Privacy Policy

18to22 Inc., an Arizona corporation (“the Company,” “we,” “our,” or “us”) is committed to protecting your privacy based on our privacy policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through any of our websites, applications, products, and services that link to this policy (our “Services” as defined in our Terms of Use) and our practices for using, maintaining, protecting, and disclosing that information.

Our Services are intended for users located in the United States. We are based in the United States and our Services are designed for job seekers aged 18 or older who seek employment opportunities in the United States. If you access or use the Services from outside the United States, you are responsible for understanding that other privacy laws may apply.

This policy applies only to information we collect:

• Through the Services;
• In communications, including email, chat, and other electronic messages, between you and the Services;
• When you interact with our advertising, job widgets, or applications on third-party websites and services, this Privacy Policy applies to the information we collect through those interactions. The third party’s own privacy policy governs the information that the third party collects. We encourage you to review the privacy policies of any third-party websites you visit; and
• From employers, employer representatives, service providers, business partners, payment processors, analytics providers, security and anti-fraud services, public sources, and integrations with employer systems or third-party job sites, if those integrations are made available through the Services.

This policy does not apply to information:

• Collected by us offline or through any other means, including on any other website operated by the Company or any third party that does not link to this policy; or
• Collected by any third party, including through any applications or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we may use it. By accessing our website, interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here indicates your acceptance of those changes, so please check the policy periodically for updates.

Children and Minors’ Data

You must be 18 years or older to use our Services. No one under age 18 may provide any personal data through or on the Services. We do not knowingly collect personal data from those under 18 years of age. If you are under 18, do not use or provide any information on the Services or through any of its features, register on the Services, make any purchases through the Services, use any of the interactive or public comment features of the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal data from a person under 18, we will delete that information. If you believe we might have any information from or about a person under 18 years of age, please contact us at privacy@18to22.net.

The Personal Data That We Collect or Process

“Personal data” means data or information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, email address, credit card number, or any other identifier we may use to contact you online or offline).

The types and categories of personal data we collect or process include but are not limited to:

• Account and contact information, including real name, address (such as home address, work address, or other address), email address, telephone number, username, date of birth, similar identifiers, and other contact information you provide to us.
• Payment information, including credit card or debit card information.
• Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
• Demographic information, including your age, gender, income level, education, marital status, medical condition, disability, citizenship status, military and veteran status, and genetic information.
• Location information, including general geographic location, such as country, state, province, or city information, and precise geolocation information.
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
• Content and information you elect to provide as part of your profile or in any reviews you make through the Services or emails, chats, or other communications sent to us.
• Job candidate information, including profile information, resumes, work history, education history such as degrees, certifications, institutions attended, academic records, credentials or licenses, job preferences, salary expectations, application materials, screener-question responses, messages with employers, interview scheduling information, performance evaluations, letters of recommendation, employer name, job title, other employment-related data, and other information you choose to provide in connection with your job search or applications.
• Employer and business account information, including employer account information, employer representative contact information, business information, job advertisements, employer pages, screener questions, hiring criteria, candidate-management activity, communications, subscription information, account administration information, or other transactions through the Services.
• Application, recruiting, and communications information, including job applications, attached files, application status, employer messages, candidate-management information, virtual interview scheduling information, and information generated through communications features that we make available through the Services.
• Payment and billing information, including billing contact information, transaction records, subscription status, limited payment card details, payment method metadata, invoices, receipts, chargeback or dispute information, and information handled by third-party payment processors in connection with Paid Services (as defined in our Terms of Use).
• Voluntary demographic or self-identification information that you choose to submit, or that an employer requests (including where required by law), through the Services, such as race, ethnicity, sex, disability, veteran status, or similar information requested in connection with an employment opportunity.
• Identity document information.
• Internet or similar network activity such as browsing history, search history, clickstream data, and information on a consumer’s interaction with a website, application, or advertisement.
• Sensory data such as audio, electronic, visual, or similar information (e.g., profile photos, video interviews if offered through the Services).
• Inferences such as inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including any job-matching recommendations or suitability assessments generated by the Services.
• Sensitive personal information such as Social Security number, driver’s license number, state identification card number, passport number, account log-in credentials (username and password), financial account or payment card information, precise geolocation, racial or ethnic origin, religious beliefs, contents of mail, email, and text messages (where the Company is not the intended recipient), and any genetic data, biometric information processed for identification, or health-related information, if collected through the Services.

