PRIVACY POLICY

Effective Date: January 01, 2025

This Privacy Notice explains how Toolbelt, Inc. (together with our affiliates, “Toolbelt”, “we”, “our”, and “us”) collect, use, share, and otherwise process your personal information (also known as personal data) in connection with the use of the Toolbelt websites and applications that link to this Privacy Notice (the “Sites”) and in the usual course of business, such as in connection with our partnerships, events, sales, and marketing activities (collectively, the “Services”). It also contains information about your choices and privacy rights.

Our Services

We provide a job recruiting and fulfillment platform (the “Platform Services” to our entity and company customers (collectively, “Customers”) under an agreement with them and solely for their benefit and the benefit of their personnel authorized to use the Platform Services (“Authorized Users”). Our processing of Customer data, including any Customer personal data, is governed by our agreement with the relevant Customer. This Privacy Notice does not apply to (i) the data we process on behalf of our customers (where we act as a data processor or service provider) that our Customers and their Authorized Users upload, submit or otherwise make available to the Platform Services, which is addressed by our agreements with our Customers; (ii) any products, services, websites, or content that are offered by third parties or that have their own privacy notices; or (iii) personal information that we collect and process in connection with our recruitment activities.

We also provide our Platform Services directly to individuals who use the service to sign-up for a Toolbelt account, create a profile, and search for work.  In this situation, we are the data controller and this Privacy Policy shall apply to our collection and use of any personal information.

We recommend that you read this Privacy Notice in full to ensure that you are informed of our practices and understand any rights or choices you may have. However, if you only want to access a particular section of this Privacy Notice, you can click on the link below to go to that section.

Information We Collect About You

Information that we collect from or about you includes information you provide, information we collect automatically, and information we receive from other sources.

Information you provide

When registering to use and using our Services, we may collect certain information, such as:

Identifiers: We collect information to administer your account and provide our Services to you, including your name, email address, phone number, and postal address.

Employment-related information: In addition to the Identifiers, we also collect information about your job title, company name, contractor license information and any trades that you specialize in.

Account information: If you create an account on our Services, we collect your authentication information used to access your account.

Customer service and other interaction information: We collect information that you provide through your interactions with us, including if you request information about our Platform Services, interact with our sales team or customer support team, complete a survey, provide feedback or post comments, register for an event, or take part in marketing activities. We may keep a record of your communications with us and other information you disclose during the course of the communications.

Commercial information: We keep records of your history of past purchases and transactions with us.

Financial information: We collect your credit card or other form of financial account information if chosen by you as a payment method, which may be collected directly by or disclosed to our third-party payment and billing service providers.

Information we collect automatically

We use standard automated data collection tools, such as cookies, web beacons, tracking pixels, tags, and similar tools, to collect information about how people use our Sites and interact with our emails. For example, when you visit our Sites we (or an authorized third party) may collect certain information from you or your device. This may include information about your computer or device (such as operating system, device identifier, browser language, and Internet Protocol (IP) address), and information about your activities on our Sites (such as how you came to our Sites, access times, the links you click on, browsing behavior, clicks and cursor movements, and other statistical information). We use this information to help us understand how you are using our Sites and how to better provide the Sites to you. We may also use web beacons and pixels in our emails. For example, we may place a pixel in our emails that notifies us when you click on a link in the email. We use these technologies to improve our communications. We may also use your IP address to derive your general location information.

We may also use the information we collect automatically (for example, IP address, and unique device identifiers) in combination with other information we collect directly from you as you interact with the Services or from other sources about you to identify the same unique person across Services to provide a more seamless and personalized experience to you and to enable and maintain enhanced security to protect your information.

Information we receive from other sources

We may obtain information about you from trusted third party sources, including resellers, distributors, business partners, event sponsors, security and fraud detection services, social media platforms, and publicly available sources. Examples of information that we receive from third parties include marketing and sales information (such as name, email address, phone number and similar contact information), and purchase, support and other information about your interactions with our Services. We may combine such information with the information we receive and collect from you.

