A. Scope
This Statement applies to personal information (i.e. information about an identified or identifiable individual) we collect and process (whether electronically, in writing or orally) from applicants seeking employment with Bright Market, LLC dba FastSpring and its subsidiaries and affiliates (collectively FastSpring, “we”, “us” and/or “our”) during the application and recruitment stage, as well as during your employment with us.
This Statement is comprised of two sections – a generally applicable statement and location-specific addendums. This initial section describes the standards in relation to how FastSpring as a whole collects and manages information during the application and recruitment stage, as well as during your employment with us. To the extent there are variations within a specific market or additional information that is required to be provided under the applicable law, a local market addendum has been attached.
B. Information we collect and process
FastSpring collects personal information during the application stage which includes:
During your employment with us, we may also collect certain sensitive categories of personal information to comply with the applicable law as well as if needed for legitimate business purposes with your consent (e.g. equal opportunity compliance). This may include information about your race, ethnicity, gender, veteran status, and any physical limitations or other medical or health-related workplace accommodations.
In certain instances, FastSpring may also collect additional information from third parties that assist us during the recruitment stage, as well as during your employment with us, including, where applicable, the results of credit and criminal background checks, drug and alcohol testing, and other screening procedures. You may also elect to have third parties, such as social media providers, share information with us as part of the recruitment process or we may collect this information if publicly available.
The personal information collected may vary from jurisdiction to jurisdiction in accordance with applicable law. Your provision of certain information is optional, however, your failure to provide certain information may disqualify you from employment with FastSpring.
C. How we use and disclose your information
We use personal information to assess your qualifications for employment during the recruitment stage and to fulfill your employment contract with FastSpring during your employment with us. This may include contacting you after you have applied, contacting references that you have provided, and carrying out background checks. We also may use your information to comply with any applicable legal obligations, record-keeping, business operations, or reporting obligations as well as to establish, exercise, or defend against any legal claims.
In order to carry out the services and objectives contemplated in this Statement, your information will be shared with third parties that assist us during the recruitment process.
During your employment with us, we will share information with our service providers, including any benefits providers, such as payroll and insurance benefits, whom we engage to provide employment benefits to you.
We may also share information with third parties:
As part of our recruitment process, we may also use information you provide (on either an individual-specific or aggregated basis) to improve our application and hiring process at FastSpring. If you elect to do so, we may also use your information to contact you in the future, for example, if you join our Talent Community.
D. Data transfers and centralized processing
FastSpring has centralized and outsourced various aspects of our business to improve how we manage and administer our recruitment process and to process your information for our business purposes during your employment with us. As a result, it may be necessary to transfer your information to a country outside of the country where it was originally collected or outside of your country of residence in order to assess your qualifications for employment. These transfers may be to any FastSpring entity around the world as well as to third-party service providers that help FastSpring manage and administer its recruitment process and for our business purposes during your employment with us.
E. Security
We have in place appropriate technical, physical, and organizational security measures that are designed to protect against unauthorized access, disclosure, damage, or loss of personal information. The collection, transmission, and storage of information can never be guaranteed to be completely secure. However, we take steps to ensure that appropriate security safeguards are in place internally and with our third-party service providers to protect your personal information.
F. Retention
Subject to the applicable law, FastSpring will only retain your personal information for the duration of time necessary to assess your qualifications for employment or otherwise in accordance with our record retention schedules. If you are employed by us, we will retain your information as long as required by applicable law and to fulfill our obligations as an employer. We may retain aggregated information in order to improve our recruitment and hiring practices for a longer duration, however, that information cannot be used to identify you. You may also elect to have your information remain with FastSpring for a longer duration, for example, if you decide to participate in FastSpring’s Talent Community.
G. Access to and control of your information
We want to ensure that you have the necessary tools at your disposal to control the information that you provide to us. It is also important that you contact us to keep your information accurate and up to date. To the extent you are not able to update your information directly through our application portal or website, please contact us at privacy@fastspring.com. Depending on your location, you may be entitled to request access to, erase, restrict and object to the processing of your personal information that is held by FastSpring. These requests should also be sent to privacy@fastspring.com.
These requests will be reviewed and processed in line with local law. If you are located in a European Union Member State or in the State of California, please see the respective addendums for additional information on your rights in this area.
