Polywork
Privacy Policy
Last Updated: January 28th, 2020
This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with ourservices.
Who We Are: Polywork is a platform for you to showcase your professional identity. Polywork is headquartered in New York, with operations in the United States, the EU, and other locations around the world. When we use the terms “Polywork”, “we”, “us” or “our” in this Privacy Notice, we are referring to Kalo Industries Inc and Kalo Industries Ltd.
Our Services: When we use the term “services”, we are referring to all the services that we offer on our own behalf, including our product offerings and the websites and mobile applications that post or link to this Notice. This Privacy Notice does not cover or address personal information and privacy practices relating to job applicants, employees and other personnel.
Region-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
− If you are based in the European Economic Area (“EEA”), see below for additional EEA-specific privacy disclosures.
What is Personal Information?
When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Our Collection Personal Information
From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.
Personal Information You Provide
We collect the following personal information you provide in connection with our services:
  • Contact information. We may receive information such as your name, email address, postal address, telephone number, username, and password when you communicate with us through the services, contact Customer Service, create an account, sign up to our marketing emails, enter a contest or sweepstakes, respond to a survey, or otherwise communicate with us. We may also collect any communications between you and Polywork, and any other information you provide to us.
  • Profile Information. When you create a profile, you are able to provide us with information such as your education, work experience, gender, salary, and employment status, skills, social account URLs, profile photo, and biography. Profile information is optional and visible by other users of the service.
  • User Content and Interactions through the Services. We collect information about how you use the services, your actions on the services, and content you post to the services, including the groups you belong to, your interaction with your connections on the services, photos and videos you post to the services, portfolio examples, comments on blog posts or reviews of our products, and any content you provide including through emails, in-app messages, chat, or other functionality ("User Content"). To share photos and video, we will access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in the "Settings" app of your device.
  • Comments, Suggestion, Chat and Opinions. When you contact us directly, e.g. by email, phone, mail or by completing an online form or participating in online chat, we will record your comments and opinions. We will also record comments and opinions you express when responding to surveys, entering a sweepstakes or taking part in promotions we run.
  • Address Book Information. With your permission, Polywork may access your contact list available on your mobile device or your email accounts so that you can locate your contacts on the services and invite your contacts to connect with our services. When we send the invitation to join the services, we will include your name and photo to let them know that you are the person extending the invitation. After sending these invitations, we may also send reminder emails to your invitees on your behalf, which may also include your name and photo.
Personal Information Automatically Collected
As is true of most digital platforms, we collect certain personal information automatically when you visit our online services, including:
  • Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
  • Analytics Data including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”).
  • Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.
For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please see our Cookie Notice.
Personal Information from Other Sources and Third Parties
We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.
We receive the same categories of personal information as described above from the following sources and third parties:
  • Business Partners, such as promotional partners collect personal information and often share some or all of this information with us. For example, we receive personal information from our partners to coordinate events, identify prospective customers, and conduct marketing.
  • Service Providers, such as analytics providers and promotional partners collect personal information and often share some or all of this information with us. For example, we receive personal information from service providers to analytics activities, facilitate survey activities, and prevent, investigate or provide notice of fraud or unlawful or criminal activity.
  • Data Providers, such as when we purchase or otherwise obtain lists or data from third-party list or data providers, distribution partners, or marketing firms, to correct or supplement personal information we collect. For example, we may obtain demographic personal information from third-party data providers to better understand the products and services that may interest you and, with your permission, to supplement your profile information. We may combine this information with the information we collect from you directly.
  • Other Polywork Entities, including other Polywork companies, businesses, brands and affiliated entities in our family of companies, so that information you provide to one brand may be used by another brand to provide you services or to communicate with you.
  • Social Networks, when you interact with us through a social media site or third party service, such as when you like, follow or share Polywork content on Slack, Google, Facebook, LinkedIn, Twitter, or other sites. We may receive information from the social network including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties.
  • Authentication Services You Connect to our Services, as some parts of our services may allow you to login through a third party social network or authentication service such as Slack, Facebook, Twitter, LinkedIn, or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third party site.
  • Publicly Available Sources, through which we collect personal information about you that we do not otherwise have, including contact information, employment related information and product interest information, from publicly available sources. We may combine this information with the information we collect from you directly.
Our Use of Personal Information
We may use personal information we collect to:
  • Process your registration on our services, including verifying your information to ensure its accuracy and validity.
  • Fulfill your requests (e.g., to provide you with information that you request).
  • Personalize your experience and customize content on our services relevant to your interests, including but not limited to targeted offers and ads through our website, email, social media channels, third-party sites or on other devices you may use.
  • Operate, maintain and provide to you the features and functionality of the services.
  • Send you important information regarding the services, such as certain changes to our terms, conditions, policies and/or other administrative information. Because this information may be material to your use of the services, you may not opt out of receiving such communications.
  • Inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, adding you to our email/mailing lists and permitting you to participate in sweepstakes, contests and similar promotions.
