Privacy Policy

This Privacy Policy informs you of the policies and procedures of Blind Creator Inc. (“Blind”) for the collection, use, and disclosure of information through www.blindcreator.com (“Site”). It includes websites, features, applications, widgets, or online services owned or controlled by Blind and that post a link to this Privacy Policy (together with the Site, the “Service”). It also includes any information Blind collects offline in connection with the Service.


This Privacy Policy describes the choices available to you regarding use, your access to, and how to update and correct your personal information. This Privacy Policy incorporates by reference Blind’s Global Data Processing Addendum. Please note that we combine the information we collect from you from the Site, throughout the Service generally, or offline.


Certain features or services referred to in this Privacy Policy may not be offered on the Service at all times. Please also review our Terms of Service, which govern your use of the Service.


We have provided brief summaries in this Privacy Policy to help you understand what information we collect, how we use it, and what choices or rights you may have. While these summaries help explain some of these concepts in a simple and clear way, we encourage you to read the entire Privacy Policy to understand our data practices.

 

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Content

 

TABLE OF CONTENTS


A) Information Collection

  • Information you provide to us

  • Personal information

  • Payment Information

  • Identity Verification

  • General Audience Service

  • Non-identifiable information

  • Combination of Personal and Non-identifiable Information

  • Information received from third parties

  • Automatically Collected Information

    • Cookies

    • Web Beacons

    • Embedded Scripts

  • How we respond to Do Not Track signals

  • Work Diaries

  • User Profiles

  • Community Forums

  • Job Listings via the Service

  • Feedback

  • Email to Friends and Referral Program

  • Social Network Services

  • SMS Terms of Service

 

B) USE of Information
C) Data Retention
D) Information Sharing and Disclosure

  • Information about freelancers shared with clients and agencies or teams

  • Service Providers

  • What happens if you agree to receive information from third parties or ask us to share your information

  • Legal and Investigative Purposes

  • Internal and Business Transfers

  • Sweepstakes, Contests and Promotions

  • Third-Party Analytics Providers, Ad Servers, and Similar Third Parties

  • Your Choices and Rights

  • Security

  • International Transfers of Personal Information

  • Links to Other Sites

  • Public Profile

  • Phishing

  • California and Nevada Residents: Your Privacy Rights

  • Changes to this Policy

  • Supplemental Privacy Notice for California Residents

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A. INFORMATION COLLECTION

 

Users of the Service may be Clients, Content Creators or Agencies, or Site Visitors (as each is defined in the User Agreement).

 

Information you provide to us


When you use the Service, you may provide us with information about yourself. This may include your name and contact information, financial information to make or receive payments for services obtained through the Blind platform, or information to help us complete tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate it with information about other users. This helps us improve our Services for you. You may also provide us with information about your contacts or friends if, for example, you wish to add those contacts to a message room. Agencies may also provide us with information about Content Creators associated with the Agency.

 

Personal Information: When using the Service (whether as a Client or Content Creator or Agency), we may require or collect information that identifies you as a specific individual and that can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, billing address, and
phone number.

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Payment Information: If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card information or other financial account information, and billing address.

 

Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued ID or photo or a bank statement.


Biometric Identifiers or Service Interaction Information: We may collect Personal Information to verify your identity and detect fraud, identity theft, or other misuse of your account through facial recognition and other technologies. This could be a photograph of your
face, a selfie, or data about your interactions with the Service. We may request documents to verify this information, such as a copy of your government-issued ID. From time to time, Blind may require you to take and submit another updated image of your face to compare against your government-issued ID. Biometric identifiers or information collected are used only for identity verification and platform security and usage integrity purposes.


General Audience Service: The Service is a general audience and is intended for users aged 18 and over. We do not knowingly collect Personal Information from anyone under 18 years of age. If we become aware that a child under 18 has provided us with Personal Information, we will make commercially reasonable efforts to remove such information from our files. If you are the parent or legal guardian of a child under 18 and believe that Blind has collected Personal Information from your child, please contact us at: leagal@blindcreator.com.

 

If you are not of legal age in the jurisdiction where you reside, you have received permission to use the Services from your parent or legal guardian.


Non-identifiable Information / Usernames: We may also collect other information, such as zip codes, demographics, information about your use of the Service, and general project related data (“Non-identifiable Information”). We may combine information collected from Blind Users, whether registered or not (“Blind Users”). In some cases, we may convert Personal Information (typically, email address) into a form of Non-identifiable Information referred to in this Privacy Policy as “Hashed Information.” This is generally accomplished by using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not directly identify you, but it may be used to connect your activity and interests.

 

Combination of Personal and Non-identifiable Information: Sometimes when Non-identifiable Information is combined, it can identify an individual. For example, if a date of birth is combined with a name, it could identify a person even if the birthday or name alone could not. But the same pieces of information are considered Non-identifiable Information when taken alone or combined only with other Non-identifiable Information (e.g., your viewing preferences). We may combine your Personal Information with Non-identifiable Information, but Blind will treat the combined information as Personal Information.

 

Collection of Personal Information from third parties: We collect the following personal information from you about your contacts or friends: first name, last name, and email address when you provide it to us for the purpose of adding your contacts to a message room.

 

You have no legal obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide you with our Service. If you have any questions about whether the provision of information is mandatory and the consequences of withholding such information, please contact us using the contact information below.

 

 

Information received from third parties

 

Third parties may also give us information about you. If we combine that information with information about you collected through the Service, we will continue to treat that combined information as set out in this Privacy Policy.


We may also receive information about you from third parties. For example, we may supplement the information we collect with outside records or third parties may provide information in connection with a joint marketing agreement or at your request (such as if you choose to sign in with a third-party service). If we combine the information we receive from others with information we collect through the Service, we will treat the combined information as described in this Privacy Policy.

 


Automatically Collected Information
Like other online companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve the way our Site works, to save your login information for future sessions, and to provide you with ads that may interest you.


We and our third-party service providers, including third-party analytics and content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, the areas within the Service that you visited, what links you clicked on, what pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages, and other information commonly shared when browsers communicate with websites.We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you and to improve marketing, analytics, and site
functionality.


The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned to or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information about the physical location of the device used to access the
Service.


Blind and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movement around the website, desktop app, and mobile app, and to gather demographic information about our user base as a whole. The technology used to automatically collect information from Blind Users may include
the following:


Cookies: Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with Blind’s Terms of Service) and session ID cookies, which expire at the end of your browser session (e.g., to enable certain features of the Service, to better understand how Blind Users interact with the Service, and to monitor aggregate usage by Blind Users and web traffic routing on the Service). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service.

 

Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “Web Beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve you relevant advertising. Web Beacons are tiny graphics with a unique identifier that may be invisible to you and are used to track the online activity of Internet users. Web Beacons are embedded in the web pages you review or in email messages you receive. Web Beacons or similar technologies may be used for a number of
purposes, including, without limitation, to count visitors to our Service, to monitor how Blind Users navigate the Service, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.


Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.

 

In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes, and we may use third parties to perform these services on our behalf.

 


HOW WE RESPOND TO DO NOT TRACK SIGNALS

 

Blind does not respond to Do-Not-Track signals.

 

Please note that your browser setting may allow you to automatically transmit
a “Do Not Track” signal to websites and online services you
visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and
online services, Blind does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. For more information about “Do
Not Track,” please visit http://www.allaboutdnt.com.


The General Data Protection Regulation: Data Processing
Addendum

 

To streamline General Data Protection Regulation (“GDPR”) compliance, Blind has published a Data Processing Addendum (“DPA”) that governs the relationship between Client (as defined in the DPA) acting as controller or data processor, as applicable (and as defined in the DPA), of personal data under European Data Protection Law; and Blind (acting as data processor or subprocessor, as applicable).

 

Unless you and Blind otherwise agree in writing, to the extent Blind processes any EU personal data for you as a controller (as defined by the General Data Protection Regulation (EU) 2016/679) in your role as a Client, the Data Processing Addendum applies.

 

Content drafts and job view

 

We collect information about a Content Creator’s work for a Client, including automatically collected information about work on a particular campaign. If a Content Creator enables Content Drafts, we will share the drafts with the Client and Agency
involved. We tell Content Creators when we are capturing information for the Work Diary and allow Content Creators to block such data sharing.


As part of the Service, when enabled by a Content Creator, we collect information about a Content Creator’s work on a project for a Client. This feature is known as a Work Diary. Work Diaries include information provided by the Content Creator, such as a memo, as well as automatically collected information about work on a campaign, (which may include a webcam photo of you if you have enabled this feature in your settings). To use Content Drafts, you must download and install the Team App software from www.blindcreator.com.

 

We will share information contained in Work Drafts with the relevant Client and any managers or administrators of any applicable Agency. We inform Content Creators each time we capture information for Work Drafts. As set out in
our Terms of Service, End User License Agreement, and help pages on the Site, a Content Creator may elect to block or delete screen shot and associated data for a recorded work interval, but then the Content Creator may not be paid for that work interval. Blind may use unidentified or aggregated information from Work Drafts for statistical analysis, product development, marketing, and research.

 

User Profiles


Content creators may create a profile, with some or all information publicly available. Clients and Agencies may also create organizational profiles.


You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, hourly payment rates and earnings information, feedback/rating information, and other information, including your username (“Profile”). Your Profile information may be visible to all Blind Users and the general public, subject to the privacy choices you make within your Blind Profile. If you choose to make your profile publicly visible, your profile will be visible to the entire Internet, including clients, freelancers, visitors, and search engines like Google and Bing, and may appear on Blind partner sites. You can edit certain information in your Profile through your account and may choose to limit who can view certain content you post to your Profile. Individual user clients and associated agencies or companies may also have the opportunity to create an organizational profile. If, in any

case, you believe an unauthorized profile has been created about you, you can request its removal by contacting us at legal@blindcreator.com.

 

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Identity Verification


We prioritize trust on our Service, so we may take steps to verify your identity.

 

Before a Content Creator can complete registration on the Service, or at any later time, we may request or re-request identity verification. Without limiting how we request identity verification, we may require Content Creators to participate in a video call after submitting their government-issued ID to enable us to confirm that the Freelancer is truly the person in the ID. We may record such video calls and take screenshots of the user during the call. Blind may use information obtained from identity verification for the purpose of verifying your identity, enforcing our Terms of Service and other agreements, and preventing fraud.

 

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Messaging

 

Content Creators, Agencies, and Clients can communicate with each other through the Service. For example, Content Creators, Agencies, and Clients may wish to discuss Client needs and Content Creator work proposals. If you communicate with an Agency or Client, that Agency or Client will also be a “data controller” with respect to such communications.

 

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Community Forums

 

We may offer public forums or blogs. If you participate, your comments and questions
will be publicly displayed.

 

The Service may provide you the opportunity to participate in and post content publicly in forums, on blogs, through interactive features on Blind, and through other communication features (“Community Forums”). You may choose, through such features or otherwise, to submit or post questions, comments, or other content (collectively, “User Forum Content”).

 

Please note that certain information, such as your name and Profile, may be publicly displayed on the Service along with your User Forum Content. Please note that your use of the Community Forums is subject to Blind’s Forum Rules and our Terms of Service.

 

Please be aware that anything you post to a Community Forum is public – others will have access to your User Forum Content and may use or share it with third parties. If you choose to voluntarily disclose Personal Information in your User Forum Content or to use Community Forums to link to your Profile, that information will be considered public information and the protections of this Privacy Policy will not apply.

 

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Testimonials

 

We display personal testimonials of satisfied customers on our Service, 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 admin@blindcreator.com.

 

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Job Listings via the Service

 

If you choose to post a job listing via the Service as a Client, the contents of such listing will be publicly visible, unless you designate the listing as only visible through the Service or as private using the settings available on the applicable website. Job listings include information such as budget, location, Client job listing history, names of other Content Creators performing work for the Client, Client feedback and rating information, and project performance timing.

 

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Feedback

 

We collect public and private feedback from Blind Users about their experience with other Blind Users of our Service. Please note that any public feedback you provide via the Service about your experience with other Blind Users of our Service or that other Users provide about you is publicly visible via the Service. On rare occasions, we may remove feedback pursuant to the relevant provisions of our Terms of Service, including the Terms of Use. Any private feedback you provide via the Service about your experience with other Blind Users of our Service or that other Users provide about you will not be publicly visible via the Service.

 

We also collect feedback from Users about our Service. We use this information to respond to your inquiries, to improve the Service and how our Site works, and to develop new products and features.

 

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Email to Friends and Referral Program


Blind allows you to email project postings to friends. Blind also offers the ability to email friends about providing or purchasing services via the Service. You should only provide Blind contact information for people you know and with their consent. If you choose to use either of the features, your friend’s email address will be used to send the requested posting and your email address will be used to copy you on the message to your friend or to send the message on your behalf. Blind stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.


Your friend may contact us at https://support.blindcreator.com or legal@blindcreator.com to request that we remove this information from our database.

 

 

Social Network Services


You may register for an account directly with our Site or through a social network service. If you register for a social network service (or later link your account to one), we will collect certain information about you from that social network service, and what we collect depends on your privacy settings with that social network service. The Service may also
allow you to “like” or share content with social network services.

 

You may register to join the Service directly through the Service or by logging into your account with a third-party social network service (“SNS”) via our Service (e.g., Facebook, TikTok, and other third party services that let you sign in using your existing credentials with those services). If you elect to register through an SNS, or to later link your account with the Service to your account with an SNS, we will use the Personal Information you have provided to the SNS (such as your name, email address, gender, and other information you make publicly available via the SNS) to create your account. Please note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Information an SNS has about you is obtained by the SNS
independently of our Service, and Blind is not responsible for it.

 

The Blind Service may also permit additional interactions between it and a third-party website, service or other content provider, such as enabling you to “like” or share content with a third-party SNS. If you choose to “like” or share content, or to share information from or through our Service with a third-party site or service, that information may be publicly displayed, and the third party may have access to information about you and your use of our Service (and we may have access to information about you from that third party). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Your interactions with third parties through an SNS or similar features are
governed by the respective privacy policies of those third parties.

 

You represent that you are entitled to use your SNS account for the purposes described herein without breach by you of any of the terms and conditions that govern the SNS, and without obligating Blind to pay any fees or making Blind subject to any usage limitations imposed by such SNS. You can disable the link between your Blind account and your SNS account at any time through the “Settings” section of our Service. Please note that your relationship with any SNS is governed solely by your agreement(s) with such SNS. If your SNS account terminates, functions enabled through the link between your Blind account and your SNS account will also terminate.

 

 

SMS Terms of Service

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US Short Code Terms of Service
 

Blind Alerts


For users who opt in, the Blind Alerts SMS program sends helpful reminders related to activity on the Blind platform and other marketing and promotional messages, such as event invitations and job post support.

 

The number of messages received may vary based on user activity. Messaging and data usage rates may apply to all text messages between you and Blind. If you have any questions about your text plan or data plan, it’s best to contact your wireless service provider. This program is provided as a service to you, and neither Blind nor your mobile carrier will be liable for delayed or undelivered messages.

 

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B. USE OF INFORMATION


We use information collected through the Service to provide and improve the Service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and, as permitted, with your consent.

 

WE USE THE INFORMATION WE COLLECT TO:
 

To provide and improve the Service, complete your transactions, address your inquiries, process your registration, verify that the information you provide is valid, and for internal business and compliance purposes.

 

To contact you with administrative communications and Blind newsletters, marketing or promotional materials (on behalf of Blind or third parties) and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions in the Your Choices and Rights section,
below.

 

To tailor the content we display to you and the offers we may present to you, both on the Service and elsewhere online.

 

To manage and develop our business relationship with you and, if applicable, with the corporation or other legal entity you represent.

 

To evaluate your proposal to perform a freelance project for Blind and to prepare related governmental and internal statistical reports.

 

To enforce and comply with the law, including conducting an investigation, to protect the property and rights of Blind or a third party, to protect the safety of the public or any person, or to prevent or stop activity that we may consider to be, or poses a risk of being, illegal, fraudulent, unethical, or legally actionable activity. We may also use device identifiers to identify Blind users.

 

For the purposes disclosed at the time you provide your information, with your consent, and as described in more detail in this Privacy Policy. We use your personal information for the purposes described above to:

 

To comply with our contractual commitments to you. Much of our processing of personal information is to fulfill our contractual obligations to our investors, or to take steps at the request of Users in anticipation of entering into a contract with them.

 

For our legitimate interests. In many cases, we handle personal information on the grounds that it furthers our legitimate interests in business activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

  • Providing our Site and Service.

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  • Measuring interest and engagement in our Services.

  • Short-term, transient use, such as contextual customization of ads.

  • Improving, updating, or enhancing our Services.

  • Developing new products and services.

  • Ensuring internal quality control and safety.

  • Authenticating and verifying individual identities.

  • Debugging to identify and repair errors with our Services.

  • Auditing related to interactions, transactions, and other compliance activities.

  • Enforcing our agreements and policies.

  • Analyzing and improving our business.

  • Communications, including marketing and responding to your inquiries about our services.

  • Addressing information security needs and protecting our Users, Blind, and others.

 

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Managing legal matters.
 

To comply with legal obligations. We need to use and disclose personal information in certain ways to comply with our legal obligations.

 

C. DATA RETENTION
 

Unless you request that we delete certain information (see Your Choices and Rights below), we retain government-issued identification documents you submit to verify your identity for 40 days, selfies you submit to verify your identity for 180 days, a copy of the headshot from your ID for 5 years, and other information we collect for at least 5 years. Your information may persist in copies made for backup and business continuity purposes for additional time. If you choose to provide us with personal information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.

 

D. INFORMATION SHARING AND DISCLOSURE
 

We may share information about you to provide the Services, for legal and investigative purposes, in connection with sweepstakes and promotions, or if we are part of a merger or acquisition. We may also share non-identifiable information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes.

 

We may share aggregated non-identifiable information and may disclose non-identifiable information (including, but not limited to, hashed information) to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with an opportunity to opt in or opt out of such sharing. We may also share information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, or in the following circumstances:

 

Information about Content Creator Shared with Clients, Agencies, Blind Payroll Providers, and The Blind Foundation Initiative Partners: We share information about Content Creators who have entered into a contract with a Client or who have chosen to participate in Blind Payroll, including information in work drafts and work history, with Clients, Agencies, and Blind Payroll providers. Please note that if a Content Creator is suspended from the Blind Service, we may share that information with Clients for whom that Content Creator has worked or has submitted work proposals. We may also share information with Agencies to which Content Creators are associated for a particular work project. If you choose to view a job posting or submit a work proposal as a Content Creator via the Service, we may share relevant information with applicable Clients, including, but not limited to, information contained in your Content Creator Profile. If you choose to participate in The Blind Foundation Initiative as a Content Creator, we may share information relevant to your participation in the program with Blind partners who provide support to Content Creators through that program.

 

Information about Clients and Agencies shared with Content Creators: If you have entered into a service contract or have agreed to use Blind Payroll with another user, we may provide your name, company address, billing address, or tax ID or VAT number to complete the transaction or facilitate resolution of a claim or dispute. The user receiving your information may not use it for purposes unrelated to the transaction, such as contacting you for marketing purposes, unless you have expressly consented to it.

 

Service Providers: We may employ third-party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Blind features) or to assist us in analyzing how our Service is used. These third parties may have access to your personal information to perform these tasks on our behalf. What happens if you agree to receive information from third parties or request that we share your information: You may be presented with the opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time that your Personal Information be shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to that third party’s privacy policy and practices. We are not responsible for the privacy policies and practices of third parties, and if you later decide that you no longer wish to receive communications from a third party, you will need to contact that third party directly. You may also request, sometimes through the use of an SNS or a similar interactive feature or third-party application, that we share information about you with a third party, and we will generally do so in those circumstances.

 

Legal and Investigative Purposes: Blind will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including, but not limited to, in connection with earnings reporting. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including, but not limited to, subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation when we determine in our sole discretion that disclosure is necessary to (a) protect the property and rights of Blind or a third party. party, (b) protect the safety of the public or any person, or (c)
prevent or stop activity that we may consider to be, or poses
a risk of being, illegal, fraudulent, unethical, or legally
actionable activity.

 

Internal and Business Transfers: Blind may share information, including Personal Information, with its parent company Blind Creator Inc. and any current or future subsidiary or affiliate, primarily for business and operational purposes, including activities such as IT administration, to provide you with services or support and complement the Services we provide. We may sell, transfer, or share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization, or sale of assets (including, in each case, as part of the due diligence process with any potential acquiring entity) or in the event of bankruptcy.

 

Sweepstakes, Contests and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you agree to the official rules that govern that Promotion, which may contain specific requirements from you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of person in advertising or marketing associated with the Promotion. If you choose to participate in a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the official rules of the Promotion, such as in the winner list.

 

 

E. THIRD-PARTY ANALYTICS PROVIDERS, AD SERVERS, AND
SIMILAR THIRD PARTIES

 

We may work with advertising agencies and providers who use technology to help us understand how people use our Site. These providers may use technologies to serve you ads that may interest you. You can opt out of interest-based advertising.

 

Blind works with (or may work in the future with) network advertisers, advertising agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Service, including page views and actions taken when visiting the Service; to serve our advertisements on other websites, within mobile applications, and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service, as well as on other websites or services, may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other websites and online services. We may also share certain Non-identifiable Information with these parties, including hashed information, in connection with the services they provide to us. If you wish to opt out of interest-based advertising, please click here (or if you are in the European Union, click here). If you opt out, please note that you will still receive generic ads.

 

While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information about targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information about targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program.

 

 

F. YOUR CHOICES AND RIGHTS

 

In accordance with applicable law, you may have certain choices and rights associated with your personal information.

 

Communication preferences.

 

Registered Blind Users can update their choices regarding the types of communications they receive from us through their online account.

 

You can opt out of receiving marketing emails from us by following the unsubscribe instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (e.g., administrative and service announcements) by email and other means, and these transactional account messages may not be affected if you opt out of receiving marketing communications.

 

Registered Blind Users who access the Service using a Blind mobile application may, with permission, receive push notifications. Similarly, registered Blind Users who access the Service using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu of the mobile application or applicable browser.

 

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Data Subject Rights.

 

In accordance with applicable law, you may have the right to:

 

Access personal information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access or a copy of your personal information.


Request the correction of your personal information when inaccurate, incomplete, or outdated. In some cases, you can update your personal information within your Blind account by logging in and visiting settings/user settings.


Request the deletion, anonymization, or blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive, or non-compliant. Please note that if your information is deleted, your account may be deactivated. If your account is deactivated or you request to close your account, you will no longer be able to use the Service. If you wish to close your account in our system, you can do so through the Blind Service (once logged in, visit settings/user settings and then click the Close my account link).

 

Request the restriction of or object to our processing of your personal information when processing is not compliant.

 

Withdraw your consent for us to process your personal information. If you refrain from providing personal information or withdraw your consent for processing, some features of our Service may not be available.

 

Request data portability and receive an electronic copy of the personal information you have provided to us.

 

Be informed about third parties with whom your personal information has been shared.

 

Request a review of decisions made solely on the basis of automated processing if this could affect the rights of data subjects.

 

Please refer to our Privacy Center for more information or to send us a request regarding your personal information. Blind uses automated means to calculate freelancers’ job success score. If you believe our services have miscalculated your job success score or if you wish to exercise any other right regarding your personal information, please email us at legal@blindcreator.com for assistance. We may be able to assist you by performing a manual review of your job success score, such as evaluating whether the information you have provided to us is accurate. While we strongly encourage you to first raise any questions or concerns about your Personal Information directly with us, you have the right to file a complaint with the relevant supervisory authority and to seek judicial redress.

 

We will make commercially reasonable efforts to comply with your deletion requests; however, certain information will actively persist on the Service even if you close your account, including information in your Work Drafts and messages you posted to the Service. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information that we are required by law to retain or have compelling legitimate interests in retaining (e.g., for fraud prevention purposes). Your personal information may remain in our files and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. Furthermore, we will not ordinarily remove information you have publicly posted on or through the Service. Please note that neither you nor Blind can delete all copies of information that has been previously shared with others on the Service.

 

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G. SECURITY

 

We take a number of steps to protect your data, but security is not guaranteed.
 

Blind takes commercially reasonable steps to help protect and secure the information it collects and stores about Blind Users. All access to the Site is encrypted using industry-standard Transport Layer Security (“TLS”) technology. When you enter sensitive information (such as taxpayer ID number), we encrypt the transmission of that information using Secure Socket Layer (“SSL”) technology. We also use HTTP Strict Transport Security to add an extra layer of protection for our Blind users. But please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your personal information, Blind cannot guarantee and does not guarantee the security of any information you transmit to us.

 


H. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

 

Because we are a U.S. company, we process and store your information in the United States and our service providers may process and store it elsewhere.

 

Blind is a U.S. company. If you are located outside the United States and choose to provide information to us, Blind transfers Personal Information to the United States for processing, and our service providers may process Personal Information in the United States and elsewhere. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to the United States, we will protect it as described in this Privacy
Policy.

 

When we transfer Personal Information from territories in the EEA or with similar laws to our affiliates or service providers in the United States and elsewhere outside the EEA, we rely on approved data transfer mechanisms, which may include standard contractual clauses approved by the European Commission and the Privacy Shield, as described below. You may request a copy of the relevant standard contractual clauses for your Personal Information, if applicable, using the contact information below.

 

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I. LINKS TO OTHER SITES

 

Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third-party’s website. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

 

 

J. PUBLIC PROFILE

 

The profile you create on our Site will be publicly accessible unless otherwise indicated. This means it will be visible to the entire Internet, including clients, freelancers, visitors, and search engines like Google and Bing, and may appear on Blind partner sites. You can change your profile’s privacy settings through your account portal.

 

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K. PHISHING

 

Phishing websites mimic legitimate websites to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to Blind. For more information about phishing, visit the Federal Trade Commission’s website at http://www.consumer.ftc.gov/articles/0003-phishing. In addition, if you believe you have received an email or had a similar interaction with a third party impersonating Blind, please report it at https://support.upwork.com.

 

 

L. CHANGES TO THIS POLICY

 

We may change this Privacy Policy. If we make material changes, we will
notify you.

 

Blind may update this Privacy Policy at any time, and any changes will be effective upon posting. In the event of material changes to how we treat your personal information, we will display a notice through the Services before the change becomes effective. We may also notify you by email, at our discretion. However, we will use your personal information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.

 

 

M. SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
 

This Supplemental Privacy Notice for California Residents supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information that we collect on or through the Service and through other means (such as information collected offline, in person, and by telephone). It does not apply to personal information that we collect from our employees or job applicants in their capacity as employees and job applicants. Nor does it apply to information we collect about businesses that use our Service, including employees, owners, directors, officers, or contractors of those businesses, in the course of our provision or
receipt of business-related services.

 

Summary of information we collect
 

California law requires us to disclose information about the categories of personal information we have collected about California consumers (as that term is defined in the California Consumer Privacy Act (“CCPA”)), the categories of sources from which the information was collected, the business or commercial purposes (as defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

 

We or our service providers may collect the following categories of information for the following business or commercial purposes (as those terms are defined in applicable law):

 

Providing the Service (e.g., account service and maintenance, matching freelancer talent with client needs, customer service, advertising and marketing, analytics, and communication about the Service);

 

Our or our service providers’ operational purposes;

 

Auditing consumer interactions on our site (e.g., measuring ad impressions);


Detecting, protecting against, and prosecuting privacy and security incidents and fraudulent or illegal activities;

 

Error detection, error reporting, and activities to maintain the quality or safety of our Service;

 

Investigating compliance, enforcement, and/or compliance with the law;

 

Short-term, transient use, such as customizing the content we or our service providers display on the Service;

 

Improving our existing Service and developing new services (e.g., by conducting research to develop new products or features);

 

Other uses that promote our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from us or third-party partners;

 

Other uses that we notify you about.

 

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Accessibility


This Privacy Policy uses industry-standard technologies and was developed in connection with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

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