If you are a California resident, additional information may apply to you as described below in the Additional Information for California Residents.

Some of the information identified above, including precise geolocation information or voluntary demographic or self-identification information, may be considered sensitive data under certain state privacy laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, Services, or information.

You should not include sensitive information in your profile, resume, application materials, messages, or other submissions unless that information is specifically requested and necessary for the applicable feature or employment opportunity. Information you submit may be shared with employers or other users as described in this policy and our Terms of Use.

We also collect:

• Statistical or aggregated data that does not directly identify a specific person. We may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products, or jobs that you search for, view, click, save, like, start to apply for, or apply to, time spent on employer pages, responsiveness to employer messages, page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), application events, or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account or profile, fill out a form, purchase a service, post or manage a job advertisement, search for jobs, save or click on jobs, apply for jobs, upload or update a resume, answer screener questions, communicate with employers or job candidates, schedule or participate in interviews, use candidate-management tools, create, upload, or post content to the Services, including reviews and documents, or contact us.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, browser type, device information, and information collected through cookies, pixels, web beacons, APIs, logs, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, communication data, job advertisements viewed, applications started or completed, messages or alerts opened, and which resources and Services features you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
• Pixels, APIs, server logs, software development kits, and similar technologies that help us measure use of the Services, support job alerts and communications, detect fraud or spam, and provide or improve job search, matching, analytics, and employer features.

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses through the controls we make available, by using a browser or extension that supports the Global Privacy Control where required by applicable law, or by contacting us using the Contact Information below. Please note that some Services features may be unavailable as a result.

We may use the following types of cookies and tracking technologies:

• Essential cookies: These cookies are necessary for the Services to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms.
• Performance and analytics cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us know which pages are the most and least popular and see how visitors move around the Services.
• Functional cookies: These cookies enable the Services to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Targeting and advertising cookies: These cookies may be set through our Services by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (“DNT”) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies, data analytics providers.
• Your device manufacturer.
• Your internet or mobile service provider.
• Employers, employer systems, employer representatives, third-party job sites, communications providers, payment processors, hosting providers, integrations with employer systems, and other service providers or business partners that support the Services.
• Social media platforms and public sources.
• Security and anti-fraud services.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from employers, employer representatives, service providers, business partners, payment processors, email platform providers, hosting and content delivery providers, analytics providers, public sources, security and anti-fraud services, and integrations with employer systems or third-party job sites, if those integrations are made available through the Services.

De-Identified and Aggregated Data

We may create de-identified or aggregated data from personal data by removing or altering data components that make the data personally identifiable. We maintain and use de-identified data in de-identified form and do not attempt to re-identify the data, except as permitted by law to test our de-identification processes. De-identified data is not personal data and is not subject to this policy.

How We Use Your Information

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

• Provide you with, maintain, and improve the Services and any content, features, information, products, or services that we make available through the Services.
• Fulfill and manage subscriptions and payments.
• Fulfill any other purpose for which you provide it.
• Provide you with notices about your account or subscription, including expiration and renewal notices.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them. Our analysis may include the use of artificial intelligence, machine learning, and similar technologies as described in the Artificial Intelligence and Automated Tools section below.
• Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties’ services. We may use your information to model, segment, target, offer, market, and advertise our Services.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any products or services we offer or provide through them.
• Create, maintain, secure, authenticate, and administer accounts, profiles, employer accounts, and access credentials, including by verifying email addresses or phone numbers and addresses helping prevent fraud, spam, unauthorized access, or misuse of the Services.
• Facilitate job searches, job applications, resume and profile features, candidate-management tools, communications between candidates and employers, interview scheduling, virtual communications, and the transmission, formatting, assembly, delivery, and management of application materials.
• Make profiles, resumes, application materials, contact information, and related job candidate information available to employers and other users of the Services, including through resume search, employer candidate-management features, and application submission tools.
• Recommend jobs to job candidates, suggest candidates or profiles to employers, personalize search results, provide job alerts, identify potential matches, and display informational labels, summaries, or metrics related to jobs, candidates, applications, or employer activity.
• Provide, administer, bill for, and support employer products and Paid Services, including sponsored or promoted job advertisements, enhanced visibility features, candidate-management tools, subscription renewals, invoices, receipts, payment disputes, chargebacks, performance reports, dashboards, and analytics.
• Support legal compliance, safety, security, fraud prevention, spam prevention, quality control, data analysis, troubleshooting, and enforcement of our Terms of Use and other agreements.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our Services.
• We and our third-party partners may link your various devices so that content you see on one device can result in relevant advertising on another device. We and our partners may use cross-device linkage to serve interest-based advertising, perform analytics, and measure the performance of our advertising campaigns. You may be able to opt out of cross-device tracking through your device settings or the opt-out mechanisms described in the Advertising, Marketing, Cookies, and Other Tracking Technologies Choices section below.

