Privacy Policy US

Maxi 15, Sep 2022 27 min

Lionstep Inc. (“Lionstep” or “we”) cares deeply about the privacy of its users and would like to share the steps it takes to protect your personal information in compliance with applicable data privacy laws and best practices.  The below policy describes: (1) what information may be collected; (2) how such information may be used; and (3) your rights as a visitor or user of this website or our application regarding such information.  Lionstep uses this information to deliver the services it offers, to inform you of changes to said services or your account, to enhance our services, to prevent illegal or potentially prohibited conduct, and to enforce our Terms of Use (both for customers and candidates,) which incorporates this Privacy Policy by reference.

Before you access or use any of our services we encourage you to read this entire Privacy Policy. A short summary follows:

  • We collect information related to your use of the services;
  • Such information is used to provide and improve our services;
  • You have the right to request the deletion of your personal information and any information you have uploaded at any time and for any reason by contacting privacy@lionstep.com.

We take your privacy very seriously and we work hard to earn and keep your trust.  As such, we adhere to the following basic principles to protect your privacy:

  • We do not rent or sell your personally identifiable information to third parties for marketing purposes;
  • We do not share your contact information without your consent;
  • Any personally identifiable information you provide will be secured with industry standard protocols and technology;
  • Information we collect will only be store for so long as we need it to provide you with the services or to comply with applicable law.

1.         Please Read the Whole Policy

The Privacy Policy governs Lionstep’s information management policies, including how Lionstep gathers, stores or shares your information, if at all.  Notwithstanding anything to the contrary, this Privacy Policy does not apply to information that is gathered or collected offline unless it is added to your online profile as described in Section 3. By using the website (“Website) and app (“App”) (collectively “Site”) and sharing information with Lionstep, you agree to the practices described herein and to any other applicable terms, including the Terms (both for Customers and Candidates.) This Privacy Policy is intended to provide you with a clear explanation of how, when, and why we collect and use your personal information, as well as an explanation of your legal rights.  Nothing in this policy is intended to override the terms of any contract you have with us or any rights you have under any applicable data privacy laws

Please be sure to read the entire policy and make sure you fully understand our practices before using our services. If you do not agree with our practices you must immediately leave the Site.  If you have questions after reading this policy please contact: privacy@lionstep.com

From time to time, we may develop new or offer additional services or we might change or extend the list of partners that we use to store and process personal data.  If the introduction of services results in any materials changes in the way we collect or process your information we will provide you with more information and update this policy.

2.         What Information Is Collected?

 

We collect two types of information from visitors and users.  The first, unidentified and non-identifiable information (“Anonymous Information”) does not enable Lionstep to identify the visitor or user from whom it was collected. The Anonymous Information collected by Lionstep may consist of your IP address, the URLs visited, the date, time, length and non-precise geo-location of your visit, the operating system and browser used, and the amount of data transferred. This Anonymous Information is used to make the Site run, to analyze, store, and evaluate user behavior anonymously and to continuously improve and develop our Site. For further details on the systems used in this process, please refer to the sections on cookies and social media, below.

The second type of information we collect is individually identifiable information, meaning information that can identify an individual or may, with reasonable efforts, lead to the identification of an individual (“PII”).  PII collected by Lionstep consists of contact details provided by users when creating a user account (“User Account”) (e-mail address, full name, profile information and descriptive elements), correspondence through the Site, and any other PII provided directly by users and visitors to the Site.  Third party processors are listed below in Section 6 and 8. If any Anonymous Information is linked to PII, it is treated as PII as long as the connection exists.

You may review, amend, or delete any and all information associated with your User Account by emailing privacy@lionstep.com. You may also request the deactivation of your User Account and any uploaded content by sending an e-mail to privacy@lionstep.com. Use of data in general form in the provision of the website and creation of log files.

3.     Why Is Information Collected and When is it Shared?

We use the information we collect (both Anonymous Information and PII) to operate and improve the Site.  We do not share your PII with outside parties except to the extent necessary to operate our Site.

In the future, we may sell to, buy, merge with, or partner with other businesses. In such transactions, Anonymous Information and PII may be among the transferred assets.

We process PII only insofar as it is necessary for providing the Site and for the provision of the services we offer.  Users have the right to revoke consent at any time without giving reason and with no effect on future consent.

Lionstep also processes personal data for statistical and market analysis purposes. In this context, statistics are created and evaluated based on Anonymous Information only, for the following purposes (though not limited to these purposes): industry affiliations, locations, and market area of the website. Details on the personal data we collect are to be found in this Privacy Policy.

Additional data protection information may apply to special services (e.g. sending newsletters) for which you will be informed in writing before you use the respective service.

