Privacy Policy

Updated April 8, 2024

Overview

We Work Remotely Ltd. (“We Work Remotely”, “we”, “us” or “our”) is committed to protecting the privacy of personal information (i.e. any information relating to an identified or identifiable natural person) who visit any of the sites owned by We Work Remotely, which includes, but is not limited to: (freshgigs.ca), We Work Remotely (weworkremotely.com) (collectively, the “Sites”) and use the services available thereon (the “Services”). Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Site and/or Services following the posting of any amendment to this Privacy Policy shall constitute your acceptance of such amendment.

Please review this privacy policy carefully. By submitting your personal information to us, by using our Sites, or by otherwise accessing or using the Services, you consent to our collecting, using and disclosing your personal information as set out in this privacy policy.

“Personal information” means information about an identifiable individual. This information may include, but is not limited to, your name, mailing address, e-mail address, telephone number, browsing information and country of residence.

Personal information does not include information where there is no serious possibility that it can be used to identify an individual, whether on its own or in combination with other information, or personal information that has been anonymized such as to be considered anonymized information or no longer personal information under applicable laws.

Your Consent to Collect and Use Information

The primary basis on which we collect, use and disclose your personal information is with your consent, unless otherwise permitted or required by law. How we obtain your consent will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy policy.

Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our use or disclosure of your personal information at any time by contacting us using the contact information below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services. Please also note that certain data will remain within the Services for us to fulfill its contractual obligations, even after you withdraw your consent.

Our Collection of Personal Information

When you register as a user of our Site and Services, we ask for personal information that will be used to activate your account, provide the Services to you, communicate with you about the status of your account, and for other purposes set out in this Privacy Policy.

We collect Personal Information from you in the following ways:

• Through your use of the Services, whether directly uploaded and created by you, or automatically collected by us as you use the Services.
• Through your engagement with our Sites, including information submitted by you within a website form or obtained from us through cookies or similar technologies.
• From other third party sources, such as our partners and service providers.
• Through events we organize or take part in, and other business initiatives (including partner promotions, communications, and events).

Types of Information we Collect

We collect the following types of information from you:

• Account and Profile Information: Your name, company name, address, telephone number, email address, credit card information and certain other information about you may be required by us to provide the Services or be disclosed by you during your use of the Services. You will also be asked to create a user name and private password, which will become part of your account information.
• Information from linked accounts: We may receive information about you when you integrate or link a third-party service with our Services. You may also integrate our Services with other services you use, so as to allow you to access, store, share and edit certain content from a third-party through our Services. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.
• Usage and Technical Information: We collect usage information relating to your use of the Services and how you interact with our Sites. Such information may include your Internet protocol address, information about your device, browser and operating system, how you are using our Services, and the date and time of your visit. Please refer to our Cookie Policy for a list of cookies used on our Sites.
• Payment Information: For the purposes of billing your account (if you have a paid account) and in order to process payments, We Work Remotely utilizes third party payment gateways, such as Stripe, who will collect and utilize your credit card and other payment information in accordance with their respective privacy policies. We Work Remotely shall not be liable to you or any other person for any damages that might result from unauthorized use, publication, disclosure or any other misuse of such payment information, including credit card information.
• Website Forms: We collect information that you submit to us on our Sites, including your name, e-mail address and other contact information.

Our Use of Personal Information

We take steps designed to ensure that only those employees who need access to your personal information to fulfill their employment duties will have access to it. We may use and disclose your personal or account information for the following purposes:

• To provide the Site and Services to you and to other users of the Site and Services;
• To improve the quality of the Site and Services through polls, surveys and other similar feedback gathering activities conducted by We Work Remotely and/or third parties;
• To create, manage and control your account information, and to verify access rights to the Site and Services;
• To bill your account;
• To communicate with you (subject to your opt-out rights set forth in this Privacy Policy), including without limitation for the purpose of providing you with information about the Services, or informing you of changes or additions to the Services or of the availability of any other services or features we provide;
• To assess service levels, monitor traffic patterns and gauge popularity of different features and service options of the Site and/or Services;
• To enforce this Privacy Policy or our Terms of Service;
• To protect against fraud or error, and to respond to claims of any violation of our rights or those of any third parties;
• To respond to your requests for customer service;
• To protect the rights, property or personal safety of you, us, our users and the public; and As required to comply with applicable laws or as authorized by applicable laws.

Legal Basis. When we process and use your personal information under EU data protection law, we need a justification to do so. An overview of the justifications for processing personal information under EU data protection law, and why we use your personal information is provided below. Additional details on how we process your personal information may be provided to you in a separate notice.