We do not use sensitive personal information — including racial or ethnic origin, religious beliefs, health-related information, or genetic data — for purposes of automated decision-making, profiling, or employment screening through our AI-powered tools.

We may also use your information to contact you about services, job opportunities, job alerts, employer messages, or other information that may be of interest to you. If you do not want us to use your information in this way, contact us using the Contact Information below. For more information, see Your Rights and Choices About Your Information.

Artificial Intelligence and Automated Tools

We may use artificial intelligence, machine learning, large language models, and similar automated tools to support the Services, including search, matching, recommendations, candidate-management tools, job candidate summaries, translations, fraud prevention, quality control, data analysis, and service improvement. These tools are intended to support, not replace, user and employer judgment, and the Company does not make hiring or employment decisions on behalf of employers.

We may use de-identified or aggregated data derived from your use of the Services to improve our artificial intelligence and machine learning models. We do not sell your personal data to third parties for the purpose of training their AI or machine learning models. If we intend to use identifiable personal data for AI training purposes beyond what is described in this policy, we will provide you with additional notice and, where required by applicable law, obtain your consent.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or that you provide as described in this privacy policy:

• To contractors, service providers, processors, and other third parties we use to support our organization and the Services, including hosting providers, analytics providers, security and anti-fraud vendors, email and communications vendors, payment processors, customer support providers, and providers of artificial intelligence, machine learning, or similar technology, who are required to use personal data only as permitted for the services they provide to us.
• To our lawyers, accountants, consultants, business and financial advisers, and similar professional advisers who need the information to provide services to us and are subject to confidentiality obligations.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To employers, employer representatives, and employer account administrators when you apply for a job, make your profile or resume available, communicate with an employer, interact with an employer page or job advertisement, or otherwise use Services features that are designed to connect job candidates with employers.
• To employer account owners and administrators when you access or use the Services through an employer account. Actions taken through an employer account and information provided through that account may be visible to the employer.
• To third-party payment processors and related financial service providers to process payments, subscriptions, renewals, refunds, chargebacks, and payment disputes for Paid Services.
• To analytics, security, anti-fraud, and quality-control providers to measure performance, improve the Services, detect or prevent spam, fraud, abuse, or unauthorized access, and maintain the integrity and safety of the Services.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including in response 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 our organization, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• To government agencies, law enforcement, or regulatory authorities on a voluntary basis when we have a reasonable belief that disclosure is necessary to report suspected fraud, criminal activity, threats to safety, harassment, misrepresentations, libel, slander, threat of death or serious physical injury or other matters of public concern.

The categories of personal data we may disclose include:

• Account and contact information.
• Payment information.
• Account history, including information about your subscription or account.
• Demographic information.
• Location information, including general geographic location and precise geolocation.
• Device information.
• Content and information you elect to provide to us.
• Identity document information.
• Job-board activity and performance information, including searches, clicks, saved jobs, liked jobs, applications started or completed, message responsiveness, employer page activity, job advertisement performance data, and related analytics.
• Job candidate information, including profiles, resumes, application materials, screener-question responses, credentials or licenses, work history, education history, job preferences, salary expectations, communications, application status, and information generated from job-search activity.
• Employer and business account information, including business contact information, employer account information, employer representative information, job advertisements, employer pages, screener questions, candidate-management activity, subscription information, and performance data.
• Communications, scheduling, and virtual communications information, including messages, interview scheduling information, automated messages, audio, visual, or written information exchanged through communications features if those features are made available through the Services.
• Payment, billing, subscription, transaction, invoice, receipt, refund, payment dispute, and chargeback information related to Paid Services.
• Inferences drawn from the above, including job-matching scores, candidate suitability assessments, salary estimates, and other AI-generated outputs.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, Marketing, Cookies, and Other Tracking Technologies Choices