Candidates: Lionstep tracks which jobs you apply to solely to prevent individuals from applying to jobs multiple times. If you approve the sharing of your data, your PII will be shared with Customers whose jobs you have expressed interest in. You will be asked to approve each individual Customer. On the Site you have the option to create a profile to view job postings and participate in the application processes. For this purpose, you are required to provide the following data: name, surname, contact details (including email address and password, telephone number), postal address, photo, CV (including date of birth), current location (city), and other information relevant to the application (e.g. degree title, special knowledge and skills, professional experience, etc.). You may volunteer further data (such as educational transcripts, skills, employment history, and work samples). If you create a user profile with us via your LinkedIn account (log-in via LinkedIn), we collect the information you provide on LinkedIn and connect it to your user profile on Lionstep. Further, if you participate in a phone interview with Lionstep staff we may add notes from that interview to your file. We require the above-mentioned data to ensure that the user profile functions as intended and is assigned to you only. In addition, we can consider you for jobs on the basis of this data, therefore, it is required to access our services. The collection and processing of personal data in this context is justified by the Terms we have with you. If you do not provide us with this data it will be difficult or impossible to provide you with Job Opportunities and for Customers to reach out to you, if interested.

Should you wish to participate in application processes, the data collected for your profile (and any supplemental data you provide) will be disclosed to Lionstep customers who have published a job notice. The disclosure is necessary to enable contact between such customers and you.

Should you access a job posting published by us via a link within a social network (e.g. LinkedIn), we will collect and store the following information that you have made publicly available on the relevant social network: name, surname, referrer URL, employer and job title, retrieved job posting.

We collect this information to ensure that you do not apply for the same job more than once and that you are not contacted more than once in relation to the same job.

Customers: The details you provide in your job description will be shared with Candidates. On the Site you have the ability to create a profile to publish job advertisements and find suitable candidates. For this purpose, the following data is required: name, surname, company (for legal entities), contact details (including email address and password, telephone number), postal address, billing address, registration data, company and job descriptions. Further data may be provided on a voluntary basis. We require this data to ensure that the user profile functions as intended and can be assigned to you only. The collection and processing of personal data in this context is justified by the service contract and Terms we create with you. If you do not provide us with this data, we will be unable to create a user profile for you and provide our associated services.

Should you choose to activate suitable candidates for your job vacancy, the data collected for your profile will be disclosed to such candidates. The disclosure enables contact between employers and candidates.

All Users: When you contact Lionstep via the contact form on the Site, we collect the following personal data: name, email address, and phone number. Should you contact us via our live chat, we only collect information that you voluntarily provide to us via the chat window. We use collected data exclusively to respond to your inquiries. No further processing takes place. Should you not provide us with this data, we cannot process or respond to your request.

In order to constantly improve our services, we analyze the Anonymous Data collected from applications, enquiries, job advertisements, etc. The analyses are carried out for the purpose of business evaluations, marketing, and market research. We may take into account details of information about users, e.g. the services they have used. The analyses serve to increase our user-friendliness, the optimization of our offerings and business management. The analyses serve us alone and involve no external service providers. Only Anonymous Data based on aggregated values are disclosed to third parties.

Lionstep will not sell, license, rent, or otherwise disclose your PII except as stated herein, unless under the following circumstances: (1) you have affirmatively given your consent; (2) we previously notified you of the disclosure in this Privacy Policy or when you provided your information on the Site; (3) we are compelled by law, legal process, or court order to disclose; (4) disclosure is required to identify, contact, or bring legal action against someone who may cause harm to, or interference with, Lionstep’s rights or property, our users, or anyone else; or (5) to respond to an inquiry, request or complaint that you have made. Lionstep may cooperate with Internet service providers to identify users whenever required to comply with law, to enforce compliance with this Privacy Policy or our Terms, or to protect the Site, our customers and others.

4.         Where is Information Stored?

Lionstep works with state-of-the-art partners to establish and protect their data storage facilities.  We use industry standard technologies to safeguard your data (both Anonymous Data and PII) from unauthorized use and disclosure and to prohibit possible security breaches of the Site.  Unfortunately, no website, application, computer system or online communication is completely secure. Lionstep cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Site is at your own risk.

Lionstep will take commercially reasonable steps to use heightened security technologies to protect the transmission and storage of transactional information to the Site. Such heightened security measures may include the secure transmission and encryption of all supplied sensitive financial or other transaction-related information. Lionstep does not handle any such information directly but instead uses Stripe’s secure system. You can review Stripe’s privacy policy here.

Unless otherwise specified, whenever you make a payment, your financial and other transaction-related information will only be used to process your transaction and will not be stored on our servers or used for marketing purposes.

