partners LLC, and its subsidiary Curate Partners LLC, II (collectively, “Curate”, “us”, or “we”) in the process of providing this website, https://www.curatepartners.com/, (the “Site”), and the associated services, data, information, tools, functionality, updates and similar materials (collectively, with the Site, the “Service”), as well as how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service.

By accessing or using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service at which are incorporated as if fully recited herein (“Terms of Service”). Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.

We may revise or update this Privacy Policy by posting an amended version through the Service and making you aware of the revisions, which may be through posting to the Site or otherwise. Your continued access to or use of the Service following our notice of changes to this Privacy Policy (or other acceptance method) means you accept such changes. Please refer to the “Last updated” date above to see when this Privacy Policy was last updated.

2.   Territoriality

2.1   Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. In all instances in this Privacy Policy, “our servers” means servers that we own or on which the Service is hosted, or which are otherwise utilized by the Service. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

2.2   This Privacy Policy may be subject to the provisions of the California Consumer Privacy Act of 2018 (“CCPA”), and other applicable privacy laws. under the CCPA, we are a “Business”, and you, if you are an individual residing in California, are a “Consumer” with certain protected privacy rights concerning your “Personal Information”. We will take commercially reasonable steps to maintain compliance with the CCPA’s requirements.  Your Personal Information may identify you as a person, and thus may be referred to as Personally Identifiable Information (“PII”).

3.   Who Collects Your Information On Our Site?

We do. Under the CCPA, Curate is what is known as a “Business”.  We collect information from you on the Service, and we are responsible for protection of your information.

4.   What Information Do We Collect?

4.1   Personally Identifiable Information. We may request specific PII from you when you register for the Service, when you use the Service, from third parties, when you communicate or interact with us, or otherwise when you submit such information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Site and Service. The types of PII we may collect and save include:

• Contact information such as name, email address, telephone number, payment account information (e.g. bank account numbers), and employment information/history.

You may provide Curate with information (e.g. feedback, comments, or other messages) when you interact with us through email, online chat, messaging functions within the Service, or otherwise Information you provide such as feedback, comments or other messages.

4.2   Non-personal Information. Non-personal information is anonymous or non-personally identifiable information about you, including but not limited to links and materials posted, information about your web browser, pages visited, length of session, device type, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Through collecting your IP address, we may be able to approximate your geographic location, however, unless and until this is information is paired with your PII, it cannot be used to identify you.  Further, the Service may utilize web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools.

We may also automatically collect certain technical information in our logs, such as standard web log entries that contain your IP address, device identifiers (e.g. UDID, MEID, and IMEI), first (including session cookies) and third party cookies, keystrokes and clicks while using the Site, page URLs, the pages and features accessed most frequently, time spent on a page, how pages and features are used, previous page and referring page URLs, and similar analytics about use of the Site or Service.

If non-personal information is paired or linked to any of your PII, we will treat that non-personal information as if it was also PII.

4.3   Background Check Information. Although it may look like we are collecting your social security number, driver’s license number, and other sensitive information, they are actually being collected and used by a third party service provider that will conduct a background check on each Service Provider (“Background Checker”).  The Background Checker will use this information, and may possibly request more, to conduct a thorough background check on you.  We do not hold, and cannot see or access the information that you provide the Background Checker.

4.4   Financial Information. Although it may appear that we collect financial information from you on the Service, it is actually collected and processed through a third party service provider (“Payment Processor”) to process payments for the Service. The Payment Processor may collect financial information such as banking information from you on the Service.  We do not hold your financial information.

4.5   Anonymous Information. We may also collect anonymous, non-identifying and aggregate information such as the pages you visit, type of browser you are using, device type, the operating system you are using, and the domain name of your Internet service provider. We may create anonymous or de-identified information from PII. Information collected or created pursuant to this section will not be considered PII and not subject to the terms and conditions of this Privacy Policy.

5.   Why Is My Information Being Collected?

5.1   We need to collect your PII so that we can respond to your requests for information and demonstrations or to be added to our emailing lists, and to process your requests for access to our Site. We also collect aggregate information to help us better design the Site and Site. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Site and Site, calculate usage levels, and otherwise provide services to you.

5.2   Background Check. A background check is required by our corporate customers, that you would like to work for, or provide services to as an independent contractor.  Without going submitting this information to the Background Checker, we cannot submit your application for the position that you are seeking.

5.3   Financial Information. If you are hired for a temporary or contractor role for which you applied on the Service, you will be hired by Curate, not our corporate customer, for such position and we will pay you for the work that you do on behalf of our corporate customer.