Cookies and Other Tracking Technologies. We use cookies and similar tracking technologies to collect and use personal data about you, including to serve interest-based advertising. For more information about the types of cookies we use, why we use them, and how you can control cookies, please see the cookie settings or preferences available through the Services.

Promotions by the Company. If you do not wish us to use your information to promote our own or third parties’ services, you can opt out by contacting us using the Contact Information below.

Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target audience preferences, you can opt out by contacting us using the Contact Information below.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt out by contacting us using the Contact Information below. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”), see NAI: How to Opt Out. You may also use a browser or browser extension that supports the Global Privacy Control (“GPC”) to signal your opt-out preference to websites you visit.

Job alerts, profile visibility, and employer contact choices. You may be able to adjust job alert, communication, profile visibility, and employer contact preferences through your account settings. Changing these settings may affect whether employers can find your profile or contact you through the Services, but it may not affect personal data that has already been shared with employers or other third parties.

Artificial Intelligence Principles

We are committed to ensuring that AI tools used in our Services do not make employment decisions on behalf of employers and are designed to support, not replace, human judgment. For more information about how we use AI, please see our Terms of Use.

When we use AI tools in connection with the Services, we do not process sensitive personal information — including racial or ethnic origin, religious beliefs, health-related information, or genetic data — through our AI systems for purposes of automated decision-making, profiling, or employment screening. Any AI-powered features offered through the Services (such as job matching, candidate summaries, or search recommendations) rely on non-sensitive professional and employment-related information, job preferences, and platform activity data.

Location Data Choices

Location Data. We may use general location information, such as city, state, ZIP code, or job location, to support job searches, job recommendations, employer search results, and related Services features. If we offer a feature that collects real-time or precise device location, you can choose whether to allow that collection through your device settings or other controls we provide, and some Services features may be unavailable or not function properly if you block location information.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, which will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Using Personal Data for Sales, Targeted Advertising, and Profiling for Certain Legal or Similarly Significant Decisions. You may request that we do not use your personal data for these purposes. Some states may also grant you the ability to learn more about or challenge those automated decisions.

Important: The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please contact us using the Contact Information below. Some browsers and browser extensions support the GPC that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

We will acknowledge receipt of your request within 10 business days and will respond substantively within 45 days of receipt. If we require additional time, we will notify you of the extension and the reason for it. In no event will our total response time exceed 90 days from the date of your original request.

Nevada provides its residents with a limited right to opt out of certain personal data sales. If this applies to you, you may submit a request using the Contact Information below.

If you are a California resident, additional information may apply to you as described in the Additional Information for California Residents below.

Additional Information for California Residents

This section is provided for transparency for California residents and applies to the extent California privacy laws, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act and its implementing regulations, apply to us. For purposes of this section, “personal information,” “sensitive personal information,” “sell,” and “share” have the meanings given to those terms under applicable California privacy law.

Categories of Personal Information We Collect

Depending on how you use the Services, we may collect the following categories of personal information: identifiers; California customer records information; protected classification characteristics, if you or an employer voluntarily provide self-identification information through the Services; commercial information, including subscription and payment-related records; internet or other electronic network activity information; geolocation information, limited to general location information unless a feature collects more precise location with appropriate notice or consent; professional or employment-related information; inferences drawn from the information described in this policy; and sensitive personal information, if you voluntarily provide it or if it is necessary for a specific feature or employment opportunity.

The examples of information in those categories include the information described in The Personal Data That We Collect or Process section above, including account and contact information, account history, device information, job candidate and application information, employer and business account information, voluntary demographic or self-identification information, job-board activity and performance information, communications and scheduling information, and payment and billing information.

