Legal>> The Basics

Ethnio Privacy Policy

The Basics

We will not use information gathered from you in any way, except as described when you agreed to provide it.

Ethnio, Inc. (“we” or “Ethnio”) is committed to respecting the privacy rights of users of Ethnio’s Website and Services, whether they are Participants or Customers, as those terms are defined in Ethnio’s Terms and Conditions. Whether you are a Participant or a Customer (in either case, “You”), we created this Privacy Policy to give You confidence as you visit and use Ethnio.

Obviously, the point of Ethnio is to collect information and data from Participants and share it with Customers. With this in mind, we will not share any of Your information except as expressly disclosed to You at the time You agree to provide it. Any other data or information You provide us (including images, email addresses, etc.) will otherwise be held in total confidence. We will never share Your information with third parties for marketing purposes, and don't engage in cross-marketing or link-referral programs with other sites. If You have opted-in to receive information from Ethnio by email, we will send You updates and information on Ethnio occasionally, but You can always unsubscribe.

Children’s Privacy

Ethnio does not solicit or knowingly collect personally identifiable information from children under the age of 13. If Ethnio obtains actual knowledge that it has collected personally identifiable information from a child under the age of 13, Ethnio will immediately delete such information from its database. Because Ethnio does not collect personally identifiable information from children under the age of 13, Ethnio has no such information to use or disclose to third parties. Ethnio has designed this Privacy Policy in order to comply with the Children’s Online Privacy Protection Act (COPPA).

CCPA Compliance

Ethnio agrees to never sell any personal information submitted by customers or respondents. This applies to any future mergers, acquisitions, or bankruptcy proceeding for any other party involved.

EU-U.S. Data Privacy Framework (EU-U.S. DPF), UK Extension, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF)

Ethnio complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), UK Extension, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Ethnio has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the UK, and the European Union in reliance on the EU-U.S. DPF. Ethnio has certified to the U.S. Department of Commerce that it adheres to the UK Extension, and Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension, or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov

In compliance with the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF, Ethnio commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF should first contact Ethnio at info@ethn.io

Furthermore, in compliance with the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF, Ethnio commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF.

As part of our compliance, Ethnio has designated the following Independent Recourse Mechanism (IRM) for resolving privacy-related disputes:

  • For EU: The EU Data Protection Authorities (DPAs)
  • For UK: The UK Information Commissioner’s Office (ICO)
  • For Swiss: The Swiss Federal Data Protection and Information Commissioner (FDPIC)

If a customer or participant has an unresolved privacy concern related to our compliance with the EU-U.S. DPF, UK Extension, or Swiss-U.S. DPF, they may submit a complaint to the relevant independent recourse body free of charge.

Ethnio will cooperate with these authorities and comply with their advice regarding unresolved complaints. Additionally, in compliance with DPF requirements, Ethnio commits to responding to complaints in a timely manner and taking necessary corrective actions, as applicable.

Federal Trade Commission (FTC) Compliance and Binding Arbitration

Ethnio is committed to ensuring the privacy and security of your personal information. As part of our commitment to transparency, we want to inform you that our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We take compliance with the FTC regulations seriously. This includes adherence to privacy and data security standards that help ensure a secure and trustworthy experience when using our services.

Under certain conditions, you have the possibility to invoke binding arbitration for disputes related to your use of our services. This option is governed by the terms set forth in Annex I of the Data Protection Framework (DPF) Principles.

To initiate binding arbitration, you must deliver notice to Ethnio and follow the procedures and conditions outlined in Annex I of the DPF Principles. Binding arbitration provides an alternative dispute resolution process that can be less formal and costly than traditional litigation.

Onward Transfers

Ethnio may disclose Personal Data to subcontractors and third-party agents who assist us in providing Services to our customers and prospects. Before disclosing, Ethnio will commit to: (1) Utilize the Personal Data solely to aid Ethnio in delivering the Services. (2) Implement, at a minimum, the same level of protection for Personal Data as mandated by the DPF Principles. (3) notify Ethnio if the recipient is no longer able to provide the required protections. In the event of such notice, Ethnio will take immediate action to cease and rectify any unauthorized processing of Personal Data by the recipient.

Ethnio may also be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. To the extent permitted, we will inform you before making such disclosure and provide a reasonable opportunity to object.

Ethnio will not otherwise disclose Personal Data to third parties.

Ethnio shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

Data Submitted by Customers

We ask for Your email address, and other contact information for the purpose of confirmation emails, authenticating accounts, and for billing purposes. We do not collect personally identifiable information about You except when You specifically provide this information on a voluntary basis. We will make every effort to ensure that whatever information You provide will be maintained in a secure environment. However, even if You opt out of receiving any communications from Ethnio, we reserve the right to contact You regarding Your account status or any other matter that might affect our service to You and/or our records on You.

Our web logs collect standard web log entries for each page served, including Your IP address, page URL, and time stamp. Web logs help us to diagnose problems with our server, to administer the Ethnio site, and to otherwise provide our service to You. We share customer data with the following third parties, including:

  1. Our contracted service providers and subprocessors that process Personal Data on our behalf for IT and system administration, credit card processing, research and analytics, marketing, customer support and data enrichment;
  2. Third party advertising networks or others in order to tailor and serve advertisements regarding the Platform to customers.
  3. Legal, accounting, insurance, and regulatory third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law, including to meet national security or law enforcement requirements; (ii) to protect and/or defend our agreements with our Customers and our policies, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of Ethnio or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Such disclosures may be carried out without notice to you.

