Completed Privacy and Cookie Policy

Revised May 25, 2020.

We, Completed, explain in this Privacy and Cookie Policy (the “Policy”) how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the “Platform”) that link to this Policy, as amended from time to time. This Policy describes how Completed collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.

Unless we specify otherwise, this Policy applies only to information we collect, process and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us, unless we notify you at the time of collection that this privacy policy applies.

For the purposes of this Policy, “Completed,” “we,” or “us” shall mean the following entities:

    • Completed, LLC, a California limited liability company with offices at 8605 Santa Monica Blvd #43936, West Hollywood, CA 90069-4109.

Information We Collect

We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. If you are a registered user of the Platform the data collection is largely necessary for operating our Platform or fulfilling our obligations, where neither of those is the case, alternative legal grounds serve as our legal basis for processing (i.e., consent, legal obligation, and legitimate interests—see details below). Information we collect, includes, but is not limited to: Full name;

    • Address (e.g., postal, billing, shipping, etc.);
    • Telephone number including cell number;
    • Fax number;
    • E-mail address;
    • Date of birth;
    • Payment information (e.g., credit or debit card number, expiration date, other financial account details, etc.);
    • User ID, login name, screen name, nickname, or handle and password;
    • Social media accounts and/or IDs;
    • Likeness and physical characteristics (e.g., profile picture, eye and hair color, height, etc.); and
    • Details regarding background or preferences (e.g., interests, nicknames, favorite quote, etc.);
    • IP Address;
    • School, workplace and job position and history of such workplace or job or school;
    • Criminal record
    • Employer
    • Age
    • Information about your work performance
    • Reviews from others about you
    • Profile Views

Information You Give Us

When you fill out forms or provide us with other personal information actively or otherwise use the Platform, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:

    • Creating an account
    • Signing up for email alerts
    • Completing a form related to the Platform
    • Completing your Profile or preferences
    • Sending messages through Completed or leaving reviews or comments
    • Contacting us for technical support or customer service.

Depending on how you interact with our Platform, the personal information we collect from you may vary. For example, to create an account we may ask only for an email address and password. In other circumstances, we may ask you to provide other information, which may include your name, phone number, employer, age, job positions, postal address and/or other information for your profile. We also collect and store certain information associated with actions you take. We also store information about your behavior on our Platform. Because much of this information is necessary for us to operate our business, if you don’t share this information you may not be able to use some features of the Completed platform.

If you connect to the Platform using LinkedIn, Facebook, Google+, or another social networking site (each a “Social Networking Site”), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, birthday, current city work, school, and email address. When we receive this information, it becomes Completed account information for purposes of your use of the Platform. This information also constitutes personal information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from your Completed account by adapting the privacy settings in your Social Networking Site account. If you come to the Platform through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.

On certain Completed domains, when you set up an individual user account on the Platform, you may create a profile or another person may create a profile for you (each a “Profile”) that will include personal information.

We process, monitor, review, store and analyze such content and other materials, including via automated means, for commercial purposes, data analysis, quality control, enforcement of our Terms, and improvement of our services. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. Completed may (but is not obligated to) notify you in such an event. If you enter credit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.

When you submit personal information to a third party and are informed at the time of collection that your information may be shared with us, we may collect that information for lawful marketing purposes.

Categories of personal information collected by Completed may include anything related to your Profile and anything else that is publicly available on the Platform, including, but not limited to, content that you contribute, such as reviews and/or comments as well as flagged items.

Information We Collect Automatically

When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.

Automated means of data collection include the following:

Cookies And Tracking Technologies. Technologies such as: cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies (“Cookies”) are used by Completed and our partners (such as advertising, marketing and analytics providers) (“Ad Partners”). We use Cookies to remember users’ settings as well as for authentication and analytics. These technologies may be used in analyzing trends, administering the Platform, tracking users’ movements around the Platform and to gather demographic information about our user base as a whole. Our Ad Partners may also use such technologies to deliver advertisements to you. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our website or service.

Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a Completed website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.

Device Information. We collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

How We Use Information

We use the information we collect to provide the Platform and sometimes for our commercial purposes. In order for us to best provide our Platform (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy.

As a registered user of our Platform, Completed processes your information in accordance with our contractual obligations based on the Terms of Use and, where this is not the case, alternative legal grounds serve as our legal basis for processing (i.e., consent, legal obligation, and legitimate interests) including personal information for the following purposes:

    • to provide Platform offered by Completed, as well as other promotional content and services (for example, Completed and its affiliates may use your previous search and browsing history to determine relevant search results and provide you with recommended jobs on Completed or on sites of Completed affiliates, or Completed may reach out to you about jobs or companies you may be interested in; we also use your IP address and mobile device for these purposes); For the purposes of this Policy, “affiliates” means any entity that directly or indirectly, controls, is controlled by, or is under common control of or with Completed LLC, now or in the future. “Control” for these purposes means having a majority of shares or the right and ability to direct management.
    • to moderate and display the reviews and other content you have submitted for the benefit of our other users;
    • to customize and improve the features, performance, and support of the Completed site and sites of Completed affiliates;
    • to communicate with you or initiate communication with you (for marketing or service-related purposes) on behalf of third parties through your Completed account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you provide to us or (where it is lawful for us to do so) that we otherwise obtain from third-party resources;
    • to permit Completed to contact Completed users with respect to recommendations;
    • to provide relevant advertising, including interest-based advertising from us and third parties, which may mean that we share non-personally identifiable information, such as your job title, to third-party advertisers;
    • to share your Profile with employers, subject to visibility settings you control;
    • to allow Completed and Completed affiliates to process your personal data for the purpose of improving for internal operations, including detecting and preventing fraud and spam, troubleshooting, data analysis, testing, research, and service improvement (this includes use of your IP address and mobile device information to help diagnose problems with our service and to administer the Platform);
    • to create statistical data that we can commercialize;
    • for other purposes that you separately authorise as you interact with Completed.

When we collect any information that does not identify you as a specific natural person (“Non-Personal Information”), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.

Please note that if you choose to provide us with Personal Information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with the terms and conditions set forth in this Policy. You should also be aware that any Personal Information you submit through public areas of Completed (e.g., blogs, forums, people search pages, etc.) can be viewed, collected, and possibly used by others, both on Completed (e.g., to send you unsolicited messages) and potentially on third-party services to the extent permissible under this Policy. We encourage Members and non-Members to refrain from disclosing Personal Information within such public areas of the Services that they do not wish to share.

We may acquire Personal Information about you from other sources, such as: people who provide reviews about you, public databases, joint marketing partners, social media platforms, people with whom you are friends or have otherwise connected on social media platforms, and other third parties.

We may also maintain a database of public domain information gathered from other sources. Please note that we may use this information to create public profiles for non-Members (“Public Profiles”), as well as to allow Members to add to their existing Member Profiles. Members and non-Members can use Completed to search for individuals from their past using various parameters, and the results of their searches may include public domain information from Public Profiles and/or Member Profiles. If people search for you on the Internet (e.g., through a third-party search engine like Google or Yahoo!), their search results may also include links to your Public Profile and/or Member Profile on the Services.

How We Share Information/Recipients

We only disclose your personal information to third parties as follows:

    • We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business. These companies are authorized to use your personal information;
    • We may also share your information with Completed affiliates, namely any entity that directly or indirectly controls, is controlled by, or is under common control with Completed. Such affiliates shall process your personal data either (1) at our direction as a processor under a contractual relationship, (2) as a separate controller of your information where you are informed at the time of collection or processing of their relationship to you, or (3) where we believe it is necessary for the purposes of a legitimate interest, and where such purposes are aligned with those for which you provided your personal data to us.
    • We will disclose data If we believe in good faith such disclosure is necessary (1) to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us (though we reserve the right to take action on behalf of our users to defend their right to anonymity when we believe there is a legitimate basis to do so, because candid, lawful, anonymous free speech is fundamental to Completed’s mission of workplace transparency); (2) to enforce our Terms of Use and Privacy Policy; (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (4) as we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of us, the users of our services, or third parties; or (5) as permitted under applicable laws to meet national security and similar requirements;
    • In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;
    • We share certain information that does not identify you personally, but which is unique to your use of the Platform, such as job titles that you have entered at the time of registration or on your profile;
    • Completed may share your data with our affiliates. When we share this data, this may be considered a “sale” under applicable law. Once we begin sharing data you will be able to opt-out of this sharing contact us via https://completed.com/contact-us.