Where required by applicable California privacy law, California residents have the right to be notified of the categories of personal information we collect and the purposes for which we collect, use, disclose, sell, or share that personal information, as described in this section and elsewhere in this policy.

Sources of Personal Information

We may collect personal information from you directly, from your use of the Services, from employers and employer representatives, from service providers, contractors, payment processors, analytics providers, security and anti-fraud services, public sources, and from integrations with employer systems or third-party job sites, if those integrations are made available through the Services.

Purposes for Collection, Use, and Disclosure

We may collect, use, and disclose personal information for the business and commercial purposes described in How We Use Your Information and Who We Disclose Your Information To, including to provide and maintain the Services, administer accounts, facilitate job searches and applications, connect job candidates and employers, operate employer and Paid Services, process payments, send service communications and job alerts, personalize and improve the Services, perform analytics and quality control, use artificial intelligence and automated tools as described in this policy, prevent fraud and spam, secure the Services, comply with law, enforce agreements, respond to legal process, and evaluate or complete corporate transactions.

Disclosures for Business Purposes

We may disclose the categories of personal information described above for business purposes to service providers, contractors, processors, payment processors, analytics providers, security and anti-fraud providers, communications vendors, hosting providers, customer support providers, employers, employer representatives, employer account administrators, professional advisers, government authorities, and parties involved in actual or potential corporate transactions. The categories of personal information we have disclosed for a business purpose include: identifiers; California customer records information; protected classification characteristics (if voluntarily provided); commercial information; internet or other electronic network activity information; geolocation information; professional or employment-related information; education information; inferences; and sensitive personal information (if voluntarily provided or necessary for a specific feature).

Sale, Sharing, and Targeted Advertising

We do not sell personal information for monetary consideration. We may “share” personal information (as that term is defined under California law) with advertising networks and ad-technology partners for cross-context behavioral advertising purposes. The categories of personal information we may share include identifiers, internet or other electronic network activity information, inferences, and device information. If our practices change, we will update this policy and provide the opt-out methods required by applicable law.

You may opt out of the sharing of your personal information for cross-context behavioral advertising by contacting us using the Contact Information below, by using a browser or extension that supports the Global Privacy Control, or through any opt-out mechanism we make available on the Services.

We do not knowingly sell or share personal information of consumers under 16 years old.

Sensitive Personal Information

We may collect sensitive personal information only as described in this policy or when you or an employer voluntarily provide it through the Services. We do not use or disclose sensitive personal information for purposes other than those permitted by applicable California privacy law, unless we provide additional notice and any required right to limit.

If we use or disclose sensitive personal information for purposes that trigger a right to limit under applicable California privacy law, California residents may direct us to limit our use and disclosure of sensitive personal information to purposes permitted by law, such as providing the Services requested, maintaining account security and integrity, preventing fraud or misuse, and other limited purposes allowed by law.

California Privacy Rights

To the extent applicable California privacy law applies to us, and subject to applicable exceptions, California residents may have the right to: (a) know or access the categories and specific pieces of personal information we have collected about them; (b) know the categories of sources from which we collected that personal information; (c) know the business or commercial purposes for which we collect, use, disclose, sell, or share that personal information; (d) know the categories of third parties to whom we disclose personal information; (e) know the categories of personal information we sell, share, or disclose to third parties; (f) receive a portable copy of certain personal information; (g) request deletion of personal information we collected from them; (h) request correction of inaccurate personal information; (i) opt out of the sale or sharing of personal information, including through a user-enabled opt-out preference signal where required by law; (j) limit certain uses and disclosures of sensitive personal information; and (k) be free from discrimination or retaliation for exercising their California privacy rights. Where the CCPA applies, you may make a request to know up to twice in any 12-month period, free of charge.

To the extent prohibited by applicable California privacy law, we will not ask California residents to waive their rights, and any contract provision or other agreement that purports to waive those rights is unenforceable.

How to Exercise California Rights

Where applicable, you may exercise your California rights by using the controls available in your account, submitting a request through any privacy request form we make available, contacting us using the Contact Information below, or using a browser or extension that supports the Global Privacy Control for opt-out preference signals where required by applicable law.

