Privacy Policy
KARAT PRIVACY POLICY
Last Updated: October 27, 2023
At Karat, Inc. (“Karat”), we take your privacy seriously. Please read this Privacy Policy to learn how we process your personal information, which is defined as any information that identifies you (“Personal Information” or “Personal Data”). By using or accessing our services, including our websites and platform (collectively, “Services”), you are accepting the practices described in this Privacy Policy and consenting to our collection, use and sharing of your Personal Information as described herein.
This Privacy Policy does not cover the privacy practices of websites, applications and services of organizations we do not own or control or people we do not manage (“Third Party Services”), even if such Third Party Services may be accessed through links in our Services. Furthermore, if you are a Karat employee, contractor, or job applicant, this Privacy Policy does not apply to your interactions with Karat; please refer to Karat’s internal-facing privacy policy for information about Karat’s privacy practices applicable to you.
You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@karat.com.
1. HOW WE COLLECT INFORMATION
We may collect information about you by the following means:
- Directly from you, when you provide information to us or interact with us;
- Automatically when you utilize or interact with our website or Services;
- From online advertising companies who may share information about the marketing and advertisements you have seen or clicked on, and from social networks and other sources of publicly available data;
- From other third party sources that provide consumer data, such as information about your interests, demographic information, and marketing inferences.
- If you are a job candidate or interviewee (“Candidate”), the Prospective Employer that referred you.
2. WHAT INFORMATION WE COLLECT
Candidates
Candidate Personal Data | ||
Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties with Whom We Share Personal Data |
Profile or Contact Data |
|
|
Device/IP Data |
|
|
Web Analytics |
|
|
Social Network Data |
|
|
Consumer Demographic Data |
|
|
Professional or Employment- Related Data |
|
|
Geolocation Data |
|
|
Photos, Videos, and Recordings |
|
|
Inferences Drawn from Other Personal Data Collected |
|
|
Other Identifying Information that You Voluntarily Choose to Provide |
|
|
Categories of Data Considered “Sensitive” Under the GDPR or the laws of the United States |
|
|
Website Visitors and Prospective Customers
Personal Data of Website Visitors and Prospective Customers | ||
Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties with Whom We Share Personal Data |
Profile or Contact Data |
|
|
Device/IP Data |
|
|
Web Analytics |
|
|
Social Network Data |
|
|
Geolocation Data |
|
|
Other Identifying Information that You Voluntarily Choose to Provide |
|
|
3. HOW WE USE YOUR INFORMATION
- Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics, comparative assessments and benchmarking, and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Processing your information to determine eligibility for certain product features, offerings, and other opportunities provided by Karat or other third parties.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
- Marketing the Services
- Sending you marketing emails.
- Showing you advertisements, including interest-based or online behavioral advertising.
- Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Karat or the Services.
- Sending emails and other communications according to your preferences or that display content and certain product features, offerings, and other opportunities that we think will interest you.
- Providing you with support, feedback, and opportunities for you to provide us with feedback regarding Karat or the Services.
- Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, Karat or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.
Data That Is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business (including marketing and producing white papers and other publications relating to the Services), provided that we will not share such data in a manner that could identify you.
4. WITH WHOM WE SHARE YOUR INFORMATION
- Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Advertising Partners. These parties help us market our services and provide you with other offers related to Karat, such as our Services and new products and features, that may be of interest to you. We may share the Personal Data of Website Visitors with ad networks for such purposes.
- Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
- Companies that track how users found or were referred to the Service.
- Companies that track how users interact with the Services.
- Prospective Employers. We may share certain of your Personal Data, including our assessment of any technical interviews you complete with Karat and recordings of the interviews, with the Prospective Employer.
- Interested Employers. When you consent to participate in certain product features, offerings, and other opportunities with Karat and/or certain Interested Employers, we may share certain of your Personal Data, including your contact details, your resume, our assessment of any technical interviews you complete with Karat, recordings of the interviews and any other information with Interested Employers that you approve.
- Legal. We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “How We Use Your Information” section above.
- Corporate Event. All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
5. HOW WE PROTECT AND STORE YOUR INFORMATION
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and methods of processing. Although we take reasonable steps designed to protect your Personal Information, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law.
6. HOW TO CONTROL YOUR PRIVACY OPTIONS
Email Marketing
If at any time you no longer wish to receive marketing communications from us, you can click the unsubscribe link at the bottom of any email or email us at privacy@karat.com.
Online Activity Tracking
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time. We use the following types of Cookies:
- Strictly Necessary Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Performance Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
- Targeting Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For example, we use Google retargeting/advertising cookies, as well as those provided by other vendors. For more information about this, please see the section below titled “Interest- Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking Cookies Settings, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/.
Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
Visit http://www.networkadvertising.org or http://www.aboutads.info to learn more about your options for opting out of interest-based advertising (or if located in the EEA, UK, or Switzerland, click here). Please note this does not opt you out of being served ads.
7. PERSONAL INFORMATION OF CHILDREN
We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@karat.com.
8. JURISDICTION-SPECIFIC NOTICES
US Residents
If you are a resident of certain US jurisdictions, including the State of Nevada, California, Virginia, Colorado, Connecticut, Utah, you have the additional rights set forth in this section under applicable state law. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.
