The privacy of our community members and users is important to us. This Privacy Policy outlines the kinds of data we may collect online, as well as how we use and may share any information we collect, in connection with your access to or use of any service or application provided by Sellstack, Inc. d/b/a FractionL(“FractionL”, “we” or “us”) (the “Services”).
Terms used here in have the same meaning as those in the Terms of Service unless otherwise noted. BY USING OR ACCESSING THE SERVICES YOU REPRESENTTHAT YOU HAVE READ AND AGREE TO ALL THE TERMS OF THIS POLICY ANDTHE TERMS OF SERVICE AND THAT YOU CONSENT TO THE COLLECTIONAND/OR USE OF YOUR DATA FOR PROCESSING, AND/OR TRANSFER TO THEUNITED STATES AS DESCRIBED HEREIN. If you do not consent to this Policy and the Terms of Service, you are not permitted to access or use the Services.
This website may contain links to third party sites or hosted platforms or devices that are not owned or controlled by FractionL. Please be aware that we are not responsible for the privacy or other practices of such other sites. We encourage you to be aware when you visit our website and to read the privacy statements of each website you visit.
FractionL collects information to operate our business and provide you with its products and services. In the course of those efforts, we may collect personal information, which is information that can be used, directly or indirectly, alone or together with other information, to identify you (“Personal Information”), and non-personal information. Information we collect may include the following:
• Account Creation
○ CXO candidates: When you register to be part of the FractionL community and create an account, we collect registration and demographic details that make up your “Account Profile”:
• Name
• Username and password
• Email address
• Phone number
• Zip code
• Type of positions sought
• Photo (optional)
• Education and Professional experience (including your resume and information via LinkedIn or other providers)
○Client Companies: When you register as a client company, we collect registration and other information that make up your company account
• Name
• Username and password
• Email address
• Name of company
• Type of services sought
• Payment Information. We may collect information and details associated with your purchases, including payment-related information collected by our third-party payment processors on our behalf. We do not directly collect or store any payment card information, but may receive billing address or other non-sensitive information associated with your payment card from our third-party processors.
• User-Generated Content. We may collect Personal Data voluntarily disclosed by you onour forums, blogs and our other areas of the Service to which you can post informationand materials.
2.2 Log Information We Collect from You Automatically. When you use a device or specific product to access the Services, we may collect certain information about the device or product such as serial number, UPC, or other device-related information. When you engage with our online communities on the Services, we may collect information about those interactions. When you create an account(“Account”) and/or purchase a membership, we collect information regarding your purchase, cancellations and other transaction information regarding your purchases, such as the membership product purchased and the price you paid.
2.3. Cookies. FractionL uses cookies and other data collection tools to collect data. We may also work with or through other companies including analytics companies or advertisers, who may also use similar technologies to collect data. Of particular importance are cookies — data files stored by your browser when you interact with a website. Such cookies enable sites to recall information about your visit and help improve your experience. Using cookies, we can make it easier for visitors to access or use the Services and the functionality and features they contain, as well as to offer other functionality such as support for analytics or marketing. In addition, cookies can be used to collect information about the browsers and devices being used in order to enhance and optimize the user experience. Particular types of cookies used include:
– Cookies that are necessary or appropriate for the operation of our Services.
– Cookies that identify users when they return to the website to assist in personalization and/or streamline the experience and/or otherwise assist with functionality.
– Cookies that recognize and count visitors to FractionL’s web site, and/or that track visitor movement around the site and/or that track links followed or applications launched.
FractionL uses Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Your browser may offer you a “Do Not Track” option, which allows to signal to website operators and web applications and services (including behavioral advertising services)that you do not wish such operators to track certain of your online activities over time and/or across different websites. We do not support Do Not Track requests at this time.
3. How We Use Your Information. Subject to the terms of this Privacy Policy, FractionLuses the data we collect, including any Personal Information, to:
● Provide the Services to clients, candidates and/or to fulfill contractual obligations.
●Operate our business, advertise and provide our products and Services, improve existing products and services, develop new products and services, and improve and personalize your experiences with FractionL.
● Communicate with you and prospective clients about job position candidates and assignments.
●Running our business (including addressing operational, infrastructure and security issues as appropriate); optimizing and/or personalizing our offerings, analyzing user behaviors and selections.
● Improving user experience; conducting or supporting promotions or other marketing activity; and/or enabling access to services provided by other parties.
● As required by law or regulation.
4. How We Share Your Information
FractionL generally maintains security of information it generates or receives and will not disclose Personal Information without notice (except as stated herein). As a general matter, we may disclose your information if needed to help provide services or complete transactions.
● CXO Account Profiles: The information you provide as part of your Account Profile will be shared with prospective company clients, and companies seeking fractional candidates with what FractionL deems to be reasonably matching your skills and professional experience.
● Client Company Account: The information you provide us as part of the Services will be shared with prospective CXO candidates.
● Service Providers: We may employ third party companies and individuals to facilitate our Service-related services (e.g., without limitation, maintenance services, web analytics, and payment processing) or to assist us in analyzing how our Services are used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf, and/or on your behalf via your direct interaction with the third party’s website and other digital properties.
● Legal and Business Transfers: We may also disclose any information as required by law, if we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent harm or protect the rights of other users. In the event of a corporate transaction such as a merger or acquisition, we may also disclose your information.
5. Security of Your Information. FractionL is committed to protecting the security of your Personal Information. FractionL uses a variety of technical and other measures designed to protect your information against unauthorized access, theft, and loss. However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), please immediately notify us. We also recommend that you take additional measures to protect yourself and your information, such as installing anti-virus software, closing browsers after use, keeping confidential your log-in credentials and passwords, and making sure that you regularly update software and apps you have downloaded. We are not responsible for any lost, stolen or compromised passwords or for any activity on your Account via unauthorized password activity.