  • Help maintain the safety, security and integrity of our service, technology assets and business.
  • Use for our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the services, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns, including to inform our machine learning for purposes such as user engagement.
  • Perform the contract we are about to enter into or have entered into with you for the services.
  • Provide certain features or services that you have consented to (you may withdraw your consent for some uses of the data at any time by contacting us at the information provided below).
  • Comply with a legal or regulatory obligation, such as to respond to law enforcement requests and as required by applicable law, court order or governmental regulations and enforce our corporate reporting obligations and our Terms of Service, or to comply with applicable laws.
  • Fulfil the purposes disclosed at the time you provide your personal data or as otherwise set forth in this Notice.
  • Monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the services, you consent to the recording, storage and disclosure of such communications you send or receive for these purposes.
If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
Our Disclosure of Personal Information
Our services allow you to share information about yourself with other individuals and other companies, including other users and potential users of the services or other products or services offered by Polywork and third-party Social Networking Sites. Information on your profile is viewable by other users or visitors to our services and may also be viewable through public search or on third-party sites that you use. We do not control who reads the information you share or what others may do with this information, so we encourage you to use discretion and caution with respect to your personal information. Also, when sharing information about others, please consider their safety and privacy and get their consent for that sharing.
We may also disclose personal information in the following ways:
  • Within Polywork. We are able to offer you the products and services we make available because of the hard work of your team members across all the Polywork entities.
  • Select Marketing and Strategic Business Partners. We may share limited personal data with our preferred marketing and strategic business partners so that they can provide you with information and marketing messages about products or services that may interest you. These parties may use your information in accordance with their own privacy policies.
  • Service Providers, consultants and other vendors who perform functions or services on our behalf and under our instructions to make our services available to you, including infrastructure partners (such as AWS), customer support service providers, marketing outreach and analytics service providers, safety check providers, cybersecurity partners, anti-fraud analytics companies, and similar partners.
  • Advertising Networks and technology companies, including Google, Facebook and Twitter, and companies that measure advertising performance and attribution. We share personal data with advertising networks or permit these networks to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers, to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please see our Cookie Notice.
  • Promotional Partners with whom we partner to provide contests and sweepstakes or other joint promotional activities. These partners will usually be identified in the contest rules or promotional materials.
  • Social Networks, such as Facebook and LinkedIn, where you have given permission to do so or where you have used your social network account to log in to Polywork. If you have chosen to do this, your data will be governed by the privacy policy of that social network.
  • The Public, when you provide feedback or post user content on our services (e.g., if you post a review on our website or comment on our social media sites), your information (e.g., your first name and comments) may be displayed on our websites or on our social media pages.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
    • to detect, suppress, or prevent fraud;
    • to reduce credit risk and collect debts owed to us;
    • to protect the health and safety of us, our customers, or any person; or
    • as otherwise required by applicable law.
  • Consent: We may disclose personal information about you to certain other third parties with your consent.
Children’s Personal Information
Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
Third-Party Websites
Our websites and online services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
California’s “Shine the Light”
California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please email us at privacy@polywork.com.
Contact Us
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@polywork.com.
Alternatively, inquiries may be addressed to:
Polywork
214 W 29th Street, 5th Floor
New York, NY 10001
ADDITIONAL EEA PRIVACY DISCLOSURES
Last Updated: January 28th, 2020
Unless otherwise expressly stated, capitalized terms in these Disclosures have the same meaning as defined in the Privacy Notice above.
Scope of Disclosures
These Additional European Economic Area (EEA) Privacy Disclosures supplement the information contained in our Privacy Notice, but unlike the Privacy Notice, these Disclosures apply only to our processing of your personal data where you are based in the EEA.
Kalo Industries Inc. is the data controller responsible for the collection and use of such personal data.
Personal Data Disclosures
When we use the term “personal data” in these Disclosures, we mean any information relating to an identified or identifiable natural person.
Legal Bases for Processing
We rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
Category of Personal Data How We Use the Personal Data Legal Bases for Processing
a) Profile Data, such as name, age, experience, skills, and location
(b) Contact Data such as email address, phone number, or social media user account, as limited by your privacy settings
(c) Data from Social Networking Sites (If you use LinkedIn or Google to log-in to the Polywork services), including any interests or other data imported from your Social Networking Sites
(d) Technical Data, such as device ID or IP Address, including timestamps
To register you as a new member. (a) Performance of a contract with you
(b) With your consent in the case of sensitive personal data
a) Profile Data, such as name, age, experience, skills, and location
(b) Contact Data such as email address, phone number, or social media user account, as limited by your privacy settings
(c) Data from Social Networking Sites (If you use LinkedIn or Google to log-in to the Polywork services), including any interests or other data importedfrom your Social Networking Sites.