We may need to verify your identity or authority before responding to certain requests, and we will use personal information provided with the request only to verify and respond to the request. You may use an authorized agent to submit a request on your behalf if the agent provides proof of authorization and, where required, you verify your identity directly with us.

We will confirm receipt of your request within 10 business days and provide a substantive response within 45 days. If we require additional time, we will notify you of the reason and the extension, which will not exceed an additional 45 days (90 days total from the original request). If we deny your request in whole or in part, we will explain the basis for the denial unless legal or regulatory restrictions prevent us from doing so, and we will describe any appeal process available under applicable law.

Financial Incentive Programs

We do not currently offer any financial incentive programs that involve the collection, sale, or deletion of personal information. If we offer such a program in the future, we will provide the material terms of the program and obtain your opt-in consent before enrollment.

California “Shine the Light” Law

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. If we change this practice, we will update this policy and provide an opt-out mechanism.

Retention

Where California privacy law applies to us, we retain each category of personal information for as long as reasonably necessary for the purposes described in this policy and in the How We Retain Your Personal Data section, below, including to provide the Services, maintain business records, comply with law, resolve disputes, enforce agreements, and prevent fraud, spam, abuse, or unauthorized access.

Accessibility

If you need this section in an alternative format due to a disability, please contact us using the Contact Information below.

Appeal Process

If we deny your privacy request, in whole or in part, you may appeal that decision by emailing us at privacy@18to22.net within 60 days of receiving the denial. Please include the word “Appeal” in the subject line and describe the basis for your appeal.

We will respond to your appeal within 45 days of receipt. If we deny your appeal, we will provide you with a written explanation of the reasons for the denial and inform you of your right to file a complaint with the attorney general of your state of residence. Contact information for applicable state attorneys general offices will be provided in the appeal denial notice.

How We Protect Your Personal Data

We use commercially reasonable measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

How We Retain Your Personal Data

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal, regulatory, tax, accounting, or other requirements.

The following table sets forth our default retention periods for the categories of personal data we collect. These periods may be extended where legally required or necessary for ongoing legal proceedings, audits, or dispute resolution.

These are default retention periods and may be extended where legally required or necessary for ongoing legal proceedings, audits, or dispute resolution. When your personal data is no longer required for the purposes described in this policy, we will securely delete or anonymize it in accordance with our data retention and disposal procedures.

For example, we may retain account records, profiles, resumes, application materials, screener-question responses, messages, job advertisements, employer account records, candidate-management information, payment and transaction records, invoices, receipts, security logs, analytics, and records needed to comply with law, resolve disputes, enforce agreements, prevent fraud or abuse, operate the Services, and maintain business records.

If you disable, delete, or terminate your account, we may retain personal data after account termination where retention is stated in the Terms of Use, reasonably necessary, or legally permitted. Deleting or modifying personal data in your account may not delete or modify copies that were previously sent to employers, employer representatives, service providers, or other third parties, and you may need to contact those parties directly regarding their copies.

If you are a California resident, additional information applies to you as described in the Additional Information for California Residents section above.

Additional U.S. State Privacy Disclosures

In addition to the California-specific and Nevada-specific disclosures above, residents of other states with comprehensive privacy laws — including Colorado (effective July 1, 2023), Connecticut (effective July 1, 2023), Virginia (effective January 1, 2023), Utah (effective December 31, 2023), Oregon (effective July 1, 2024), Texas (effective July 1, 2024), Montana (effective October 1, 2024), and other states as their laws take effect — may have similar rights to access, correct, delete, and port their personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling activities. To exercise any of these rights, please contact us at privacy@18to22.net. We will process your request in accordance with the privacy law applicable in your state of residence.

Annual Privacy Metrics

Where required by applicable law, we will publish annual metrics regarding the privacy requests we receive and how we respond to them, including the number of requests to know, delete, and opt out, and our response rates and median response times.

Third-Party Links

Our Services may contain links to other websites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last modified is identified at the top of the page. We will notify you of changes to this policy by updating the “last modified” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us through the privacy controls available in your account, any privacy request form we make available, or at: privacy@18to22.net.

Privacy contact email: privacy@18to22.net