privacy policy

Appendices:

Appendix A - Advertising networks and their partners

Appendix B - Analytics and other service providers

1. Who We Are
2. fair pair ("fair pair" or the "Company") with a mailing address of 1712 Pioneer Avenue Suite 500, Cheyenne, WY 82001 is responsible for the processing of personal information collected and processed via the Company's websites (the “Websites”), fair pair devices, products, services, online stores and mobile applications referring to this privacy policy (hereinafter together the "fair pair Services"). This privacy policy applies to all users of the fair pair Services.
3. Scope and Purpose
4. This privacy policy (the “Privacy Policy”) applies to all fair pair Services for users who are residents of the United States (the “Users”). Its purpose is to inform Users about the way fair pair processes Personal Data.
5. Definition of Personal Information
6. Personal information is any information that directly or indirectly identifies a User (“Personal Information”). Anonymized or aggregated information, which would otherwise be considered Personal Information, that has been processed appropriately to make it non-identifiable, is excluded from the definition of Personal Information.
7. How We Collect Personal Information

   The Personal Information processed by fair pair comes from three sources:

   • Personal Information provided by the User: this is the data that the User sends or provides to us, in particular when registering with the fair pair Services, in the context of communication(s) that the User sends to fair pair (for example, a request for assistance), or when the User agrees to respond to a survey;
   • Personal Information collected via the use of the fair pair Services: this data is generated by or collected on the occasion of the use of the fair pair Services (for example, the identification and characteristics of the terminals used to access the fair pair Services, the generation of logs, etc.);
   • Personal Information collected via other sources: this is data that is transmitted to us via third parties with whom we contract, in particular subcontractors and partners.
8. What Personal Information We Collect

   fair pair may collect Personal Information when a User uses the fair pair Services, and in particular the following data (each category of data includes non-exhaustive examples to enable a better understanding of the type of data collected):

   Information About You That You Share With Us Directly

   • When you use our Services (whether through a social network or through fair pair Services directly), you may give us information directly (like when you’re setting up your account) and we will store that on our systems and use it for the purposes described in this Privacy Policy.
   • Some apps or parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us some or all of the following information:
     • your first and last names;
     • your cellphone number;
     • your e-mail address;
     • a password; and
     • other information that helps us make sure it’s you accessing your account or helps us improve our services.

   Payment Information

   • fair pair or its third-party payment processor may collect the billing and financial information it needs to process charges owed by employers or job posters. This may include your postal address, e-mail address, social security number, account numbers, bank information, and financial information. fair pair does not collect or store your financial information, like credit card numbers. However, fair pair’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order. fair pair may also obtain the billing and payment information that you provide when your purchase is processed by someone else such as when you purchase something in an app on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies. Please note that purchases of third-party credits or currencies may also be subject to those parties’ policies.

   Customer Support Correspondence

   • Except as provided herein, when you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address). We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support and improve the Services.

   Information You Give Us For Text Messaging Services

   • We receive and store the information you provide, including your mobile telephone number, when you choose to create an account with fair pair.
   • To enhance your experience and streamline the account verification process, we read your SMS to auto fill the One-Time Password (OTP) sent to your mobile. This ensures a faster and more secure login without the need for manual entry.

   Information About You That We Get From Connected Third-Party Applications, Including Social Networks (like Facebook)

   • If you access any of fair pair’s Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook, fair pair may receive certain information about you from the provider of the third-party application. The information we receive depends on the fair pair service you’re using, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.
   • For example, fair pair may collect and store some or all of the following information shared by the provider of the connected third-party application:
     • your first and last name;
     • your physical location and that of the devices you use to access our Services;
   • If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy.
   • If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

   Cookies and Automated Information Collection

   • We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:
     • cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;
     • web beacons, which let us know if a certain page was visited or whether an e-mail was opened;
     • tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and
     • local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-app preferences and speed up load times.
   • We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:
     • IP addresses;
     • the type of computer or mobile device you are using;
     • your operating system version;
     • your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
     • your browser types;
     • your browser language;
     • referring and exit pages, and URLs;
     • platform type;
     • the number of clicks on a page or feature;
     • domain names;
     • landing pages;
     • pages viewed and the order of those pages;
     • the amount of time spent on particular pages; and
     • the date and time of activity on our websites or apps.
   • In some cases, we may connect the above information with your social network ID or fair pair user ID.

   Other Information from Your Mobile Device

   • If you use fair pair services on your mobile device, in addition to your device identifiers, we may also collect:
   • the name you have associated with your device;
   • your telephone number;
   • your country; and
   • your specific geolocation;
     • We utilize map integration to enhance your search experience by suggesting complete locations as you type in city keywords. This feature ensures that you can quickly and accurately select your desired destination without the need to type full addresses.

   Information Is Not Collected on Minors

   The Services are not directed towards anyone under the age of 18 and fair pair does not knowingly collect the Personal Information of anyone under 18. Do NOT use the Services if you are under the age of 18.