*For the personal information from the EU/UK that we process, this column describes the relevant legal bases for such processing under the EU General Data Protection Regulation (“GDPR”) (and local implementing laws of EU member states and the United Kingdom); this does not limit or modify the obligations, rights and requirements under the privacy laws of non-EU jurisdictions.

** For the personal information from the EU, the processing is in our legitimate interests (set out above), which are not overridden by your interests and fundamental rights.

Our Sharing of Personal Information

Sharing with Third Parties

We share your personal information with third party service providers who perform some functionality within the Services on our behalf, such as hosting, data storage, resume reviews, and research and analytics. We also share your information with third party service providers who provide products and services that we use to operate our business, such as payment processing, email services and marketing campaigns. Specifically, we share information with MailChimp, Typeform, Hubspot, Amazon Web Services, Stripe, RDS and Sendgrid.

When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.

We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information on our Sites.

Other Disclosures

Additionally, we may disclose your information when we believe such disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

International Transfers and Storage of Information

Your personal information is primarily stored and processed in the United States. However, personal information may be processed in other countries where we engage third party service providers. By using the Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy.

For Personal Data that is subject to the GDPR, We Work Remotely utilizes approved contractual transfer mechanisms, such as the EU adequacy decisions, and the Standard Contractual Clauses approved by the European Commission.

Opting Out of Communications

We may occasionally communicate with you regarding our products, services, news and events. You have the option to not receive this information. We provide an opt-out function within all email communications of this nature, or will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you. The only kind of these communications that you may not “opt-out” of are those required to communicate announcements related to the Services, including information specific to your Account, planned Services suspensions and outages. We will attempt to minimize this type of communication to you.

Age of Consent

We do not knowingly provide the Services to, and will not knowingly collect the personal information from anyone under the age of consent. If you live in a country in the EU/EEA, you must be at least 13 years old to use our Services or such greater age required in your country to register for or use our Services. If you live in any other country except those in the EU/EEA, you must be at least 14 years old to use our Services or such greater age required in your country to register for or use our Services. In addition to being of the minimum required age to use our Services under applicable law, if you are not old enough to have authority to agree to our Privacy Policy in your country, your parent or guardian must agree to our Privacy Policy on your behalf. If you have any concerns about your child’s personal information, please contact us at [email protected].

Neither the Site nor the Services are intended for children under 13 years of age, and no one under age 13 may provide any personal information to, on or through the Site or Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to, on or through the Site or Services, make any purchases through the Site or Services, use any of the interactive or public comment features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the email address provided in the paragraph above.

Rights to Your Information

Individuals have a number of rights concerning their personal information under global privacy laws. Under certain conditions, you may make a written request to access, correct or delete any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

You have the right to access and edit your information at any time through the web interface provided as part of the Services. On written request and subject to proof of identity, you may access the personal information that we hold, used or communicated and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information by mail or e-mail.

Under some privacy laws, you may be entitled to additional rights, including: (i) the right to withdraw consent under conditions; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (vi) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.

Aggregated Data

We may also use your personal information to generate Aggregated Data for internal use and for sharing with others on a selective basis. “Aggregated Data” means records which have been stripped of information potentially identifying users, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information will be kept anonymous in Aggregated Data.

Cookies, Targeting and Analytics

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, APIs, and other mechanisms to automatically collect and record information about your browsing activities, use of the Services, device, and similar information within our Services. We use this information to target advertising and content across our Services and third-party sites, combine it with other personal information we collect, understand how our Services are used, track and resolve bugs and errors, optimize and improve our performance, verify account credentials, allow logins, track sessions, prevent fraud, protect our Services, personalize content, and for analytics purposes. You have choices about our use of cookies and tracking within the Services, as described in this section.

Cookies: When you visit our Site, we or one of our third-party service providers may place a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is an alphanumeric identifier that is transferred to your device’s hard drive through your web browser for record-keeping purposes. The cookie cannot be read by any website other than the one that placed the cookie.

Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services. For example, we and our third-party service providers use cookies to collect and store Internet log information, such as what time the visits occurred, whether the visitor has been to this site before, and what site referred the visitor to the web page. General geographic data is also determined by the IP Address of the visitor’s computer. This information collected by the cookie is transmitted to our third-party service providers and is then used to evaluate visitors’ behaviour and to generate statistical reports for the website activity on our Sites and may be used for marketing or advertising purposes.

Pixel tags: Pixel (also referred to as web beacons, web bugs or clear GIFs) tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags, in connection with our services to, among other things, help us manage ads and content, and compile statistics about usage of our services. We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics and Tools: We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Targeted Advertising: We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“Third-Party Ad Companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these Third-Party Ad Companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.

