Privacy Policy

Last Updated: August 15, 2018

12twenty, Inc. (“12twenty“, “we“, “us” and “our“) is committed to safeguarding your privacy and trust. This Privacy Policy applies to data and information collected by 12twenty through the www.12twenty.com domain name (the “12twenty Website” or “Website“), as well as through 12twenty’s proprietary software and technology (collectively, the “Services“). The use of information collected through our Services shall be limited to the purpose of providing the service for which our customers have engaged 12twenty and as otherwise described herein.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

SUMMARY:

We adhere to the following principles to protect your privacy:

A. We do not rent, sell or otherwise provide your personal information to third parties without your consent, except as described in this Privacy Policy or as required by law;

B. Except as described in this Privacy Policy, we do not share any information that you have not chosen to share with other parties, unless compelled by law, or as necessary to enforce our Terms of Service or protect the rights, property, or personal safety of 12twenty, its users, and the public.

C. All information that you provide will be protected with industry standard protocols and technology.

THIS PRIVACY POLICY CONTAINS SIX SECTIONS:

  • Introduction/Data Controller
  • Types of Information We Collect and Why
  • How We Use and Share Information
  • How You Can Change or Remove Information
  • How We Protect Information
  • Other Terms

1. Introduction/Data Controller

12twenty’s Services include the 12twenty Website and a variety of proprietary web-based services for universities and other higher education institutions, recruiters, students, and alumni. These services include, but are not limited, to outcome analytics and reporting, recruiting-related services, and employer relationship management services. For the purpose of applicable data protection legislation, in certain instances we are acting as the “data controller” (i.e. the party that determines the purposes for which and the manner in which any personal data are processed). In other instances, we are acting as the “data processor” (i.e. the party that processes personal data on behalf of a data controller). When we are acting as the data controller, the data controller of your personal data is 12twenty, Inc., located at 12twenty, Inc. 1112 Montana Ave., #186, Santa Monica, CA 90403. You hereby consent to our acting as the data controller. Please contact us at support@12twenty.com with any questions.

2. Types of Information We Collect and Why

A. Information provided to us/no Sensitive Information

12twenty is a platform used by its users, including students, alumni and participating companies and universities. Participating universities may register students, alumni, and participating companies before they become a 12twenty member and provide us their name, email address, and, if students or alumni, their degree program, and graduation year. If you are a student, when you sign up to become a member of 12twenty, you can confirm such information and provide us other information about yourself such as your career preferences and job and education history. Any information provided to us by you at registration may be used by 12twenty as described in our Terms of Service and this Privacy Policy. Subject to the next sentence, when we are acting as the data controller, we ask that you not directly send to us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website or otherwise to us. If you send or disclose any sensitive personal data to us when you submit content to our Website, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Website.

B. Information we collect when you interact with 12twenty/Cookie Policy 

(i) General. When you visit our Website and/or use our Services, you may choose to contact us, including with general inquiries, request a demo of our Services, or to refer us to the offices of your university’s Career Center. If you chose to contact us in these ways, we may collect standard personal information such as name, email, job title, and phone number, professional information such as the name of your company, your school, degree type or job title, and information about your university’s Career Center, including the name and email of the publicly listed contact there.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality. We and our partners, educational establishments, affiliates, or analytics service providers may use technologies such as cookies or similar technologies to analyze trends, administer the Website, track users’ movements around the Website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these third parties on an individual and aggregated basis.

(ii) Cookie Policy.
a. What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Website. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Website; and (2) third party cookies, which are served by service providers on our Website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

b. Cookies we use

Our Website uses the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Essential Cookies

These cookies are essential to provide you with services available through our Website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Website and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Website to remember choices you make when you use our Website, such as remembering your login details and remembering the changes you make to other parts of our Website which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Website.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Website and how users use our Website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Website, the websites that referred them to our Website, the pages they visited on our Website, what time of day they visited our Website, whether they have visited our Website before, and other similar information. We use this information to help operate our Website more efficiently, to gather broad demographic information and to monitor the level of activity on our Website.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

You can prevent the use of Google Analytics relating to your use of our Website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

c. Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

If you do not accept our cookies, you may experience some inconvenience in your use of our Website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Website.