The Legal Basis on Which Completed Processes Your Personal Data

Completed collects and processes your personal information on the basis of different legal grounds, depending on the nature of the personal information being provided and the type of processing involved.

Performance of a Contract

Most of the personal Data processed by Completed is performed on the basis that it is necessary for the performance of our agreements with you (among them, your agreement to our Terms of Use and this Policy), or in order to take steps at the request of the user prior to entering such an agreement.

Legitimate Interest

A second ground relied upon by Completed for other types of processing of your personal information is that it is necessary for the purposes of legitimate interests pursued by Completed. Such legitimate interests may include where Completed sends you marketing about our products and services or where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf. A further example would be where Completed shares your personal information with our affiliates. Completed will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.

Compliance with a Legal Obligation

A third ground relied upon for certain types of processing is that it is necessary in order to allow Completed to comply with a legal obligation. An example of this would be where Completed is required to retain business records for fixed periods of time or transmit them to a user in order to comply with local legal requirements.

Consent

Finally, in certain limited situations, Completed relies on your consent in order to process your personal information. Where Completed requires your consent in order to collect and process certain personal information, we seek your consent at the time of provision, and such processing will only be performed where consent is secured unless Completed has another lawful basis on which to rely. For example, your consent may be sought where you submit feedback to Completed, or in certain instances where you initiate a marketing message or other communication with Completed. You can withdraw your consent where applicable.

In the event that we file for bankruptcy, or Completed is (or substantially all of its assets are) acquired by a third party pursuant to an acquisition, merger, sale, reorganization, liquidation, or similar business transfer, the Personal Information stored in our databases may be one of the transferred assets.

Cookie Policy and Ad Choices

This Cookie Policy describes how Completed uses Cookies and similar technologies. For more information on our general data privacy practices, please see the full Privacy Policy.

Cookies

Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. We use cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies (“Cookies”) to help us recognize you on the Platform, enhance your user experience, understand usage of the Platform, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you’re visiting. After you register on the Platform, we may connect information we collect from the Cookies set by us and our partners with other information received from you. The provision of your data via Cookies is voluntary except for those Cookies that we place on your device because we need them for the performance of our Platform and our services.

What types of Cookies do we use?

We use two types of Cookies on the Platform: “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Platform. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or “lifetime” of the specific Cookie and your browser settings).

What are Cookies used for?

Cookies transmit information about you and your use of the Platform, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information such as the job titles that you entered at time of registration or on your profile, but this is not linked to your name. We use four types of cookies: Strictly Necessary, Functional, Analytics, and Targeting. You can reference which specific cookies fall into each category by using our Cookie Consent Tool in our website footer.

We use Cookies for things like:

Purpose

Explanation

Authentication

We use Cookies to help us determine whether or not you’ve signed in to the Platform and to keep you signed in during visits as you access different pages.

Security

We use Cookies to enable and support security features, prevent fraud, and protect your data from unauthorised access.

Preferences and Features

We use Cookies to enable features and help us provide you with personalised content, such as showing you your recent search activity.

Advertising

We use Cookies to deliver, evaluate and improve advertising, such as by using information about you to provide relevant advertising both on and off the Platform. Our Ad Partners may use a cookie to determine whether you’ve already been shown an advert or how it performed, or provide us with information about how you interacted with an ad.

Analytics and Performance

We use Cookies to analyze how our visitors use the Platform and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how our visitors reach our sites.