9. How We Use Personal Information

   fair pair processes Personal Information for the purpose of operating, providing, improving and informing Users about the fair pair Services. In particular, depending on the fair pair Services used, Personal Information may be processed for the purposes described below.

   • Provision of the fair pair Services. We process part of a User’s Personal Information in order to allow the proper functioning and provision of the fair pair Services, including the management of the contractual and commercial relationship (orders, subscriptions, invoicing, accounting, outstanding payments, etc.), the proper technical and administrative functioning of the fair pair Services, the provision of the fair pair Services, assistance with the use of the fair pair Services, the reply to requests and questions from Users, as well as the sending of notifications in the event of a technical incident.
     For example, fair pair processes a User’s Personal Information to manage the User’s subscription, to respond to support requests from Users, or to notify Users of maintenance or an incident.
   • Improvement and Optimization. We process part of a User’s Personal Information in order to improve and optimize the fair pair Services, which includes measuring and improving the quality of the fair pair Services and User satisfaction, following the navigation of the User, producing statistics on the fair pair Services and their use, managing and optimizing the operation of the servers, providing the fair pair Services in line with the needs of the Users, in particular on the equipment making up the servers, as well as defining User profiles to enable the improvement and optimization of the fair pair Services.
   • Communication and Marketing. We process part of a User’s Personal Information for the purposes of communication and marketing, including providing information and news, managing the registration of Users for the newsletter and notifications, carrying out surveys, setting up contests and advertising apps, by random draw or by any other means, communication relating to new fair pair Services, commercial or promotional offers, whether targeted or not, as well as the setting up and carrying out of partnerships with third parties.
     For example, fair pair processes a User’s Personal Information to send Users a newsletter, to propose surveys or contests, or to offer a new service or an option.
   • Verification and Security. We process part of a User’s Personal Information for the purpose of verifying and ensuring the use of the fair pair Services in accordance with the Terms of Use and the applicable laws, to ensure the security and integrity of the systems, to comply with our legal obligations, including the compliance of the contractual and commercial relationship with the obligations in force, as well as the response to requests from administrative authorities or legal requisitions, in accordance with current legislation.
   • Aggregated and Anonymous Data We may disclose or publish aggregated information (information about you and other users collectively that is not intended to specifically identify you, for example, users between the ages of 21 and 25 who live San Francisco) and other non-personal information about our users for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes. In addition, we may share your information (which may include personal information) with third parties (in other words, parties other than fair pair) or allow third parties to collect this information from our Services in the following circumstances:
     • Your Consent With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.
     • Third-Party Advertising Including Tailored Advertising and Analytics We may have advertising on our Services so we might offer many of our Services for free. We do not actively share personal information with third-party advertisers for their direct marketing purposes unless you give us your consent. When advertisers or ad networks place ads in our Services, they may collect or we may share the following types of information from within our Services:
       • performance data (like the number of clicks on an advertisement);
       • aggregated and/or de-identified information about you and other users collectively that is not intended to specifically identify you (like users between the ages of 21 and 25 who live San Francisco);
       • certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID);
       • and other contextual data about your app use (for example, your level and session length).
   • The information collected may be used to:
     • measure how effective ads are, to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising), and/or
     • undertake web analytics (like Google Analytics which is used to analyze traffic and other user activity to improve your experience).

   Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.

   Please note, after clicking on a third-party advertisement, you may no longer be on a site hosted by fair pair or the social network through which you are using fair pair’s app.

10. How We Store and Transfer Personal Information
    • Depending on the User’s consent and fair pair’s legitimate business interest in the Personal Information, storage durations may vary between 1 and 10 years
    • Once the storage periods have been exceeded, fair pair will erase or anonymize the Personal Information concerned.
    • In order to carry out the processing necessary for the purposes described in this Privacy Policy, fair pair may transfer Personal Information outside the United States.
    • These transfers are mainly explained by the location of the subcontractors that we have chosen. When they are established outside the European Union or the United States, fair pair ensures that the legal framework of the country in question provides a satisfactory level of security, or implements the procedures required to obtain the guarantees necessary for securing the transfers.
11. How We Use Cookies

    We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:

    • cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;
    • web beacons, which let us know if a certain page was visited or whether an e-mail was opened;
    • tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and
    • local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-app preferences and speed up load times.

    You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

    If you disable cookies, you may lose some of the features and functionality of our Services because FAIR PAIR cookies are necessary to track and enhance your app use.

12. Your Data Rights and California Data Rights

    The California Consumer Privacy Act (“CCPA”) requires specific disclosures for California residents. In addition, other states may require that we provide you access to information we have stored about you

    The CCPA provides the right to request information about how fair pair collects, uses, and discloses your personal information. And it gives you the right to access your information and request that fair pair delete that information.