H. Cookies and other tracking technologies
We use cookies (a small text file placed and saved in your browser when you access our websites), web beacons (a graphic file placed on a website to gather usage and performance data), and other tracking technologies as part of providing the services described in this Statement. In certain instances, cookies and other tracking technologies may also be used to serve you more relevant advertisements and for other personalization purposes. These technologies may be set by us or by third parties. There are ways to control and/or reject the setting of cookies and similar technologies within your browser settings. As each browser is different, please consult the “help” menu within your browser. Depending on the services being used, restricting cookies may prevent you from accessing and using all or part of the services.
I. Your choices about online ads
We support the self-regulatory principles for online advertising (“Principles”) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt-out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices , or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt-out of interest-based advertisements across all your browsers and devices, you will need to opt-out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt-out again. If you want to opt-out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices .
Please note that when you opt-out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.
J. Questions and how to contact us
If you have any questions in relation to the collection and management of your personal information by FastSpring under this Statement, please contact FastSpring at privacy@fastspring.com.
K. Changes to this Statement
From time to time we may change, modify or amend this Statement in order to comply with the evolving regulatory environment or the way we operate our business. Subject to any applicable legal requirements to provide additional notice and/or obtain consent, any changes to this Statement will be communicated to you through this website.
L. Effective date
September 10, 2023
Addendum A – United States (California)
Privacy Statement for California Residents as required by the California Consumer Privacy Act of 2018 (“CCPA”)
Last updated: February 11, 2022
The provisions below supplement the information provided in the generally applicable portion of our Privacy Statement and apply solely to individuals that are residents of California and qualify as a “Consumer” under the CCPA. This California-specific Statement provides additional information about how we collect, use, disclose, and otherwise process the personal information of these individuals, either online or offline, within the scope of the CCPA. Any terms defined in the CCPA or as otherwise defined in our Privacy Statement have the same meaning as used in this addendum.
When we use the term “personal information” in this Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
A. CCPA personal information table
To help you understand how FastSpring uses your personal information, the below table summarizes:
Please see the generally applicable section of this Privacy Statement for additional information on FastSpring’s information practices, including more detail on how we use and disclose your personal information.
| Category of personal information | Collected? | Categories of sources | Commercial or business purpose | How we disclose your personal information |
| Identifiers, such as your name, address, phone number, email address, date of birth, or other similar identifiers | ✔ | Provided directly to FastSpringAutomatically collectedProvided to FastSpring by third parties | To assess your qualifications for employmentTo communicate with you during the recruitment process To improve our hiring and recruitment processFor legal and compliance-related purposesFor business purposes as needed during your employment with usTo provide employee benefits to you | WIth our third-party service providersWIth legal and other regulatory authorities |
| California Customer Records (Cal. Civ. Code § 1798.80(e)) | ✔ | Provided directly to FastSpringProvided to FastSpring by third parties | To assess your qualifications for employmentTo communicate with you during the recruitment processFor legal and compliance-related purposes | WIth our third-party service providersWith legal and other regulatory authorities |
| Protected Classification Characteristics | ✔ | Provided directly to FastSpring | For legal and compliance-related purposes | With our third-party service providers |
| Commercial Information | ❌ | N/A | N/A | N/A |
| Biometric Information | ❌ | N/A | N/A | N/A |
| Internet/Network Information | ✔ | Automatically collectedProvide to FastSpring by third parties; collected when you use any FastSpring systems, software or devices | To improve our hiring and recruitment processFor business operations purposes during your employment with us | With our third-party service providers |
| Geolocation Data | ❌ | N/A | N/A | N/A |
| Sensory Information | ❌ | N/A | N/A | N/A |
| Professona/Employment Information | ✔ | Provided directly to FastSpringPorivded to FastSpring by third parties | To assess your qualifications for employment | With our third-party service providers |
| Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99) | ✔ | Provided to directly to FastSpring | To assess your qualifications for employment | With our third-party service providers |
| Inferences | ✔ | Provided directly to FastSpringProivded to FastSpring by third parties | To assess your qualifications for employment | With our third-party service providers |
B. Categories of personal information sold
FastSpring does not “sell” personal information as most individuals would typically understand that term. However, please see our website privacy policy for additional information that we may collect and process personal information of visitors to our website and individuals who use our services.
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C. Description of rights available to Consumers
A number of individual rights are available to individuals under the CCPA relating to personal information that we have collected (subject to certain limitations at law), including:
Please note that your ability to invoke the rights above are limited pursuant to the scope and limitations of the CCPA, including any available exceptions. For example, an access request can only be made twice by a Consumer within a 12 month period.