Data Submitted by Participants in Screeners

Ethnio is a hosted usability service that allows Customers to create recruiting screeners (“Screeners”), similar to web surveys. Our customers use our service to post Screeners on a website, or send links to those screeners via email or other methods. We have no control over how Ethnio customers use the personal data submitted by users to their recruiting screeners, except if they violate the Terms and Conditions. If You suspect someone has violated these Terms, please contact us. Participants may have any relationship to our customers, and Ethnio only acts as a Data Processor (a company that processes Personally Identifiable Information on behalf of a Data Controller) so that each Ethnio Customer acts as a Data Controller (a company that determines the purposes for which and the means by which the Personally Identifiable Information is processed). To process information means to carry out an operation or set of operations on the information, such as collecting, recording, storing, disclosing, or organizing it. Information that Participants provide to Customers passes through our service and resides on our servers, in the most secure manner adhering to industry guidelines. That information may be stored and processed in the United States or any other country in which Ethnio or its affiliates, subsidiaries or agents maintain facilities.

We do employ cookies in the Screeners. A cookie is a small text file that our Web server places on a user's computer hard drive to be a unique identifier. Cookies enable Ethnio to make sure people don't see recruiting screeners more than once, because that would be really annoying. Our cookies expire after 30 days, and don not collect personally identifiable information.

Right to Access, Change, or Delete Personal Data

  1. Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Ethnio collected it. Individual Customers may review their own Personal Data stored and processed by Ethnio, correct, erase, or block any data that is incorrect, as permitted by applicable law and Ethnio policies. Upon reasonable request Ethnio allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting Ethnio by phone or email. Individual Participants may contact their respective Customers to request changes. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local Ethnio office.

  2. Requests for Personal Data. Ethnio will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Ethnio receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, Ethnio will refer such Data Subject to the Individual Customer.

  3. Satisfying Requests for Access, Modifications, and Corrections. Ethnio will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

Consent to Receive Email from Ethnio

You may be given the opportunity to “opt-in” to receive periodic email communications regarding Ethnio. You may opt-out of receiving such communications at any time by following the unsubscribe instructions contained in each email.

Third-Party Websites

The Screener and other parts of Ethnio may contain links to the websites or tools of third parties (“Third-Party Websites”). At times, Participants may be directed to Third-Party Websites from within the Screener.

Ethnio neither owns nor controls Third-Party Websites. Accordingly, Third-Party Websites are under no obligation to comply with this Privacy Policy except with respect to personal information provided directly to them by Ethnio. Before visiting or providing personal information to a Third-Party Website, You should inform Yourself of the privacy policies and practices (if any) of that Third-Party Website, and should take those steps necessary to, in Your discretion, protect Your privacy.

Resolution of Disputes

Ethnio’s objective is to address and resolve any disputes between you and Ethnio swiftly and cost-effectively. Both parties agree to resolve any issue that emerges in line with this section. Prior to pursuing the alternatives mentioned, you agree to first contact us directly at privacy@ethn.io to attempt a resolution.

  1. Recourse. Individuals with concerns regarding the processing of their personal data are encouraged to reach out to us. Ethnio has procedures in place to address complaints and inquiries promptly.

  2. Enforcement. Ethnio performs regular assessments to ensure adherence to our privacy policy and the Data Privacy Framework. Any discrepancies identified are corrected to maintain ongoing compliance.

  3. Law and Forum for Disputes. This Agreement is governed by the laws of the State of California, excluding its conflicts of law provisions. Any claim against us must be resolved by a court located in San Francisco County, California. Both parties agree to the personal jurisdiction of the courts within San Francisco County, California for litigating any claims. Any cause of action must be commenced within 180 days after it arises, or it is barred.

  4. Arbitration Option. For claims (excluding those seeking injunctive or other equitable relief) where the total award sought is less than $10,000, either party may elect to resolve the dispute through binding non-appearance-based arbitration. The arbitration will be initiated through an established alternative dispute resolution (“ADR”) provider mutually agreed upon by the parties, adhering to the rules specified by the ADR provider regarding the mode of arbitration and any personal appearances.

  5. Improperly Filed Claims. Should you file a claim contrary to this “Resolution of Disputes” section, Ethnio is entitled to recover attorneys’ fees and costs, provided that we have notified you of the improperly filed claim, and you have failed to promptly withdraw the claim.

  6. Waiver of Jury Trial. If a claim proceeds in court, both Ethnio and you waive any right to a jury trial.

Ethnio remains committed to upholding a secure and compliant environment for data processing, valuing the trust and satisfaction of our users and customers as a paramount priority.

Data Storage and Security

Regarding submitted by Participants in Screeners, as a Participant, You recognize that, when You submit Data using the Screener, You are transmitting information over the Internet. Depending on the Customer’s implementation of Ethnio, Your Data may be (1) transmitted securely, or (2) transmitted via regular HTTP protocol. You understand and agree that Data submitted by You via regular HTTP protocol is not secure and You agree to hold Ethnio harmless for any resulting harm, such as a security breach.

Regarding all other data, Ethnio uses industry-standard security measures to protect the integrity and confidentiality of all user information associated with Ethnio, such as SSL encryption.

Updates and Changes to Privacy Policy

Although most changes are likely to be minor, Ethnio reserves the right, at any time and without notice, to add to, update, change or modify this Privacy Policy, simply by posting such update, change or modification on this page. Any such addition, update, change or modification will be effective immediately upon posting on the Website. Each time You use the Website, the then-current version of this Privacy Policy will apply. Accordingly, each time You use the Website You should check the date of this Privacy Policy (which appears at the end) and review any changes since the last time You used the Website. Unless InCorp obtains Your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier Privacy Policy.