Managing Your Cookie Preferences

We make available several ways for you to manage your preferences regarding targeted advertising, matching and cookies within our Services. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. Remember that you may continue to receive generic or “contextual” ads from us. You can manage your cookie preferences for our Site and opt-out of certain cookies as explained below.

• Cookie Settings: you can review or change your preferences for targeting cookies and tags by adjusting your cookie settings via our Cookie Preference Manager, accessible from the footer of our Site. Please note, that your preferences are browser and device specific.
• Browser Settings: in addition, you can block or disable cookies for the device and browser you are using, through your browser settings by following the procedure described in the ‘Tools or Preferences’ menu in your browser; however, certain features on our Site may not be available or function properly if you block or disable cookies.
• Do-Not-Track: our Site currently do not respond to “do not track” signals.
• Industry Ad Choice Programs: you can learn more about the information collection practices and “opt-out” procedures of many Third-party Ad Companies by visiting https://optout.networkadvertising.org/?c=1. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Site. You may also continue to receive targeted ads on other Site, from companies that do not participate in the above programs. In addition, users in the EU and Canada may obtain more information at the following links: Your Online Choices | EDAA for EU and Opt-Out Tools — AdChoices in Canada (youradchoices.ca) for Canada.

Security and Retention

We will strive to prevent unauthorized access to your personal information, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. We have implemented and maintain reasonable security procedures and practices (based on the nature of the information we collect) to protect that information from unauthorized disclosure. We will continue to enhance security procedures as new technologies and procedures become available.

We strongly recommend that you do not disclose your password to anyone.

Please remember that you control what personal information you provide while using the Site and Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any personal information in your possession for the use of the Site and/or Services. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the personal information you provide to others through the Site or Services. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the Site or Services, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the Site or Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party. You release us from any and all liability in connection with the use of such personal information or other information of others.

We will maintain your personal information for as long as they are needed, or as required by applicable laws, regulations, or government orders. After the relevant amount of time has passed, we will delete your information. The general retention periods for data that we hold are as follows.

• Account Data: We retain your account data for as long as an account is active, and for up to 1 year after account termination. We will retain some of your information longer, as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to support business operations. Any anonymized and aggregated data will be retained by We Work Remotely for internal business purposes.
• Services Improvement and Development: Where we retain information for Service improvement and development, we take steps to make that information non-personal, non-identifiable and anonymous. We only use this information to uncover collective insights about the use of our Services, and not to specifically analyze personal characteristics about you.
• Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Changes to this Policy

We may update this Privacy Policy from time to time. If we do so, we will send an email to users subscribed to the Company News list. We will also add a site banner alerting users who may not be subscribed. If the change materially effects the treatment of your personal data, and we have your email but you are not subscribed to the Company News list, we will send you an email. (You are responsible for ensuring that we have an up-to-date email for this purpose.)

Contact Us

If you have any questions or comments about this Privacy Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer (or Data Protection Officer) can be reached by mail or email using the following contact information: by email at [email protected].

Supplemental Notice for US Residents

The personal information that we may collect, or may have collected from consumers in the preceding twelve months, fall into the following categories established by the California Consumer Privacy Act, California Privacy Rights Act, Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, and Utah Consumer Privacy Act, and any such applicable Act that may be amended from time to time (collectively, “US Consumer Privacy Laws”), as applicable, depending on how you engage with Us:

• Identifiers, such as your name, alias, address, phone numbers, or IP address;
• Characteristics of protected classifications under US State or US federal law, such as age or gender;
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with the Services;
• Geolocation data, such as the location of your device or computer;
• Audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise;
• Inference data, such as information about your preferences.

Use of Personal Information:

• To facilitate, operate, and provide our Services;
• To further develop, customize and improve our Services, and to provide you with any such enhanced Services;
• To provide customer assistance and technical support;
• To contact our Users and Sites visitors with general and personalized service-related notices, surveys and promotional messages including marketing and advertising messages;
• To create aggregated statistical data and other aggregated and/or inferred Non-Personal Information, which we, our Users or our business partners may use to operate and improve our respective services, or for any other purpose;
• To act as permitted by, and to comply with any legal or regulatory requirements; and
• To conduct any additional activities that may require the use of your Personal Information (as that term is defined under US Consumer Privacy Laws), for which we will request your consent in advance.

No Sale or Sharing of Personal Information

We Work Remotely does not sell Personal Information for monetary or other value. In the preceding twelve months, we have not sold any Personal Information of consumers, as those terms are defined under the US Consumer Privacy Laws. We Work Remotely has shared Personal Information as noted in the “Sharing” section above, within the preceding 12 months.

“Shine the Light” Disclosure.

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes within the meaning of that law.

No Discrimination.

We will not discriminate against any consumer for exercising their rights under the US Consumer Privacy Laws