- Access: You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. In response to your request, we will provide you with the following information:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
- Deletion: You have the right to request that we delete the Personal Data that we have collected about you. Under the applicable laws, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to prevent cheating or fraud, or provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
- Correction or Rectification: You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the applicable laws, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may then have to provide express consent on a case-by-case basis for the use or disclosure of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Opt-Out of Certain Processing Activities: You have the right to opt out of the processing of your Personal Data for targeted advertising purposes. To opt-out of targeted advertising, please disable Targeting Cookies. To modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking Cookie Settings. You also have the right to opt out from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable.
Furthermore, we will not sell your Personal Data, and have not done so over the last 12 months. We do not sell the Personal Data of minors under 16 years of age.
We will not discriminate against you for exercising your rights. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
European Residents (including residents of the UK, Lichtenstein, Norway and Iceland)
If you are a resident of the European Union ( “EU”), United Kingdom ( “UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation and UK General Data Protection Regulation (collectively, “GDPR”) with respect to your Personal Data, as outlined below. Karat will be the controller of your Personal Data processed in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.
- Personal Data We Collect: The “What Information We Collect” section above details the Personal Data that we collect from you.
- Personal Data Use and Processing Grounds: The “How We Use Your Information” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include the following:
- Contractual Necessity (Solely with respect to Candidate’s Personal Data): We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Job Candidate Interview Agreement with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- Profile or Contact Data
- Professional or Employment-Related Data
- Non-Public Education Data
- Photos, Videos, and Recordings
- Inferences Drawn from other Personal Data Collected
- Legitimate interests: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties (as described in the “How We Use Your Information” section above):
- Profile or Contact Data
- Device/IP Data
- Web Analytics
- Social Network Data
- Geolocation Data
- Consumer Demographic Data
- Other Identifying Information You Voluntarily Choose to Provide
- Contractual Necessity (Solely with respect to Candidate’s Personal Data): We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Job Candidate Interview Agreement with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
We may also de-identify or anonymize Personal Data to further our legitimate interests
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
- Sharing Personal Data: The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
- Europe Residents Data Subject Rights: You have certain rights with respect to your Personal Data, including those set forth below.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File a Complaint: You have the right to lodge a complaint about Karat’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. We may not respond to requests that do not meet these criteria. In some circumstances, we may not be able to fully comply with your request, such as if it is frivolous, if it jeopardizes the rights of others, or if it is not required by law, but we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. We will work to respond to valid requests within the time period required by applicable law. If we determine that your request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a request by emailing us at privacy@karat.com.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
9. INTERNATIONAL TRANSFERS
The Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction, including outside the European Economic Area (the “EEA”) and the UK, and in countries that are not subject to an adequacy decision by the European Commission and that may not provide for the same level of data protection as your jurisdiction. It may also be processed by staff operating outside of your jurisdiction who work for us in connection with the activities outlined in this Privacy Policy. More specifically, Karat is located in the United States and operates globally; we currently utilize data centers in the United States. The laws in the United States regarding Personal Information may be different from the laws of your jurisdiction or country. Any international transfers, collection, storage, or processing of your Personal Information will comply with safeguards as required by relevant law.
Standard Contractual Clauses
For transfers from the EEA, the UK, or Switzerland to the United States, we will comply with applicable laws to provide an adequate level of data protection for the transfer of your personal data. Karat relies on the European Commission approved Standard Contractual Clauses (and the equivalent standard contractual clauses for the UK where appropriate) as a legal mechanism for data transfers to the United States.
Data Privacy Framework
Karat also complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Karat 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 European Union in reliance on the EU-U.S. DPF. In addition, Karat has certified to the U.S. Department of Commerce that it adheres to the 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 and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
10. HOW WE UPDATE THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. We will alert you to any such changes by placing a notice on the Karat website, by sending you an email and/or by other legally-binding means. Your continued use of the Services following these changes reflects your acceptance of the revised Privacy Policy. The processing of your Personal Information is subject to the Privacy Policy in effect at the time such information is collected.
11. HOW TO CONTACT KARAT
For questions about our privacy practices, please contact us as follows:
- Karat, Inc.
Attn: Legal Department – Privacy
1414 NE 42nd St, Ste 204
Seattle, WA 98105-6271 USA
privacy@karat.com
+1 (509) 761-9141
If you are located in the EU or UK, you may also contact the following:
- Data Protection Officer
Dr. Felix Wittern
privacy@karat.com
Fieldfisher Tech Rechtsanwaltsgesellschaft mbH, Am Sandtorkai 68, 20457 Hamburg, Germany
- EU Member Representative:
Karat@LionheartSquared.eu
Lionheart Squared (Europe) Ltd, 2 Pembroke House, Upper Pembroke Street 28-32, Dublin D02 EK84, Republic of Ireland
- UK Member Representative:
Karat@LionheartSquared.co.uk
Lionheart Squared Limited, Attn: Data Privacy, 17 Glasshouse Studios, Fryern Court Road, Fordingbridge, Hampshire, SP6 1QX, United Kingdom
*****