Privacy Policy

Aptology Privacy Policy

1. Privacy Policy Summary

This policy describes how Aptology collects, stores, uses, and discloses personal information and outlines your rights and options with respect to this data. By visiting the Aptology website and/or using our Hosted Services, you are accepting the practices described in this Privacy Policy.

Aptology complies with the California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100 et seq. (CCPA), the European Union (EU) General Data Protection Regulation 2016/679 as updated to reflect the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (GDPR), and UK Data Protection Laws. UK Data Protection Laws means the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 in the UK (“UK GDPR”) and the Data Protection Act of 2018. In addition, Aptology complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Aptology has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Aptology commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

2. Definitions

Individual Survey Participant: This is a person who is not affiliated with an Aptology corporate user or directed by an employer or potential employer to participate in the Aptology Survey. An Individual Survey Participant accesses the survey directly through Aptololgy’s website.
Information: all of the various forms of data, content, and information that may be collected by us through our interactions with you as described in this Privacy Policy.
Personal Information: information that could be used to uniquely identify you as an individual. This could include full name, address, email, and phone number. Personal Information does not include data that has been anonymized. Anonymized information cannot be directly tied to a specific individual.
Aptology Website: This is our web portal and as you interact with it may collect usage data using common web technologies, such as web logs and cookies. See paragraph 5.c below.
WorkStyle Survey: Our behavioral interview consisting of a series of questions that ascertain a person’s approach to a work setting.
TeamWorks Platform: Our hosted solution where employers are able to review the results of scoring and statistical modeling based on the information collected through WorkStyle Surveys combined with employee performance data.
Success Portrait: A Success Portrait is a statistically derived measure of match between an individual’s behavioral profile and a particular job role.

3. Changes to Policy

Our Privacy Policy may change from time to time, and any updates to that policy will be reflected on this page. Any changes will be effective immediately upon being posted. You may check this website at any time to see the latest version of our Privacy Policy.

4. Information You Provide

a. Account and Profile Information for corporate users

When you register an account with us as a direct user of Aptology Services, you provide a username and a password along with user details consisting of your name, email, and possibly some additional contact information. User email addresses may be used by us to send notifications regarding important updates and other release announcements, service interruptions and outages, and account information.

Additionally, you may participate in Aptology’s Success Portrait match process as either an employee or a prospective employee. As a prospective employee, you will be asked to provide your name and email address. As an employee, we also may ask you for some additional employment information. This may be data you provide yourself or may be provided by your employer. Examples of this information could include work email, work address, job title or position and tenure.

b. Account and Profile Information for Individual Survey Participants

Individual Survey Participants may participate in Aptology’s Success Portrait match process as a prospective employee for potential employers. You will be asked to provide your name, email address, location, and other demographic information at your option.

c. Survey participation

At the core of our Hosted Service is the WorkStyle Survey, which records user responses to a series of behavioral questions. These responses are critical to all the services we offer and are stored and used throughout the system and associated with the user unless the user specifically requests it to be removed or anonymized.

5. Other Information We Collect

a. Employer-provided performance data

In order for us to provide certain services, employers may provide objective performance metrics for their employees. These are used solely for the purposes of Aptology’s statistical analysis and modeling and are never transferred to or shared with other parties (with the exception of secure cloud storage). Please also note that your employer may provide your data anonymously, solely for purposes of analysis, in a way that is not tied to your personally identifiable data, such as your name or email.

b. External data

We may work with third party providers to obtain additional, publicly available data on our users in order to improve the accuracy of our offerings. In these situations, we will always ensure that these third party providers have the right to distribute such information to Aptology and that they provide adequate security and privacy safeguards.

c. Cookies

When you visit the Aptology website or use any part of the Aptology Platform, we may also collect usage information (such as your browser IP, URLs of the pages you visit, and the associated timestamps) and use browser cookies, so we can recognize you as a returning visitor in the future. This allows Aptology to provide you with a more efficient and personalized process with our services (e.g. continuing from where you left off in a survey and speeding up your log-in authentication process). This information also helps us improve your user experience as well as help us to more efficiently troubleshoot problems. See Aptology’s Cookie Declaration for information on the cookies we use.

d. Miscellaneous Data

We may also collect information as part of sharing promotional and information content with you in accordance with your communication preferences. This information may include your name and email address. You may opt out of these types of communications, such as product updates or marketing at any time.

6. Use of Information

a. WorkStyle Behavioral Portrait

When a user of Aptology’s Services completes the WorkStyle Survey, their answers are scored to build a WorkStyle Portrait — a multifaceted behavioral profile of the user in a workplace setting — and compared against the overall population of survey participants.

b. Success Portrait for a job role

When an individual is considered for a particular role, their responses are compared against a statistical model based on existing and prior employee survey and performance data. Individual trait matches, as well as derived metrics, may be calculated, stored, and presented to the individual participant as well as potential hiring managers and support staff to assist in their decision making for talent acquisition and people management processes.

7. Data Minimization and Confidentiality

The personal data obtained from each user will be limited to what is necessary in order to prepare the WorkStyle Behavioral Portrait and Success Portrait (e.g., name, email address and survey responses).

The personal data obtained from each user will only be processed or used in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Additionally, Aptology’s personnel are trained in the appropriate and secure handling of any personal data to ensure appropriate security of the personal data. Furthermore, access by Aptology personnel is highly restricted and only allowed on a need to know basis to support the processing.

8. Retention of Information

We will retain your personal and customer information as long as you continue to be a registered member either directly with us or through an employer. We also retain your data for at least one year after you initially choose to participate in our Services unless you opt out of the Hosted Services. Please note that if you opt out, the deletion of (or complete anonymization) of your data is irreversible. Should you choose to renew your participation at a later date, you would have to provide the needed information and complete the survey again.