6.   How Do We Use the Information We Collect?

6.1   We use the PII you provide for the purposes for which you have submitted it including:

• Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, develop and improve the Service, and perform research and analytics.
• Onboarding You. In the event that you are applying to a temporary or contractor position, Curate will be the entity that hires you so that you may provide services to our corporate customers.  To do so, we will need to process some of your personal information.
• Sending Administrative Emails. We may use your PII to send you emails to: (a) confirm your account and your other PII, (b) provide you with information regarding the Service, (c) inform you of changes to this Privacy Policy, our Terms of Service, or our other policies; or (d) provide you with information on our other services and products, or promotions related to the Service.
• Financial Information. We use this information to pay you if you are hired as a temporary worker or a contractor.
• Background Checks and Credit Reports. Your social security number, driver’s license number, and other PII, will be collected, and used, by a third party provider to conduct background checks so that we know it is safe for you to work for, or provide services to, our corporate customers, and receive access to their confidential information and proprietary systems. The Background Checker may also obtain a copy of your credit report with this information.

6.2   We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your Site experience. We also may use this information in the aggregate to analyze how the Service is used, analyze industry trends, as well as to offer you programs or services.

7.   Do We Share Your PII?

In general, we will not share your PII except: (a) for the purposes for which you provided it; (b) with your consent, or as you direct; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) on a confidential basis with persons or organizations with whom we contract to carry out internal operations, which may include for example, analytical services, our ATS (as defined below), or as necessary to render the Service. With your knowledge and consent, we may share your PII with our business partners, such as our marketing partners and event co-hosts.

We may also share aggregate information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer your PII to a third party, or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control.  After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.

8.   How Can You Access and Control Your Information?

You can revise your PII from within the Service.  We may provide you with additional options to access and control your information in the future. If applicable, we will provide instructions on these options on the Service. If such options are provided, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information in order to protect your privacy and security.

9.   How Do We Store and Protect Your Information?

9.1   After receiving your PII, we will store it on our Service for future use. Your employment information will be stored in our applicant tracking system, Microsoft Dynamics, (“ATS”) provided by the Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052-8300 (“Microsoft”), in order to provide the Service to you. We, and Microsoft, have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.

9.2   If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our web servers and internal systems located within the USA.

9.3   We store your PII until we are required to remove it. We store our logs and other technical records in accordance with internal practices and policies, and potentially indefinitely.

10.   How Do We Use Cookies And Other Network Technologies?

10.1   To enhance your online experience with us, our web pages may presently or in the future use “cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. We may use session, persistent, first-party and third-party cookies. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of our Service may not function properly without the aid of cookies.  Curate uses session cookies, which are necessary to allow you to seamlessly navigate from one page or area of the Site to another during your visit, and these are normally deleted when you close your web browser.  We also use persistent cookies for your convenience so that you can log in faster, your preferences are remembered from visit to visit, and that you have an overall more convenient experience while visiting our Site.

10.2   Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://optout.aboutads.info.

10.3   We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” embedded links, and other commonly used information-gathering tools in connection with some Site pages and HTML-formatted email messages for such purposes as compiling aggregate statistics about Site usage and response rates. A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors’ hard drives. Pixel tags allow us and our service providers to count users who have visited certain pages of the Site, to deliver customized services, and to help determine the effectiveness of our promotional and advertising campaigns, Site, and Service. When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.

10.4   As you use the Internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site and Service.

10.5   Do Not Track. At present, the Service does not specifically respond to browser do-not-track signals.

11.   Collection of Information by Others

Our Service may provide links to certain third party websites and services that you may click on our Site. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.  This Privacy Policy only applies to our Service, not the services of any third party.

12.   Credit Reports

Some of the personal information that the Background Checker collect about you comes from third parties, and if those third parties are credit reporting agencies, then the Fair Credit Reporting Act of 1970, as amended by the Fair and Accurate Credit Transactions Act of 2003 (together, “FCRA”) may apply. If and to the extent that FCRA applies to the collection, use, disclosure, sharing, and storage of your personal information as described in this Privacy Policy, we certify that we will process your information in only accordance with our permissible purposes (as part of a business transaction that you have initiated and our legitimate business needs as described in this Privacy Policy); we will notify you if and when any negative adverse actions are taken against you; and we will, or you may request that the Background Checker, destroy your information in a way that prevents unauthorized access or use.

If FCRA applies to your information, you have the right to request that information from us and the Background Checker; to correct or delete inaccurate information; and to know which credit reporting agency provided your information.