Targeting Cookies: Ad Choices and Managing Cookies

Completed works with several third parties to provide you with personalized, interest-based advertising. We may target ads to you, and measure their performance, on and off the Platform using:

    • Member-provided profile information (e.g., job title, occupation, location, authorized information shared from your Social Networking Site)
    • Your use of the Platform (e.g., search history, clicks, companies you follow);
    • Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket).
    • IP address or mobile device location information (to the extent you have enabled location tracking on your device);
    • Cookies (both on and off the Platform) which may include information from the Ad Partners we use to help deliver relevant ads to you.

Some of these third-party companies may be members of the Network Advertising Initiative, which offers additional information regarding cookies and web beacons, as well as a single location to opt out of interest-based advertising from member companies (www.networkadvertising.com. You may also opt out of the use of certain cookies by Completed’s third-party advertising partners by visiting http://www.privacychoice.org/companies or http://aboutads.info/choices. If you would like more information about interest-based advertising on the Services and to know your choices about not having this information used by our advertising partners, please click here.

How We Work with Third-Parties

We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic to Completed generally. In addition, a Cookie on some of our clients sites provides us with aggregate data about the number of applications submitted to those sites by users of Platform.

Consenting to Cookies and Opting Out of Cookies

We use Cookies that are strictly necessary for us to provide the services you use and you cannot opt out of these Cookies on the Platform. You are able to disable placement of some (but not all) Cookies by setting your browser to decline cookies, though this may worsen your user experience. Additionally, you can also control, manage and/or delete cookies via your browser settings.

If you enable location data for the mobile version of the Platform (including any version installed as a native application), we may use your location data to serve you geo-targeted ads for employers and other advertisers that are local to you.

Ad Partner Cookies

Here are some options for managing the third-party Cookies used by our Ad Partners:

You can opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services by visiting Google Ad Settings or by downloading the Google Analytics Opt-Out Browser Add-on.

Please note: If ads or other features on the Platform are provided by third parties, those parties set and use their own Cookies that are subject to those third parties’ privacy notices and policies. Completed does not have access to, or control over, these Cookies. Also, if you respond to ads posted by third parties or submit information to third parties via the Platform, such third parties receive information about you subject to their privacy policies.

Do Not Track Signals

We do not currently respond to ‘do not track’ signals and similar settings or mechanisms. When you use the Platform, we try to provide a customized experience.

Other Important Privacy Information

We reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

We will send you service-related announcements when we believe it is necessary to do so. Generally, you cannot opt-out of these announcements, which are not primarily promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your account. In some cases, you can stop or limit the information we collect by automated means.

How Long We Keep Your Personal Information

We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.

Security Safeguards

Security. We employ physical, electronic, and managerial measures to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. You are responsible for keeping your username and password secret. Once you have registered with us, we will never ask you for your password. Please create a unique password for your Completed account and do not use it for any other web services or applications. Do not share your password with anyone else.

Privacy of Minors

To access or use the Platform you must be at least 18 years of age or, if older, the age of majority in your jurisdiction, otherwise you may not use the Platform. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child has provided us with personal information without parental consent, we remove such information and terminate the child’s account.

Data Controller

The information about you that we collect, process and/or use through the Platform is hosted, controlled, and services are provided by Completed in the United States. The privacy protections and the rights of authorities to access your information in the United States may not be the same as in your home country. You may reach our data protection officer at contact us.

Updates to Our Privacy Policy

We may revise this Policy from time to time by posting an updated version on the Platform. The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date or continuing to use the Platform after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately. However, they can object to the new Policy within thirty (30) days after the revision date. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy. If you object to the Policy after it becomes effective for you, you may no longer use the Platform.

Contact Us

If you have any questions or suggestions regarding this Policy, please contact us.

Completed aggregates publicly available information from government, social, and other sources, plus personal reviews written by others. Because Completed only collects this data and does not create it, we cannot fully guarantee its accuracy.