How We Use Your Information

We use your personal information to provide, maintain, improve and update our Services, to inform you of new offerings, and to communicate with you. Our purposes for collecting your personal information include:

To provide the Services:

  • To provide, maintain, deliver, and improve the Services;
  • To create and maintain your Toolbelt account;
  • To create personal and/or business profiles of users and companies;
  • For billing, payment, or account management (e.g., to identify your account and correctly identify your usage of our products and services);
  • To register and provide you with training and certification programs;
  • To provide you with customer service and support;

For marketing and sales:

  • To tailor and send you emails and other content to promote our products and services;
  • To allow third party partners to contact you and to send you marketing communications about their services;

To communicate with you:

  • To send you notifications about the Services, including technical notices, updates, security alerts, administrative messages and invoices;
  • To respond to your questions, comments, and requests, including to keep in contact with you regarding the products and services you use;
  • To contact you to conduct surveys, receive your feedback, conduct audits, and for market research purposes;

For online advertising:

  • for online advertising purposes; for example, to display and measure advertising on third party websites;
  • for personalization and Service improvement;
  • to personalize your experience when using our Services;
  • to measure your use of and improve Services, and to develop new products and services;
  • to generate and analyze statistical information about how our Sites and Platform Services are used in the aggregate;

For legal and security purposes:

  • to investigate security issues, prevent fraud, or combat the illegal or controlled uses of our products and services, including within our learning and certification programs; and
  • to comply with our obligations under applicable law, legal process, or government regulation.

We will also use your information for other purposes, where you have given consent for such uses.

De-Identified/Anonymized Information. We may de-identify or anonymize information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified or anonymized form. Except as otherwise prohibited by applicable law, our use and disclosure of de-identified and anonymized information is not subject to any restrictions under this Privacy Notice.

How We Share Your Information

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

Affiliates: with our affiliates and subsidiaries for the purposes described in this Privacy Notice.

Service Providers: with our service providers who assist us in providing the Sites and Services, such as billing, payment card processing, customer support, sales and marketing, and data analysis, subject to appropriate contractual prohibitions on their use of your information. We also disclose information to service providers who assist us with detecting and preventing fraud, security threats or other illegal or malicious behavior.

Third-Party Partners and Sponsors: with third party business partners, such as vendors, resellers, distributors, and/or referral partners, who are involved in providing content, products or services that may be of interest to our prospects or Customers (we may sell or share your personal information to these parties). We may also engage with third party partners who are working with us to organize or sponsor an event to which you have registered to enable them to contact you about the event or their services (but only where we have a lawful basis to do so, such as your consent where required by applicable law).

Advertising Partners: with advertising providers that tailor online ads to your interests based on information they collect about your online activity over time and across different services (we may sell or share your personal information to these parties).

Integration Partners: As we build integrations into third-party systems, we may disclose personal information to the vendors of such systems if you choose to enable and use such integrations.

Sponsoring Organizations: with the organization that is sponsoring a training or certification program that you take through the Services (e.g., your employer), for example to notify them of your registration and completion of the course

For legal purposes: when authorized by law or we deem necessary in good faith to comply with legal process; when required to protect and defend the rights or property of Toolbelt or our Customers, including the security of our Sites, products and services (including the Platform Services); or when necessary to protect the personal safety, property or other rights of the public, Toolbelt, or our Customers

With your consent: when you instruct us to do so or where you have consented to the disclosure of your information with third parties

Business Transactions: we may engage in transactions with other companies involving the sale of assets or parts of our business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of our assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets, including in the course of activities leading up to such transactions

International Use

Currently, our Services are designed solely for use in the United States.  We do not offer our Services to individuals or entities outside of the United States and you should not use our Services unless you are located in the United States. We make no representations or warranties with respect to use of our Services outside of the United States.

SMS/Text Communications

By providing your mobile phone number and opting into text communications, you authorize Toolbelt to send text messages to your mobile device through an automatic telephone dialing system. These messages may include service notifications, billing reminders, etc. and may be sent periodically. You understand that standard message and data rates may apply from your mobile carrier. You acknowledge that opting out of receiving text messages may impact our ability to provide certain services efficiently. You may revoke this consent at any time by emailing us at [email protected] or by visiting https://www.toolbelt.work/help-and-support/. You understand that consent to receive such messages is not a condition of any purchase or service.