C. Additional Tracking

(i) Pixel Tags. We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Website to track the actions of users on our Website. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of our Website, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

(ii) Do not track signals. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

(iii) Advertising. We may use other companies to serve third-party advertisements when you visit and use our Website. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to our Website and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies. If you wish to opt out of interest-based advertising click here (http://preferences-mgr.truste.com/).

D. Information Related to Data Collected through the 12twenty Services

As stated above, if you are a student,12twenty may collect some personal information about you under the direction of your university, prior to any direct relationship established with you through signing up for our Services. 12twenty works with universities to help them provide notice to their students concerning the purpose for which personal information is collected.

(i) Choice. If you are a student at a university that works with 12twenty, and prefer to decline having your information shared in the aggregate by others outside of your school’s career services office, please contact them to request that your information not be shared. If you are a student at a university that works with 12twenty and would no longer like to be contacted, please contact the university directly. Your universities’ privacy standards and practices concerning the sharing of your personal information with third parties are not governed by this Privacy Policy. Contact your school’s career services office for information about their privacy policy regarding your personal information.

(ii) Data Processors. 12twenty may transfer personal information to companies that help us provide our Service. For example, we use data processors in order to send emails on our behalf or on behalf of our customers. Transfers to subsequent third parties are covered by the provisions in this Privacy Policy regarding notice and choice and the service agreements with participating universities

(iii) Access. 12twenty acknowledges that you have the right to access your personal information. 12twenty may not have a direct relationship with the individuals whose personal data it processes. If you seek access to the information you have directly provided to us through the use of our Services to correct, amend, or delete inaccurate data, you may do so through the settings in your user profile. This is discussed further in Section 4 below (How You Can Change or Remove Information). If you seek to access data about you that has been provided to us by your university, you should direct your query to those individuals or entities at your university that you interact with directly. If your university requests 12twenty to remove some or all of the data they have provided to us, we will respond to their request within a reasonable timeframe

(iv) Data Retention. 12twenty will retain personal information we process on behalf of participating universities and companies for as long as reasonably necessary in 12twenty’s opinion. We will retain and use this personal information as necessary to provide our Services to you, comply with our legal obligations, resolve disputes, enforce our agreements and to otherwise carry out this intent of this Privacy Policy.

3. How We Use and Share Information

By providing information or allowing your university to provide information to us for the purposes of creating your 12twenty account or adding any additional information, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and 12twenty’s Terms of Service (the terms of which are incorporated herein by reference) that allow 12twenty to process and use information about you. You represent that if you are an individual, you are of legal age to enter into a contract and that if you are registering on behalf of a legal entity, that you are authorized to enter into, and bind the entity.

When you use the Services, your information is aggregated with the information of other 12twenty users to generate various employment statistics. Your information may also be used in the aggregate to provide information to other 12twenty users or third parties that we work with. You have the right to withdraw your consent to 12twenty’s collection and processing of your information submitted directly by you at any time, in accordance with the terms of this Privacy Policy and the Terms of Service, by changing your settings, or by closing your 12twenty account, but please note that your withdrawal of consent will not be retroactive and we may continue to use information that you have already provided.

We will use and share your personal information for the purpose for which it was provided, including to: (i) provide you with access to and to support your use of the Services and to help us improve our Services; (ii) In certain situations, 12twenty may be required to disclose personal data in response to lawful requests by public authorities, comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (iii) enforce this Privacy Policy; (iv) respond to claims of a violation of the rights of third parties, whether or not the third party is a 12twenty user, individual, or government agency; (v) respond to customer service inquiries; (vi) permit third parties to contact you to tell you about products, services and events that may be of interest to you; or (vii) protect the rights, property, or personal safety of 12Twenty, our users or the public.

We may also disclose your personal information and other information you provide to a third party as a part of a sale of the business or assets of 12twenty, or as the result of a change in control of the company. If 12twenty is involved in a merger, acquisition, or sale of all or a portion of its assets, the acquiring company will possess the information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy. We may provide your personal information to companies that provide services to help us with our business activities, such as hosting and maintenance, data storage and management, and marketing and promotions. These companies are authorized to use your personal information only as necessary to provide these services to us.

4. How You Can Change or Remove Information

Upon request 12twenty will provide you with information about whether we hold any of your personal information. You have the right to access, change and correct your profile information that you submitted to us at any time by going to your profile page and clicking edit. Information will be updated immediately. 12twenty will retain your information for so long as your 12twenty account is active or for as long as reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may request deletion of your information at any time by contacting 12twenty customer service at support@12twenty.com. We will respond to request within a reasonable timeframe, in which case your information will no longer appear in your account. However, we reserve the right to retain and use your information consistent with the terms of this Privacy Policy, including as necessary for record keeping or auditing purposes, to comply with our legal obligations, to resolve disputes and to enforce this Privacy Policy.

If you close your 12twenty account, we have no obligation to retain your information, and may delete any or all of your account information without liability. However, we may retain certain information contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personal information, account recovery, or if required by law. 12twenty may also retain and use your information if necessary to provide its services to other 12twenty users. 12twenty disclaims any liability in relation to the deletion or retention (subject to the terms therein) of information or any obligation not to delete the information.

5. How We Protect Information

In order to help secure your personal information, access to your data on 12twenty is password- protected, and sensitive data is protected by reasonable security when it is exchanged between your web browser and the 12twenty Website. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. To protect any data you store on our servers, we also regularly audit our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication are generally not encrypted, and we strongly advise you not to communicate any confidential information through these means. Although we allow you to set privacy options that limit access to your information, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your information. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures on 12twenty. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software.

6. Other Terms

(a) Changes. We may update this Privacy Policy at any time. In the event there are significant changes in the way we treat your personal information, or in the Privacy Policy document itself, we will display a notice on the 12twenty Website and/or send you an email prior to the changes becoming effective, so that you may review the changed terms prior to continuing to use the Website. The updated Privacy Policy will be reflected by a new “last updated” date above. As always, if you object to any of the changes, and you no longer wish to use 12twenty, you may close your 12twenty account. Unless stated otherwise, our current Privacy Policy applies to all information that 12twenty has about you and your account. Using the 12twenty Services after the updated terms have been published on our Website shall constitute consent to the changed terms or practices.

(b) Links to other Websites. Our Website includes links to other web sites whose privacy practices may differ from those of 12twenty. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit. Third parties may collect, but we do not authorize them to collect, personally identifiable information about your online activities over time and across different websites when you use our Website or the Services.

(c) A Note to Users Outside of the United States. Your data, including personal data that we collect from you, may be transferred to, stored at and processed by us and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Website, you agree to this transfer, storing or processing. We will take reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

If you have any questions or concerns about our Privacy Policy, contact us at support@12twenty.com. You should also report any security violation to us at support@12twenty.com or by postal mail at:

12twenty, Inc.
1112 Montana Ave., #186
Santa Monica, CA 90403

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

 

(d) Social Media Widgets. Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our Website. These features may collect your Internet protocol address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy statement of the company providing it.

(e) Note About Children. Our Services are not directed toward and we do not intentionally gather personal information from users who are under the age of 13. If we discover that we have information from a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at support@12twenty.com.

Opt-out Preference. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) any new processing of your personal data that we may carry out beyond the original purpose stated in this Privacy Policy; or (iii) the transfer of your personal data outside the EEA. Please note that your use of some of the features of the Website or Services may be ineffective upon opt-out. You may also choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account settings page. Otherwise, you can contact us regarding any opt-out request at support@12twenty.com.

(f) Testimonials. We display personal testimonials of satisfied customers on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@12twenty.com.

(g) Your California Privacy Rights. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. California residents who provide personal information are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing use. If applicable, this information would include the categories of information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities).

To request this information, please contact us via email at support@12twenty.com with “California Privacy Rights” in the subject line or by postal mail at:

12twenty, Inc.
1112 Montana Ave., #186
Santa Monica, CA 90403
Attn: California Privacy Rights