Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser. Disabling cookies will affect the functionality of this website. You may not be able to use some parts of our Services if you disable cookies. Therefore, it is recommended that you do not disable cookies.

When using the Populus Services, you will be asked to consent to the use of Cookies. The tool will record when you have consented to our Cookie policy. Essential cookies cannot be disabled.

Other Information

We do not collect sensitive personal information other than as may be necessary to collect payment from our customers for our products and services. Unless we specifically request such sensitive information from you, we ask that you not send it to us or disclose any sensitive personal information to us.

Finally, we may also receive personal information about you from third parties, such as social networks, that help us identify prospective businesses or customers that might be interested in our products and services.

Use of your Personal Information

We use personal information for the following business purposes associated with our general business operations. We may collect your personal information for the following processing purposes:

• To provide, operate, and maintain our Services, including to monitor the usage of our Services.

• To manage your account and to manage your registration as a user of the Services. The personal information you provide may give you access to different functionalities of the Service that are available to you as a registered user.

• To manage a contract, including the development, compliance and undertaking of the purchase of our Services, providing customer service and support, and responding to inquiries.

• To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. You may opt out of receiving any, or all, of these communications from us by following the instructions provided in any email we send or by following the unsubscribe link in those emails.

• To communicate with you about your job application and potential future job opportunities;

• To administer, support, and manage the job application process

• To attend and manage your requests if you choose to contact us directly (by email, form, or postal mail) or using the contact information provide to us on the Populus website

• To understand general information and trends related to our website, such as how many users have visited our website during a given period of time and the types of devices the visitors use. The information is used by us to help improve the Services.

Legal Basis for Collecting and Using Information

If you are a user of the Populus website or platform located in the EEA, we rely on several processing purposes, such as legitimate interest, as the legal basis for processing the personal information we collect via the website and platform. For instance, we may collect, process or disclose your personal information based on the following bases:

• Consent: You have given your consent for processing personal information for one or more specific purposes.

• Performance of a contract: Processing personal information is necessary to provide a service or perform a transaction (such as when we respond to your requests) and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing personal information is necessary for compliance with a legal obligation to which the Company is subject, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws

• Legitimate interests: Processing personal information is necessary for the purposes of the legitimate interests pursued by the Company, including maintaining the safety and security of the Site

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Sharing Your personal information

We may disclose information (including personal information) in the following instances:

• Vendors, Service Providers, and Business Partners. We may disclose your information to vendors and service providers we engage to perform tasks on our behalf, for example, to help us deliver our Services, bill our customers, respond to support tickets and to offer you certain products, services or promotions, and conduct background checks.

• Marketing. We may disclose your information to service providers and advertising networks as reasonably necessary for marketing our products and services.

• Affiliates. We may disclose personal information with subsidiaries, affiliates or strategic partners, in which case we will require those affiliates to honor this Privacy Policy. 

• Corporate activity. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. If the Company is involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

• Applicable order. Under certain circumstances, the Company may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

• Other Legal Requirements. The Company may disclose your personal information in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of the Company, to prevent or investigate possible wrongdoing in connection with the Services, to protect the personal safety of other users of the Services or the public, to protect against legal liability, and to secure your personal information.

• Other Disclosures With Your Consent. We may disclose your personal information with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.

We may disclose de-identified information (i.e., information with personal identifiers removed) for a variety of reasons, including under the following circumstances:

• Product Improvement: To improve our products

• Company Acquisition: If Populus is acquired or merged with another company, we will transfer aggregate information to the acquiring company.

• Compliance: To comply with a subpoena or court order, to establish or exercise our legal rights or defend against legal claims, or to cooperate with government and/or law enforcement officials.

• Lawful basis: For any lawful basis.

Security

We take security very seriously. Populus has implemented reasonable technical, administrative and organizational security controls designed to protect the confidentiality, integrity, availability and resilience of data. These measures include utilization of encryption technologies, creation and maintenance of policy overseeing the management of the security program, role-based access controls, password management, vulnerability management, and secure software development protocols.

Data Retention

The time period for which we retain your personal information depends on the purpose for which we use your personal information and the applicable law for that type of personal information and use. Populus will keep your personal information for as long as you are using our services and platform or as long as we have a valid business purpose to do so and, thereafter, for no longer than is required or permitted by law. Other information collected during your use of our website will be kept until you withdraw consent or your information is no longer needed for marketing or analytical purposes. Populus will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

E.U. - U.S. Data Transfers 

For visitor-facing components of Populus, such as the Populus EU platform, all personal information is stored exclusively in Dublin, Ireland. Other than published content that is explicitly authorized by customers, Populus does not transmit customer data to third party systems with the exception of Google’s Cloud environment (GCP), which adheres to similar and stricter data protection standards than Populus. All Populus applications and data storage are entirely hosted within a Virtual Private Cloud within GCP. Nevertheless, certain personal information may be stored or accessible outside of the European Economic Area. Populus shall remain liable under the EU-U.S. Data Privacy Framework (DPF) Principles if GCP processes such personal information in a manner inconsistent with the DPF Principles, unless Populus proves that it is not responsible for the event giving rise to the damage.

