Last revised: July 1, 2018
What information we collect
How we use information
How we share information
How we secure information
How to access and control your information
How we transfer information internationally
Other important privacy information
For the purposes of the General Data Protection Regulation (the “GDPR”), Catalant is the data controller. Catalant is a Delaware corporation established in the United States headquartered at 25 Thomson Place, Boston, MA 02210.
1. WHAT INFORMATION WE COLLECT
Information you provide
Account and Profile Information: When you create an account on the Catalant Platform Services, we will collect information that you provide to us, including your first name, last name and email address. We also collect any information that you provide to us in your profile. This may include, among other information, your location, your employment history, your educational history, your certifications or licenses, your pay rates, a profile photo, and any other information you choose to include in your profile.
Content you provide through the Catalant Platform Services: We collect content that you post, send, receive and share via the Catalant Platform Services. This may include any information about you that you choose to include in a Project posting, pitch or proposal, including, but not limited to, the files and links you upload to the Catalant Platform Services. We also collect content that you submit to our Site or via our social media accounts. For example, you provide content to us when you participate in any surveys, contests, promotions, sweepstakes, activities or events.
Payment Information: We collect certain payment and billing information when you provide it to us including when setting up your profile or transacting via the Catalant Platform Services. For example, you may provide payment information, such as credit card or bank account details, which we collect via secure payment processing services.
Communications with Catalant: When you communicate with Catalant via telephone, email, our Site, or the Catalant Platform Services more broadly, we collect information about your communication and any information you choose to provide. These communications may include feedback you provide to us or requests for assistance. For example, if you engage with a member of our support team, you may be asked to provide your contact information so that keep you informed on the status of any issues.
Information provided by others
Other users of the Catalant Platform Services: Other users may provide information about you when they submit content through the Catalant Platform Services. For example, we may receive your email address from other Catalant Platform Service users when they invite you to collaborate on a Project. Similarly, another user may provide your contact information when they designate you as the billing contact for your organization’s use of the Catalant Platform Services.
Background Check Providers: Catalant has agreed with certain Customers to conduct background checks (including criminal history, education verification, employment verification, credit checks, or drug screenings) with respect to certain other users. Catalant conduct such checks via a third-party provider. You will be notified if a Customer has requested that Catalant conduct a background check with respect to you, and any such check shall be conducted in accordance with applicable law.
Information we collect automatically
Your use of the Catalant Platform Services: We keep track of certain information about you when you visit and interact with the Catalant Platform Services. This information may include the features you use; the links you click on; the searches you run; the type, size and filenames of attachments you upload; and how you interact with others on the Catalant Platform Services.
Device and Connection Information: When you visit the Site or use the Catalant Platform Services, Catalant’s servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser software version or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We may correlate this information with other information we have about you.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. The types of cookies used include:
- Strictly Necessary Cookies.These are cookies that are required for the operation of a website. They include, for example, cookies that enable users to log into secure areas of the Catalant Platform Services.
- Analytical/performance Cookies.They allow website providers to recognize and count the number of visitors and to see how visitors move around a website when they are using it. This helps website providers to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality Cookies.These are used to recognize users when users return to the website. This enables website providers to personalize our content for you and remember a user’s preferences.
- Targeting Cookies.These cookies record a user’s visit to a website, the pages a user has visited and the links a user has followed. Website providers will use this information to build profiles of user interests for targeted marketing on other websites. We use retargeting vendors to advertise in ways that are relevant and personalized to you. You allow us to use any information you have provided to us to serve a relevant ad to you. If you consented by submitting Catalant forms, we may use that information for personalization and retargeting. To opt out of this personalized experience, you can update your cookie settings in your browser settings.
In addition, we use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Catalant Platform Services. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve the Site and the Catalant Platform Services. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our Site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
2. HOW WE USE INFORMATION WE COLLECT
As it is in our legitimate interests to provide effective services and useful content to you, we will use your information to:
To provide and improve the Catalant Platform Service and personalize your experience: We use information about you to provide the Catalant Platform Services to you, including to authenticate you when you log in, process transactions with you, and provide customer support to you. The Catalant Platform Services also include features that personalize your experience and allow you to communicate with other users on the Catalant Platform, including those users in your organization. For example, we use your information and analyze your activities on the Catalant Platform to provide relevant search results, recommendations, activity feeds and notifications. We also use information about you to connect you with other members of your organization with whom you may want to collaborate.