D. How to invoke your rights
Individual rights requests can be submitted to FastSpring through the below channels:
Once an individual rights request has been submitted, FastSpring may ask you for additional information in order to verify your identity or to provide additional details to help us respond to your request. This may include your name, email address, phone number or other details related to your application. Where applicable, these requests can be submitted by an authorized agent through the channels described above in accordance with the applicable law. Please note that in certain circumstances, we may refuse to act or impose limitations on your rights, as permitted by the applicable law.
As noted above, we do not “sell” personal information as traditionally defined, but certain third-party advertising practices on our website may qualify as “sales” under the CCPA. To the extent applicable, an opt-out mechanism has been provided in the “Categories of personal information sold” section above. You may also exercise your right to opt out of any sales outside this scope by submitting a request using the channels described above. If applicable, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our systems. Once you make an opt-out request, you may change your mind and opt back in to future personal information sales at any time by contacting us at privacy@fastspring.com.
E. Updates to this Statement
We will update this Statement from time to time. When we make changes to this Statement, we will change the “Last updated” date at the beginning of this Statement. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Addendum B – European Union
Addendum for Individuals located within the European Union and the European Economic Area
Last updated: February 11, 2022
The provisions below supplement the information provided in the generally applicable portion of our Privacy Statement and apply solely to individuals that are residents of the European Union, the European Economic Area or are otherwise afforded rights pursuant to the General Data Protection Regulation (“GDPR”).
A. Data controller(s)
For the purposes of the processing pursuant to this Statement, the data controller(s) will include:
Fred. Roeskestraat 115
1076 EE Amsterdam
The Netherlands
801 Garden Street, Suite 300
Santa Barbara, CA 93101
United States of America
B. Legal basis for processing
We collect and process your personal information based on the following grounds:
C. International transfers
We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. In particular, we may transfer your personal information to the United States. We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented European Union controller-to-controller standard contractual clauses or other such safeguards for such purposes. To obtain a copy of these clauses or additional information on transfers, please address these requests to privacy@fastspring.com. Additional information is provided in the generally applicable portion of our Privacy Statement and apply solely to individuals that are residents of the European Union, the European Economic Area or are otherwise afforded rights pursuant to the General Data Protection Regulation (“GDPR”).
EU-U.S. Data Privacy Framework (EU-U.S. DPF) Compliance. FastSpring complies with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. FastSpring has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF program 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 and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission has jurisdiction over FastSpring’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.
As explained here we sometimes provide Personal Information to third parties to perform services on our behalf. If we transfer Personal Information received under the EU-U.S. DPF to a third party, the third party’s access, use, and disclosure of the Personal Information must also be in compliance with our EU-U.S. DPF obligations. Therefore, third parties that use our products explicitly agree to abide by the EU-U.S. DPF or otherwise agree to execute the Standard Contractual Clauses issued by the European Commission for the purposes of transferring Personal Information from the EU to non-adequate countries outside the EU.
Where the EU-U.S. DPF is not applicable, FastSpring executes the Standard Contractual Clauses for the purposes of lawful transfer of personal data as set out in European Commission Decision (EU) 2021/914 of 4 June 2021, as well as the UK International Data Transfer Addendum to the EU Standard Contractual Clauses as issued by the UK Information Commissioner under S119A(1) Data Protection Act 2018 (as applicable to any transfers from the UK to non-adequate third countries).
D. Sensitive personal information
FastSpring collects sensitive personal information as part of the recruitment and employment processes where required under the applicable law or pursuant to local requirements. Where permitted under the applicable law, we may also collect sensitive personal information if you elect to provide it where we have a legitimate interest in collecting the information.
E. Choice and access
If you are located in the European Union, you have additional rights in relation to how your personal information is processed, including the right to:
Please note that if you choose to withdraw your consent, you may not be able to participate in or benefit from the programs, services and initiatives for which you provided consent to the processing of your personal information.
You may exercise these rights free of charge by submitting your request help@fastspring.com. However, subject to the applicable law, FastSpring may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, FastSpring may refuse to act or impose limitations on the information disclosed if, for instance, the disclosure is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, or interfere with pending or future litigation.
You also have the right to lodge a complaint about our processing of your personal information with a Supervisory Authority in the Member State of your habitual residence, place of work or place of the alleged infringement.