For such transfers of personal information and/or where required by law, Populus relies on the Standard Contractual Clauses as a valid transfer mechanism.  While Populus does not rely on the EU-U.S. Data Privacy Framework certification as a basis for international data transfers, Populus continues to comply with the EU-U.S. Data Privacy Framework 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 to the United States. Populus has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles. To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov/s/. 

In compliance with the EU-U.S. DPF, Populus commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF in the context of the employment relationship. EU individuals with inquiries or complaints regarding the Data Privacy Framework should first contact Populus at: Populus Technologies, Inc., 177 Post Street, Suite 200, San Francisco, CA 94108. Populus is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to Populus and following the procedures and subject to conditions set forth in Annex I of Principles. Under certain conditions, individuals have the option to invoke binding arbitration. Populus has further committed to refer unresolved Data Privacy Framework complaints to JAMS, an alternative dispute resolution provider 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/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. For purposes of enforcing compliance with the Data Privacy Framework, Populus is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. 

Other Provisions

Children's Privacy

The Populus website and Services were not developed or intended for individuals under the age of 18 and we do not knowingly collect information from children under the age of 18 years old. If you learn that your child has provided us with personal information without your consent, you may alert us at legal@populus.ai, and we will promptly take steps to delete such information.

"Do Not Track" and Global Privacy Control

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals.

Links to Other Websites

Populus’s website may contain links to other websites for your convenience and information.  These websites may be operated by companies not affiliated with Populus.  Linked websites may have their own privacy policies or notices, which we recommend you review if you visit those websites.  This Privacy Policy only applies to personal information collected on this website.  We have no control over third-party websites and are not responsible or liable for the content, privacy practices, or use of any websites that are not affiliated with Populus.

Your Rights

You may be able to exercise certain privacy rights. The rights available to you depend on our reason for processing your personal information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located In, for example, the European Union or California). Specifically, you may have the following rights:

• The right to know about your personal information: You have the right to request and obtain from the Company information regarding the disclosure of the following: the categories of personal information collected; the sources from which the personal information was collected; the business or commercial purpose for collecting or selling the personal information; categories of third parties with whom we share personal information; and, the specific pieces of personal information we collected about you

• Request access to your personal information: The right to access, update or delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your personal information. If you are unable to perform these actions yourself, please contact us to assist you. 

• Request correction of the personal information that we hold about you: You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of your personal information: This right exists where we are relying on a legitimate interest as the legal basis for our processing, and there is something about your particular situation, which makes you want to object to our processing of your personal information on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request erasure of your personal information: You have the right to ask us to delete or remove personal information when there is no good reason for us to continue processing it.

• Request the transfer of your personal information. We will provide to you, or to a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw your consent: You have the right to withdraw your consent on using your personal information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

• The right to limit the use and disclosure of sensitive personal information: We will only use sensitive or special personal information as needed for the purposes for which it was collected or with your consent. We do not currently process sensitive personal information for purposes that may be limited under applicable law. If this changes, we will notify you, and you may have the right to restrict such additional uses.

• The right to non-discrimination for exercising a privacy right: We will not discriminate against you for exercising any rights.

Exercising rights

To exercise any of your rights as set out above, please contact us by submitting a request to legal@populus.ai or by contacting us at Populus Technologies, Inc., 177 Post Street, Suite 200, San Francisco, CA 94108. Please note that you will need to verify your identity before we can fulfill your request. Your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will do our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Appointing an authorized agent

You can designate an authorized agent to submit a request on your behalf. To do so, you will need to provide a written authorization or power of attorney signed by you for the agent to act on your behalf. You will still need to verify your identity with us.

Appeals

In some locations, you may be able to appeal any decision relating to a request about your personal information. You can reach out to legal@populus.ai if you have any questions.

Unsubscribe from marketing

You can opt out of receiving certain marketing or promotional communications from Populus at any time by using the unsubscribe link in the email communications we send.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business.

Any changes we make to the Privacy Policy in the future will be posted on this page, so you should review it periodically.

If there are significant changes to our information practices, specifically how we process personal information, you will be provided with appropriate online notice. We will also post a notice on our home page if our Privacy Policy has materially changed.

How to Contact Us

If you have any questions about this Privacy Policy or its implementation, you may contact us here or you can send correspondence to the following address:

Populus Technologies, Inc.

177 Post Street, Suite 200

San Francisco, CA 94108

If contacting us does not provide you with an adequate resolution and your inquiry is related to information collected about you in the European Union/European Economic Area, please contact the applicable EU Data Protection Authority.