To communicate with you about the Catalant Platform Services: We use your contact information to send transactional communications via email and within the Catalant Platform Services, including responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages.
To market, promote and drive engagement with the Catalant Platform Services: We use your contact information and information about how you use the Catalant Platform Services to send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Catalant or partner campaigns and services) and social media advertising through social media platforms (such as Facebook or Google). These communications are aimed at driving engagement and maximizing what you get out of the Catalant Platform Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests.
Where we have a legal obligation or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
We may also use information about you where you have given us consent to do so for a specific purpose. For example, we may publish testimonials or feature expert user profiles to promote the Catalant Platform Services, with your permission.
3. HOW WE SHARE INFORMATION WE COLLECT
With other users with accounts: To facilitate engagements and other interactions between users with accounts on the Catalant Platform Services, we may share information included in your profile or Project posting with other users with accounts. For example, when you as a Contractor bid on a Project, certain information about you is shared with the user posting the Project, including your first name, your location, your engagement history on the Catalant Platform Services, and other profile information. Ultimately, you choose how much detail you want to include in either your Project posting or your profile. We may also share on your profile or Project posting any reviews you have posted on the Catalant Platform Services, and any connections you have with other users in your organization, including the nature of those connections. We don’t share your billing or payment information with other users.
With Prospective users: We may display parts of the Catalant Platform Services in promotional and marketing activities. If your profile is visible on the Catalant Platform Services, parts of your public profile page, such as your first name, your biographic description, and geographic location, may be shared with prospective users in our marketing materials. You may opt-out of this feature by changing your profile visibility in your account settings.
In the context of managed accounts: If you register or access the Catalant Platform Services using an email address with a domain that is owned by your employer or organization, and such organization wishes to establish an account or site, certain information about you including your profile information, profile picture, content, and use of your account may become accessible to that organization’s administrator and other Catalant Platform Services users sharing the same domain.
In Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights: Catalant may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Catalant, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, or (v) to protect the rights, property or personal safety of Catalant, its employees, its users, or members of the public. Where appropriate, we may notify users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Catalant’s property, its users and the Catalant Platform Services.
4. HOW WE SECURE INFORMATION
5. YOUR RIGHTS TO YOUR PERSONAL INFORMATION
Accessing, updating and correcting your information: You may access and update some of your information through your settings on the Catalant Platform. You may review, update, correct or delete the information in your profile by making edits via the Catalant Platform Services. You have the right to ask correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Catalant account) by emailing firstname.lastname@example.org. You may also email email@example.com to receive a copy of all your personal information controlled by Catalant.
Deleting your information: We retain your personal information for as long as your Catalant Platform Services account is in existence, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies. If you no longer want us to use your information to provide the Catalant Platform to you, you can request that we erase your personal information by emailing firstname.lastname@example.org. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations.
- Some of your information and the content you have provided will remain in order to allow other users to make full use of the Catalant Platform Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided.
- Because we maintain the Catalant Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Objecting to processing/requesting that we stop using your information: Where you have provided your consent to the processing of your personal information by Catalant, you may withdraw your consent at any time by emailing email@example.com specifying which consent you are withdrawing. In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground, where there are overriding public interest reasons, or where we are required by law to retain your personal information.
Opting out of communications: When you register for Catalant Platform Services, you agree to receive Catalant emails, newsletters, marketing and/or promotional materials. If you decide at any time that you no longer wish to receive such communications from us, you can opt-out by emailing us at firstname.lastname@example.org or by clicking on the unsubscribe link included at the bottom of Catalant emails.
Sending “Do Not Track” Signals: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, the Catalant Platform Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use.
6. HOW WE TRANSFER INFORMATION INTERNATIONALLY
7. OTHER IMPORTANT PRIVACY INFORMATION
Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.
Children: The Catalant Platform Services are not directed to persons under 18 and Catalant does not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian who becomes aware that your child has provided Catalant with Personal Information without your consent, please contact us at firstname.lastname@example.org. If Catalant becomes aware that a child under 13 has provided Catalant with Personal Information, Catalant will use commercially reasonable efforts to delete such information from our files.
California Privacy Rights: California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. Catalant does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent
Catalant Technologies, Inc.
25 Thomson Place, 3rd Floor
Boston, MA 02210