6. International Transfers. FractionL may transfer your Personal Information to a third party that is located in a jurisdiction other than the one from which we collected your Personal Information, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of the individual data subjects. If we do transfer your “Personal Information” to another jurisdiction, we will do so following due diligence and provided that the third party receiving the data is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organizational requirements are implemented and maintained at all times to prevent the unauthorized and unlawful processing of Personal Information, and any accidental loss or destruction, or damage to the “Personal Information” consistent with our obligations under applicable data protection laws.
7. Data Retention. FractionL will retain your personal information for as long as you maintain an Account or as needed to provide you with the Services. If you close your Account, we will delete your Account Profile data. We will also retain and use such information as necessary to comply with our legal obligations, resolve disputes, and enforce agreements. FractionL will otherwise retain data as required by law and/or as appropriate for its business purposes as explained in this policy.
8. No Information from Children Under Age 13. Children under 13 may not use our site, and our policies forbid collection from them. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we might have any personal information from a child under the age of 13, please contact us at customer@sellstack.us.
9. Subject to Change. This policy is subject to change and may be supplemented or modified at any time. We encourage you to periodically review this policy to ensure you understand our privacy practices. Under certain circumstances, (for example, with certain material changes or where it is required by applicable privacy laws, we will provide notice to you of such changes. Notice may be by email to you, by posting a notice of such changes to our Services, or both other means consistent with applicable law. If you have any questions concerning our collection, use, or storage of any information from or about you, or wish to contact us for other reasons, please do not hesitate to contact us at customer@sellstack.us.
Additional rights.
If you are a resident of the United States, you may also have certain rights under the laws of your state.
10. California: If you are a California resident, you may have certain rights under the California Consumer Privacy Act (“CCPA”)/California Privacy Rights (CPRA). The CCPA, as amended, with respect to information collected by us during the 12 months preceding your request. These include:
● Right to request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties;
● Right to correct inaccuracies in personal information, as is commercially reasonable to do;
● Right to delete personal information that we have collected about you; and
● Right to opt-out of sale of your personal information. As the terms are defined under the CCPA, we do not “sell” your “personal information”.
California residents may also request the following information (to the extent we share your personal information in this way):
● The categories of information we disclosed to third parties for the third parties; direct marketing purposes during the preceding calendar year; and
● The names and addresses of third parties that received such information, or if thenature of their business cannot be determined from the name, then examples of theproducts or services marketed.
If you wish to exercise one or more of these rights, please contact Customer@sellstack.us.
Verifying Your Request: Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. For access and deletion requests, your request must be verifiable before we fulfill such requests. You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
Notice at Collection (California):
(a) List of categories of personal information collected:
● Identifiers, such as your name, e-mail address, or similar identifiers.
● Commercial Information, such as purchase history
● Internet/Net Information, such as device information, logs and analytics data
● Geolocation Data, such as location information from your device or generated based on IP address or Wi-Fi
● Professional and educational Information
(b) The purposes for which the categories of personal information are used:
● To provide our services
● To communicate with you about our services and CXO opportunities
● To fulfill contractual obligations or otherwise take steps to effectuate or defend our rights
(c) “Sale” or “Sharing” of Personal Information. As the terms are defined under the CCPA, we do not “sell” your “personal information”, nor “share” to a third party for cross-context behavioral advertising.
(d) Data Retention: We retain the categories of personal information above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted bylaw. We will also retain and use such information as necessary to comply with our legal obligations, resolve disputes, and enforce agreements. FractionL will otherwise retain data as required by law and/or as appropriate for its business purposes as explained in this policy.
11. Colorado, Connecticut, Nevada Utah and Virginia.
If you are a resident of Colorado, Connecticut, Utah, Nevada or Virginia, we may have certain obligations and you may have certain rights respect to your personal information, including:
● Right to confirm whether the controller (FractionL) is processing the consumer’s personal information and the right to access such information;
● Right to correct inaccuracies in personal information;
● Right to delete personal information;
● Right of data portability;
● Right to opt out from targeted advertising (if applicable); and
● Right to opt out from the sale of personal information.
In certain states, you also have the right to opt from profiling of decisions that product legal or similarly significant effects on the consumer (such as Virginia, Colorado and Connecticut)and appeal a decision regarding a request to exercise your rights.
If you wish to exercise one or more of these rights, please contact Customer@sellstack.us.
12. For Individuals Located in Europe, UK or Switzerland
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.
Legal Basis for Processing: When we process your personal information, we will only do so for/when:
●Performance of a Contract: We need to use your personal information to perform our responsibilities under our contract with you.
●Legitimate Interests: We have a legitimate interest in processing your personal information. For example, we may process your personal information to communicate with you about changes to our Services, security, and to improve our Services.
● Legal Obligations: We find such processing is necessary to comply with our legal obligations.
● Consent: We have your consent to do so. When your consent is the legal basis for our processing, you may withdraw such consent at any time.
●Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Data Retention: See paragraph 7 above.
Rights concerning your Personal Data: You have a number of rights under applicable data protection laws in relation to your personal information. Under certain circumstances, you have the right to:
● Have access to your personal information by submitting a request to us;
● Have your personal information deleted;
● Have your personal information corrected if it is wrong;
● Have the processing of your personal information restricted;
● Object to further processing of your personal information, including to object to marketing from us;
● Make a data portability request;
● Withdraw any consent you have provided to us;
● Restrict any automatic processing of your personal information; and
You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm, https://ico.org.uk/global/contact-us/. If you need further assistance regarding your rights, please contact customer@sellstack.us.and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.