Once Aptology has no legal or commercial reasons to retain personal data, it will be securely deleted or destroyed.

9. Sharing of Information

The Aptology platform is designed to be used by managers and decision makers involved in the talent acquisition and management process of your current company. Alternatively you may be applying for a job, or have participated in a survey for the purposes of allowing us to provide your information to prospective employers. In any of these cases, by participating you acknowledge that Aptology will share your behavioral profile information with management and the human resource representatives involved.

We will not share your personal information with any third parties without your express consent, with the exception of Amazon Web Services (AWS) secure cloud data storage and our use of cookies as discussed in paragraph 5.c above.

We will never sell your personal information. Information provided by survey participants may be shared with potential employers, and therefore such information sharing may be considered a “sale” under the CCPA.

10. Data Storage and Security

We take all necessary industry-standard precautions to ensure your data is stored in a safe and secure manner. We work with the well-established cloud services provider, AWS, which has multiple security measures in place and is part of the Privacy Shield framework, adhering to its principles and standards. Although it is very unlikely, we cannot guarantee complete protection from possible intrusion. In the event of a breach, we have procedures in place to keep you informed and will work with you, our partners, and providers to mitigate the impact as quickly as possible.

Internally, we ensure your data is used only for the purposes described in this Policy and is protected against any unauthorized access by utilizing multiple best practice security measures within AWS and the Aptology solution, fine-grained security access rights within the actual application to further restrict access to minimally necessary Aptology and Customer personnel, and the fully encrypted transmission of all data between the browser and the Aptology System for any survey participants, Customer personnel, or Aptology personnel.

11. Data Transfer

Aptology does not transfer or sell your personal information other than as described in this Privacy Policy. Aptology does not transfer your personal data overseas. Aptology’s services are hosted by Amazon Web Services located in the United States. All data storage and any data processing is done within AWS facilities in the United States.

In the event that any transfer is made to another party, we maintain written contracts with those third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield principles. To the extent provided by the Privacy Shield principles, Aptology remains responsible and liable under the Privacy Shield principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield principles, unless Aptology proves that it is not responsible for the matter giving rise to the damage.

12. Automated Decision-Making

Aptology does not engage in any automated decision-making.

“Automated decision-making” means a decision based solely on automated processing of personal data (without human intervention) which produces legal effects concerning the person or otherwise significantly affects the person.

13. Your Rights

a. California Consumer Privacy Act

If you are a California resident, you have certain rights in relation to your personal data as follows:

Access: You have the right to obtain access to and a copy of certain personal information we hold about you. This includes a list of the categories of personal information, in the preceding twelve months, collected about you, disclosed about you, and sold, as well as other information such as the source of the information, categories of information shared, disclosed or sold to third parties, and the purpose for such sharing, disclosure or sale.

Sale Of Personal Information: You have the right to ask us not to sell any of your personal information to a third party. As described in paragraph 9, we will never sell your personal information. Information provided by survey participants who are prospective employees will be shared with the potential employer, and therefore such information sharing may be considered a “sale” under the CCPA.

If you are an Aptology Workstyle survey participant you have previously consented to have your survey results, email and name shared with/transferred to the potential employer. However, you retain the right to opt out of the transfer (or sale) of your personal information to any other third party. To opt out, click here.

If you are not an Aptology Workstyle survey participant and wish to opt out of the sale or transfer of your personal information to any third party, click here.

Deletion: In certain circumstances, you have the right to ask us to delete any personal data we hold about you.

Data portability: In certain circumstances, you have the right to request a copy of your personal data in a structured, commonly used and machine-readable format.

Withdrawing consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time.

California residents with requests about what information we collect or who wish to request that we delete information we have collected may do so by contacting us set forth in paragraph 17.

b. General Data Protection Regulations

If you are located in the EU or the UK, you have certain rights in relation to your personal data as follows:

Access: You have the right to obtain access to and a copy of any personal data we hold about you.

Rectification: If you consider that any personal data we hold about you is incorrect or incomplete, you have the right to ask us to correct or complete that personal data.

Erasure: In certain circumstances, you have the right to ask us to erase any personal data we hold about you.

Restriction of processing: In certain circumstances, you have the right to ask us not to process your personal data for certain purposes.

Objection to processing: In certain circumstances, you have the right to object to us processing your personal data for certain purposes.

Data portability: In certain circumstances, you have the right to request a copy of your personal data in a structured, commonly used and machine-readable format.

Withdrawing consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time.

If you are not located in California, the EU or the UK, you may still have rights in relation to your personal data under your local data privacy law.

To make a request pursuant to these rights, contact Aptology’s Data Protection Officer as set forth in paragraph 14 below.

14. Inquiries and Dispute Resolution for EU, UK and Swiss Citizens

In compliance with the Privacy Shield Principles, Aptology commits to resolve complaints about our collection or use of the personal information of EU, UK and Swiss citizens. EU, UK and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Aptology at:

Data Protection Officer:

Brad Benson

Aptology, Inc

2 Embarcadero Center

8th floor

San Francisco, CA 94111

privacy@aptology.com

Aptology has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

The Federal Trade Commission has jurisdiction over Aptology’s compliance with the Privacy Shield.

You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. See below for the link to Annex I, Section C of the Privacy Shield for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction

15. Age Limitations

If you are under 18, or the age of majority in the jurisdiction in which you reside, you may only use the Aptology website and Hosted Services with the consent of your parent or legal guardian.

16. Government / Law Enforcement

We reserve the right to use or disclose information provided if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process.

17. Contact Information

If there are any questions regarding this Privacy Policy, including any requests for information pursuant to the CCPA, you may contact us using the information below: