Culinary Agents Inc.

Privacy Policy

Last updated: December 1, 2016


We at Culinary Agents Inc. (“we,” “us,” or “Culinary Agents”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how the information that you provide to us is used and shared. This Privacy Policy relates to our information collection and use practices in connection with the www.culinaryagents.com website and the related mobile application through which we provide a gateway to our services. In this Privacy Policy we will refer to our website and mobile application as our "Platform".


Parents and guardians of children and teenagers under the age of 18 who wish to use the Platform must read this policy.


The information we collect, and how we use and share this information:

In the course of operating the Platform, we will collect (and/or receive) the following types of information.

1.  Registration Data

When you sign up to become a registered user of our Platform ("Registered User"), you will be required to provide us with certain information for registration purposes ("Registration Data"), which consists of personal information about yourself, such as, for example, your name, e-mail address, location, and phone number. If you contact us, you will need to provide your name and e-mail address. Registered Users may also provide other personal data in the course of using the Platform. If a Business has purchased certain products or services from us and that Business hires you, you will be required to also provide us with your social security number or tax number. We encrypt all social security numbers or tax numbers that we collect. We use your Registration Data and other personal information you provide in connection with your registration to enable your use of our Platform and to provide our services to you.

To provide our services to Registered Users, we share this personal information (including your social security or tax number) with the Businesses (i.e. businesses seeking candidates) that you select through the Platform. Use by a Business of your personal information is subject to the privacy policy of the relevant Business and is not subject to the terms of this Privacy Policy. Please be assured that we will only make your social security or tax number available to the Business(es) that you have selected and we do not otherwise share tax numbers with other organizations (other than Culinary Agents Inc. for the purposes of the operation of the Platform, as indicated below).

If you log-in to your Registered User account using any of your social media accounts, we may also collect, store, and use information that the relevant social media company provides to us through its Application Programming Interface (“API”). You control the information that we receive through these APIs and such information may include, your first and last name, username, profile picture, unique social media identifier, access token, e-mail address, social friends, current location, education history and work history . This information is also personal information and this Privacy Policy will apply to our collection and use of this personal information.

2.  Billing Information

If you are required to pay any fees to use the Platform, you will be required to provide certain information to our third-party payment processor(s). Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. In this Privacy Policy we will refer to this information as “Billing Information.” We do not store or process your Billing Information. Our third-party payment processor(s) collect, store and use your Billing Information in accordance with their terms of use and privacy policy, and not in accordance with this Privacy Policy. Our current third-party payment processor is Stripe, and Stripe's terms of service and privacy policy can be found here: https://stripe.com/us/terms and https://stripe.com/us/privacy.

3.  Other Information

We may collect additional information about you and/or your business (which we will refer to in this Privacy Policy as “Other Information”). This Other Information may be collected from visitors to our Platform who are not Registered Users as well as from Registered Users. Such Other Information may include:

  1. From You. Additional information about yourself that you voluntarily provide to us, such as job title, company size and annual revenue, product and service preferences.
  2. From Cookies and Other Technology. Like most websites, we use automatic data collection technology when you visit or use the Platform to collect information that identifies your computer or device. This comprises information about your operating system, your IP addresses, browser type and language, referring pages and URLs, keywords, date and time, and what sections of our Platform you visit, as well as the universally unique ID (“UUID”), advertising identifier (“IDFA”), MAC address; operating system and version (e.g., iOS, Android or Windows), carrier and country location, hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled), network type (WiFi, 3G, 4G, LTE), and similar data (collectively, the "usage information"). We collect this usage information by using cookies. Cookies are small packets of data that a website stores on your computer's hard drive so that your computer will "remember" information about your visit. You can reject cookies by following the directions provided by your browser vendor or by your Internet provider's "help" file. If you reject cookies, you may still visit and use the Platform, but may not be able to use some areas of our Platform. We use cookies (and the usage information collected) to help us identify you and analyze how you use our Platform.

    We also work with trusted third party partners which use cookies to collect usage information about how users use our Platform, for example, which pages users go to most often, and if they get error messages on those pages. The trusted third parties we currently work with include the following (click on the links to view these organizations' privacy policies and find out more about what data they hold about you, what they do with it, and how to opt-out from certain data collection):

    We may share Other Information about your activity on the Platform with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Platform and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

    We also use one or more third-party remarketing and conversion tracking services (including Twitter and Google Adwords) to advertise to users of our Platform on third party websites. These third-party service providers use cookies to serve ads based on a past visit to our Platform. Any data collected by such third party service providers will be used in accordance with this Privacy Policy and the privacy policy of such third party services provider. The third parties that are currently providing us with these services are listed below; for more information on these third party service providers, including how to opt out from certain data collection, please see below:

  3. Geo-locational Information

    Certain features and functionalities of the Platform are based on your location. In order to provide these features and functionalities while you are using a mobile device, we may automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers. Collection of this information occurs only when the Platform is running on your mobile device. You may decline to allow us to collect such information by adjusting your browser settings, in which case we will not be able to provide certain features or functionalities to you.

4.  Aggregate Data

In an ongoing effort to better understand our visitors, Registered Users, and the Platform, we may analyze Information in aggregate form to operate, maintain, manage and improve our Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners, including, without limitation, Businesses. We may also disclose aggregated user statistics in order to describe the Platform to current and prospective business partners and to other third parties for other lawful purposes.

5.  Purpose of Collection and Use

We use the information that we collect from you under this Privacy Policy to provide our Website, App, Platform and related support; to process and ship Product orders; to respond to general inquiries; to solicit feedback regarding our Website, App, Platform and related support and the Products; to provide relevant content on our Website, App and Platform, including advertisements regarding products and services of ours or third parties; to send invoices and receive payments; and to communicate with you regarding our current and future product and service offerings and those of our third-party marketing partners.

6.  Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information or Other Information and their functions are: direct marketing assistance, email marketing, data analytics, payment processing, billing, customer service, data storage, hosting services, disaster recovery services, sales support, logistics support, and technical assistance. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by us. You may opt out of having your personal information transferred to any or all of our categories of agents by contacting us at [email protected]. Please allow us a reasonable time to process your request. With regard to the Principle of Accountability for Onward Transfer, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

7.  Opt-In to Certain Onward Transfers

We will not transfer your personal information to a third party acting as a controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent. You may grant such consent by contacting us at [email protected]. Please allow us a reasonable time to process your response.

8.  Related Entities; Business Transfers

We may share your personal information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us for aggregation, analysis and benchmarking purposes.

In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

9.  Disclosure to Public Authorities

We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

10.  Opt-Out for Direct Marketing; Email Management

You may opt out at any time from the use of your personal information for direct marketing purposes by contacting us at [email protected]. Please allow us a reasonable time to process your request.

You may manage your receipt of marketing and non-transactional communications by clicking on the “Manage Email Preferences” link located on the bottom of any Culinary Agents marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to your Registered User account.


Information you share through the Platform:

The Platform allows you to share User Content (including documents, text, files, photos and so on – see our Terms of Use for a more detailed explanation of what we mean by 'User Content') with Businesses and other users. Your User Content may include personal information. We cannot be responsible for any third-party use of your information, and this Privacy Policy does not apply to any information that you share in any of the foregoing ways.


Access to your personal information:

Culinary Agents acknowledges that EU individuals have the right to access the personal information that we maintain about them. Upon request by sending an email to [email protected], we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time after your request. You have the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.


Retention of personal information:

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.


How we protect your personal information:

We take very seriously the security and privacy of the personal information that we collect pursuant to this Privacy Policy. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.


Children:

We do not knowingly collect any personal information from children under the age of 13 through our Platform. If you are under the age of 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected], and we will endeavor to delete that information from our databases.


Links to external websites:

Our Website may contain links to third party websites, including, without limitation, those of Businesses (“External Sites”). We have no control over the privacy practices of these External Sites. As such, we are not responsible for the privacy policies of those External Sites. You should check the applicable third party privacy policy and terms of use when visiting any External Sites, and before providing any personal information to such External Sites.


Important notice to non-US residents:

Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield and the U.S.-Swiss Safe Harbor Framework, your decision to provide such data to us, or to allow us to collect such data through our Platform, constitutes your consent to this data transfer.


Important notice for residents of the European Economic Area:

We comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway). We have certified that we adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Privacy Shield Principles”). If there is a conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with inquiries or complaints regarding this Privacy Policy should first contact us at [email protected].

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.


Important notice for residents of Switzerland:

We comply with the U.S.-Swiss Safe Harbor as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. We have certified that we adhere to the U.S.-Swiss Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement (the “Safe Harbor Privacy Principles”). If there is any conflict between the policies in this Privacy Policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/.

In compliance with the Safe Harbor Privacy Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this Privacy Policy should first contact us at: [email protected].

We have further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.


California Privacy Rights:

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83 of the California Civil Code, please contact us via email at [email protected].

We do not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.


Changes to this Privacy Policy:

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on our Platform as soon as they go into effect. By accessing or using our Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.


How to Contact Us:

If you have questions about this Privacy Policy, please contact in one of the following ways:


Copyright 2016 Culinary Agents Inc. All rights reserved.