Your Choices and Rights

We offer you choices regarding the collection, use and disclosure of your personal information and we will respect the choices you make in accordance with applicable law. Please note that if you decide not to provide us with certain personal information, you may not be able to access certain features of the Sites or use the Services.

Account information

If you want to correct, update or delete your account information, please log on to your Toolbelt account and update your profile.

Opt out of marketing

We may periodically send you marketing communications that promote our products and services consistent with your choices. You may opt out from receiving such communications by following the unsubscribe instructions in the communication you receive. Please note that it may take us some time to process your request in accordance with applicable law, and that we may still send you important service-related communications regarding our products or services, such as communications about your subscription or account, service announcements or security information.

Your privacy rights

Depending upon your place of residence, you may have rights in relation to your personal information. Depending on applicable data protection laws, those rights may include asking for:

  • Access to, or a copy of, your information;
  • Confirmation that we are processing your information;
  • Correction or amendment of your information;
  • Deletion of your information;
  • Transfer of your information to a third party;
  • Restriction or objection to certain uses of your information;
  • The withdrawal of consent to processing your information for certain purposes that were originally based on your consent; or
  • Opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

If you (or an authorized agent acting on your behalf) wish to exercise any of your rights under applicable data protection laws, submit a request online by emailing us at support@mytoolbelt.com or by visiting https://www.toolbelt.work/help-and-support/. We will respond to requests that we receive in accordance with applicable laws. Toolbelt may take certain steps to verify your request using information available to us, such as your email address or other information associated with your Toolbelt account, and if needed we may ask you to provide additional information for the purposes of verifying your request. Any information you provide to us for verification purposes will only be used to process and maintain a record of your request. Depending on the laws applicable to your request, if you are not satisfied with our response to your request, you may have the ability to appeal our response. If an appeal right is applicable to you, we will let you know in our response to you.

Notice of Right to Opt Out of Data “Sales” and “Targeted Advertising”

Depending on your location, you may have the right to opt out of the sale of your personal information or the disclosure of your personal information for purposes of targeted advertising (our online advertising activities are explained further in our Cookie Notice). If you exercise this right, we will notify any third parties to whom we have sold or shared your personal information to stop further selling or sharing. To opt out of such disclosures based on cookies and similar tools, please contact us as described above. We do not knowingly “sell” or “share” the Personal Information of individuals under 16 years of age.

Other Important Information

Notice to Authorized Users of an Organization

Where the Platform Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the Platform Services and responsible for the accounts and/or services over which it has control. For example, administrators can access and change information in your account or restrict and terminate your access to the Platform Services. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different from this Privacy Notice. Please contact your organization or refer to your organization’s policies for more information.

Data Retention

Toolbelt retains the personal information described in this Privacy Notice for as long as you use our Services, as may be required by law (for example, to comply with applicable legal tax or accounting requirements), as necessary for other legitimate business or commercial purposes described in this Privacy Notice (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you.

Security

We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.

Third Party Services

Our Services may contain links to third party websites, applications, services, or social networks (including co-branded websites or products that are maintained by one of our business partners). We may also make available certain features that allow you to sign into our Sites using third party login credentials (such as LinkedIn, Facebook, Twitter and Google+) or access third party services from our Platform Services. Any information that you choose to submit to third party services is not covered by this Privacy Notice. We encourage you to read the terms of use and privacy notices of use of such third-party services before disclosing your information with them to understand how your information may be collected and used.

Children’s Data

The Sites and Platform Services are not directed to children under 18 years of age and Toolbelt does not knowingly collect personal information from children under 18. If we learn that we have collected any personal information from children under 18, we will take steps to delete such information. If you are aware that a child has submitted us such information, please contact us using the details provided below.

Changes to This Policy

We may make changes to this Privacy Notice from time to time. We will post any changes here, and such changes will become effective when they are posted. Your continued use of the Site or our Services, or your interaction with us following the posting of any changes will mean you consent to those changes.

How to Contact Us

Please contact us at [email protected] or by visiting https://www.toolbelt.work/help-and-support/ if you have any questions about our privacy practices or this Privacy Notice. If you interact with Toolbelt through or on behalf of your organization, then your personal information may also be subject to your organization’s privacy practices and you should direct any questions to that organization

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