By using the Service, you specifically consent to our, and Our background checker’s, COLLECTION, USE, sharing, disclosure, sharing, and storage of your personal information as described in this privacy policy.

13.   California Privacy Rights

To the extent that the CCPA applies to our practices with respect to PII and you currently reside in California, the CCPA provides you with certain rights.

A.   Consumers Rights Under the CCPA.

• California consumers have the right to request that we disclose Personal Information we have collected about them in the previous 12 months including, but not limited to, the categories of information collected by us, the source(s) of such information by category, and the purpose for collecting such information. This right may not be exercised more than twice in a 12 month period.  In the previous 12 months, we have collected the following categories of Personal Information about consumers;
• • Identifiers can be your name, unique personal identifiers (device identifier, IP Address, cookies, beacons, pixel tags, mobile ad identifiers), email, phone number, and similar information;
  • Personal Information Under the California Customer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”), which is similar in nature to Identifiers;
  • Internet/Network Activity. Internet Activity Information includes browsing history, cookies, search history and a consumer’s interaction with a website;
  • Professional and employment related information; and
  • Inferences drawn from any other category of Personal Information.

We collect Personal Information in the above categories from the consumers themselves, third parties, and by automatic means for the purposes described in this Privacy Policy, and as required to comply with applicable law.

• As a California consumer, you also have the right to request that we tell you which of your Personal Information we have disclosed for a business purpose, or sold, in the previous 12 months, if any. In the past 12 months, we have disclosed Personal Information falling under the following categories:
  • Identifiers;
  • CCRLPI;
  • Employment information; and
  • Internet/Network activity.

We disclose Personal Information in the preceding categories to the consumers themselves, our corporate customers, third parties as the consumer may direct, service providers, potential and actual successors in interest, and government and law enforcement agencies for either the purpose it was provided, the provision of Services, to comply with applicable law, or as otherwise described above in this Privacy Policy.

IN THE PAST 12 MONTHS WE HAVE NOT SOLD, AND DURING THE PERIOD OF TIME WHICH THIS PRIVACY POLICY IS POSTED WE SHALL NOT SELL, THE PERSONAL INFORMATION OF ANY CONSUMER, OF ANY AGE.

• You have the right to opt-out of the sale of your Personal Information, if applicable.
• You also have the right to request the deletion of the Personal Information that we have collected from you at any time. However, we may not be required to comply with such request under several circumstances including, but not limited to, when the data is necessary for the underlying transaction, to comply with applicable law, to detect security incidents, to debug glitches, and for our internal purposes.
• In the event that you exercise one of your rights under the CCPA, you have the right to not be discriminated against by us in any way, including by the denial of goods or services, providing you with a different level of goods or services, or charging you different prices or rates for the goods or services, unless the change in price is reasonably related to the value you receive from your Personal Information.

B.   How do you exercise your rights under the CCPA?

• You may submit your requests to exercise your rights under the CCPA by calling us, toll free, at [833-828-7283], or by emailing us at operations@curatepartners.com and putting CCPA in the subject line. When submitting a request via email, please indicate which CCPA right you wish to exercise and provide sufficient information to allow us to locate your file.
• We will acknowledge receipt of your request within 10 business days of receiving it, and will do our very best to respond within 45 calendar days of receipt of your request, and in no event will our response come more than 90 days after receiving your request. If we are unable to provide our response within the first 45 day window, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond.

Before we respond to any CCPA based requests to access or delete your Personal Information, we will take steps to reasonably verify the identity of the person making the request (“Requestor”) to make sure it’s you, or your authorized agent.  We do this to this avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way.  To do this, we will ask the Requestor to confirm at least two pieces of information that we have in our files.  As the sensitivity of the information being requested goes up, we will ask the Requestor to confirm more pieces of information. If an agent is acting on behalf of the consumer, we will need to also verify the agent’s identity and their authority to act on the consumer’s behalf.  For requests to delete information, after verification, we will confirm the consumer’s desire to delete one final time before actually deleting the information.  If the identity of the Requestor cannot be reasonably verified, either as the consumer or their agent, then in order to protect that consumer, we shall not disclose the Personal Information requested.

14.   Children and Privacy

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the CCPA, the Children’s Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from our servers, please contact us at operations@curatepartners.com. Our Service will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Service without your permission, please contact us at operations@curatepartners.com.

15.   Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us at operations@curatepartners.com.

Copyright © Curate Partners LLC. All rights reserved. The Site and Service are the property of Curate, and are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site and Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.