    • Data Access

      You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we may, if required by law and if we have the information available, disclose to you:

      • The categories of personal information we collected about you.
      • The categories of sources for the personal information we collected about you.
      • Our business or commercial purpose for collecting or selling that personal information.
      • The categories of third parties with whom we share that personal information.
      • The specific pieces of personal information we collected about you (also called a data portability request).
      • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
        • Sales, identifying the personal information categories that each category of recipient purchased; and
        • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
    • Data Deletion

      You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we may delete your personal information from our records, unless an exception applies.

      We may deny your deletion request if retaining the information is necessary for us or our service providers to:

      1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
      2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      3. Debug products to identify and repair errors that impair existing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Section 1546 seq.).
      6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
      7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      8. Comply with a legal obligation.
      9. Make other internal and lawful uses of that information.
    • Exercising Your Privacy Rights

      To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request at

      Email support@getfairpair.com

      Or

      fair pair
      1712 Pioneer Avenue Suite 500
      Cheyenne, WY 82001

      Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

      You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
      • Describe your request with sufficient details that allows us to properly understand, evaluate, and respond to it.

      We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

      We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Depending on whether you have an account with us, we will deliver our written response to that account or to an email or physical address you have provided. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable.

      We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

      Additionally, you may choose to opt out of the following services:

      Opting Out of Ongoing Collection of Information About Non-fair pair Apps You Have On Your Device

      To the extent that our app is collecting information about non-fair pair apps you have on your device, the app will provide you with an option to stop making that information available to us in the “settings” page for the relevant app if fair pair should decide in the future to collect this type of data.

      Opting Out of Promotional Emails from fair pair

      If you want to stop receiving promotional e-mails from fair pair, click on the “unsubscribe” link in any promotional email from fair pair. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, and in no event longer than ten business days.

      Opting Out of Other Communications

      You can opt out of receiving SMS messages (for example, text messages) by texting back STOP to the number we send the text from for that particular SMS message program. In some cases a preferences management page will also be available. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.

      When you install our apps on your mobile device you may choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.

13. International Data Transfers

    International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

    Since we operate globally, it may be necessary to transfer your personal information outside the United States. This may happen if our servers are based outside the United States. If you use our Website and products while visiting countries outside the United States or if we transfer your personal information to servers located outside the United States, you hereby consent to the transfer of your personal information. The data protection and other laws of these countries may not be as comprehensive as those in the United States. Notwithstanding the foregoing, this Privacy Policy, and the collection of information hereunder, shall comply with all relevant data protection provisions, including, without limitation, the General Data Protection Regulation (GDPR).

    If you are located outside the United States you note that we are processing your personal information in order to provide the Services, or otherwise pursue our legitimate business interests. You acknowledge that the fair pair Services are not marketed toward or targeted at any users located outside of the United States.

    Additionally, if you are located outside the United States, we may also process your personal information when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our Site, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

    Additionally, if you are located outside the United States, we may also process your personal information when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our Site, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

    • Right to Access. You have the right to see any personal information we have collected about you as well as the purpose of our collection and processing of it.
    • Right to Correct. You have the right to complete and/or correct any inaccurate personal information in our possession.
    • Right to Erase. You have the right to have your personal information erased from our data stores without undue delay.
    • Right to Restrict. You have the right to restrict processing of your personal information.
    • Right to Port Data. You have the right to request your personal information be ported over to another controller.
    • Right to Object. You have the right to object to the collection or processing of your personal information at any time if you believe your personal information was collected or processed unlawfully.
14. How We Update This Policy

    fair pair reserves the right to modify this Privacy Policy at any time and to notify Users of this by any appropriate means. The last update date visible on this page indicates the date of the last changes. If we decide to make material changes to our Privacy Policy, we will tell you and other users by placing a notice on our website or its equivalent in-app, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on blogs, social network pages, and/or forums and on other fair pair websites. You should periodically check https://www.thefairpair.com and this privacy page for updates.

15. How to Contact Us

    If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to support@thefairpair.com.

    APPENDIX A – Non-exhaustive List of Advertising networks and their partners

    For personalized advertisement experience, the advertising networks and their partners, some of which are listed below, would like your consent, unless they have another legal basis for processing, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. You can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.

    EXAMPLE:
    Amazon Developer
    Amazon Developer is an advertising service provided by Amazon, Inc. (US)
    Privacy Policy: https://developer.amazon.com/support/legal/mobileads/terms-and-agreements

    Google AdSense
    Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet

    You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

    APPENDIX B – Analytics and other service providers

    We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

    EXAMPLE:
    AWS
    AWS is cloud computing services provided by Amazon Web Services, Inc. (US).
    Privacy Policy: http://www.amazon.com/gp/help/customer/display.html?nodeId=468496

    Google reCAPTCHA
    Google reCAPTCHA is a spam protection service provided by Google LLC. (US)
    It is primarily used to distinguish whether an input is made by a natural person or abusive by automated processing. The service includes sending data required by Google for the reCAPTCHA service to Google. Additional information about Google reCAPTCHA and Google’s privacy policy can be found at: https://policies.google.com/privacy.