(d) Technical Data, such as device ID or IP Address, including timestamps
(d) Communications Data, including the content of messages, the name and ID of the recipients of the communications, the timestamp, IP address and/or Device ID of the parties to the messages
(e) Photos, including various analytics and scoring results
(f) Usage Data
(g) Analytics and other scores used to make matches with other Polywork users
(h) Technical Data
To provide the Polywork services to you, including:

(a) Maintaining a profile, answering questions, and providing information about yourself;
(b) Analysing your personal data to match skils and performance; and
(c) Allowing you to communicate with other users of Polywork to find professional opportunities.
(a) Performance of a contract with you
(b) With your consent (with regard to your Sensitive Personal Data)
(a) Profile Data
(c) Contact Data
(d) Communications Data
(e) Photos
(f) Usage Data
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy
(b) Communicating with you
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(a) Profile Data
(b) Contact Data
(c) Usage Data
(d) Any information, content, or submissions required as set forth in the contest rules when published
To enable you to partake in a prize draw, competition or complete a survey (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(a) Profile Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Communications Data
(f) Third Party Data provided to us by trusted partners, including proprietary scores, red flags, demographic information, usage data, and other information used to determine whether a Polywork account is being used improperly, accessed by an unauthorized third party, or represents a security or fraud risk to the Polywork community
To administer and protect our business, the Polywork services, this website and your personal data (including security, fraud, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, providing administration and IT services, cybersecurity, preventing fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
(a) Device ID
(b) IP Address
(c) Location (at country, state, city, or postal code level)
(d) Gender
(f) Technical Data such as OS version, hardware type, software type.
(g) Cookies, pixels, or advertising tags
(h) Usage Data
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
(b) With your consent for targeted advertising and profiling to serve more accurate advertising content to you.
(a) Profile Data
(b) Usage Data
(c) Technical Data
(d) Communications Data
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
(a) Profile Data
(b) Transaction Data
(c) Usage Data
(d) Communications Data
(e) Location Data (at country, state, city, or postal code level)
(f) Technical Data
(g) Any other information we are compelled to provide by law
To respond to requests from law enforcement Necessary to comply with our legal obligations
You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our services and products. For example, we need your personal data to facilitate and deliver an order that you request. If you choose not to provide us with your personal data, we may not be able to provide you with a service or product you request.
Data Retention
We retain personal data about you for as long as is necessary for the purposes set out in these Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.
The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:
Legitimate Interests Where we are processing personal data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects
Consent Where we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your data erased (please see the Your Privacy Right section below)
Contract Where we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship
Legal Obligation Where we are processing personal data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfil the legal obligation
Legal Claim We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.
International Data Transfers
We may transfer personal data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the Our Disclosure of Personal Information section of the Notice. Personal data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which personal data is transferred may not provide the same level of protection for personal data as the country from which it was transferred.
We may transfer personal data about you outside the EEA and when we do so, we rely on appropriate or suitable safeguards recognized under the GDPR including adequacy decisions, standard contractual clauses, and the EU-U.S. Privacy Shield.
Adequacy Decisions
We may transfer personal data about you to countries that the European Commission has deemed to adequately safeguard personal data.
Standard Contractual Clauses
The European Commission has adopted Standard Contractual Clauses, which provide safeguards for personal data transferred outside of the EEA. We may use these Standard Contractual Clauses when transferring personal data from a country in the EEA to a country outside the EEA that has not been deemed to adequately safeguard personal data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.
EU-U.S. Privacy Shield
The EU-U.S. Privacy Shield Framework (Privacy Shield) was designed by the U.S. Department of Commerce and the European Commission to ensure adequate protection for Personal Data transferred to a company certified under Privacy Shield. If we transfer any personal data about you from the EEA to a third party outside the EEA who is certified under Privacy Shield as set forth by the U.S. Department of Commerce, we may rely on such certification to ensure adequate protection for personal data so transferred.
Your Privacy Rights
You have the following rights in relation to your personal data (subject to certain limitations at law):
Access The right to access and obtain a copy of personal data about you, as well as information relating to its processing.
Rectification The right to correct or update any personal data about you that is inaccurate or incomplete.
Restriction of Processing The right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Erasure The right to request the deletion or erasure of personal data about you without undue delay if the continued processing of that personal information is not justified.
Portability The right to obtain a copy of personal data about you in an easily accessible format and the right to transmit that personal data to another controller.
Objection to Processing You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.
Right to Withdraw Consent
Where we rely on your consent for processing of your personal data, you also have the right to withdraw your consent to such processing, subject to certain limitations at law.
You may withdraw your consent by sending us an email at privacy@polywork.com.
Submitting Requests
To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional personal data from you. In certain circumstances, we may decline a request to exercise the rights described above.
Right to Lodge a Complaint
If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). You may also contact our Lead Supervisory Authority, the Data Protection Commission, with any questions about our privacy practices.
Updates to These Disclosures
We may update these Disclosures from time to time. When we make changes to these Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. If we make material changes to these Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@polywork.com.
Alternatively, inquiries may be addressed to:
Polywork
214 W 29th Street, 5th Floor
New York, NY 10001