We store your IP address in the log files to the extent necessary for security purposes. We hash your IP address to anonymize your connection and/or device.

5.         Data Deletion

Upon written request Lionstep will provide you with information about whether we hold any of your PII. You may access, correct, or request deletion of your PII by emailing: privacy@lionstep.com. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.

Please note that permanently deleting your User Account erases all of your information from our system. After completing this process your User Account and all its data will be removed permanently, and we will not be able to restore your User Account or retrieve your data in the future.

PII note requested to be deleted is stored until the purpose of collection and storage no longer applies.

The processing of data stored on the basis of a statutory provision shall be restricted accordingly, i.e. the data shall no longer be processed for purposes other than for which it was collected. Data will also be blocked or deleted upon expiration of the storage period, unless there is a need to continue storing the data for the performance or conclusion of a contract.

6.         Use of Processors

In the performance of the services offered by Lionstep, we use external service providers who, among other things, also process your PII exclusively on our behalf. Our external service providers include but are not limited to: payment service providers, accounting service providers, newsletter delivery service providers, CRM service providers (including live chat providers, customer satisfaction, and customer support service providers), hosting service providers, and technical service providers (e.g. for troubleshooting or securing user consent). With all such processors, we have – if required by law – concluded agreements pursuant to Art. 28 GDPR on the processing of personal data on behalf users that protects your PII.  Notwithstanding such agreement, we encourage you to read their respective privacy policies and make your own decision.

7.         Transfer to third countries

Unless otherwise stated, all data processing operations take place within the EU or EEA countries where the Company’s primary business is located.

8. Cookie Policy

a) Description and scope of data processing

In order to make our Site function, we use so-called cookies or other tracking technologies (“trackers”) on various pages. Cookies are small text files that are stored on your terminal device. We use session cookies that are deleted at the end of the browser session, i.e. after you close your browser. Persistent cookies remain on your terminal device to enable us, or our partner companies, to recognize your browser upon a return visit.

You can set your browser so that you are informed about cookie settings and can determine individual acceptance or exclusion of cookies in certain cases, or in general. You can manually delete cookies from your terminal device at any time.

Should you reject cookies, the functionality of our website may be limited. Unless explicitly distinguished, the following refers to cookies and any other tracking technology.

With your consent only and in accordance with Art. 6 (1) a) GDPR, we use additional cookies that allow us to monitor and evaluate user behavior for market analysis purposes. These are third-party cookies that are used when you use our services. Please refer to the following sections for details. Unless otherwise stated, the transfer of your data to third parties in the USA, whose cookies are used via our website, takes place within the framework of the EU-USA Privacy Shield. However, there is currently no adequacy decision by the European Commission for the USA.

Unless explicitly stated otherwise, we use the following cookies and trackers only with your consent.

GOOGLE ANALYTICS

We work with “Google Analytics”. This is a web analysis service of Google Inc. The information generated by the Google Analytics cookie about your use of our Site is usually transmitted to a Google server in the USA and stored there.  IP anonymization has been activated on our Site so that the IP address of users is shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the unabbreviated IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Site. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data, by installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For further information on the handling of personal data by Google, please refer to Google’s privacy policy: https://policies.google.com/privacy?hl.

GOOGLE REMARKETING

Google Ads is an offering of Google Ireland Limited, a company incorporated and operated under the laws of Ireland, with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland [http://www.google.com].

As described above, we advertise our offer via Google Ads in the Google search results as well as on the websites of third parties. Insofar as you have given us your consent for this in accordance with Art. 6 (1) p. 1 lit. a GDPR, the so-called remarketing cookie is set by Google for this purpose when you visit our website, which automatically enables interest-based advertising by means of a pseudonymous cookie ID and on the basis of the pages you have visited. After the end of the purpose and the end of the use of Google Ads Remarketing by us, the data collected in this context will be deleted. Further data processing will only take place if you have consented to Google linking your web and app browsing history to your Google Account and using information from your Google Account to personalize ads you see on the web. In this case, if you are logged in to Google while visiting our Site, Google will use your data together with Google Analytics data to create and define targeting lists for cross-device remarketing. For this purpose, your personal data will be temporarily linked by Google with Google Analytics data in order to form target groups.

Insofar as information is transferred to Google servers in the USA and stored there, the American company Google LLC is certified under the EU-US Privacy Shield. A current certificate can be viewed here [https://www.privacyshield.gov/list]. Based on this agreement between the USA and the European Commission, the latter has determined an adequate level of data protection for companies certified under the Privacy Shield.

You can revoke your consent at any time with effect for the future by deactivating the remarketing cookie via this link [https://adssettings.google.com/authenticated?hl]. In addition, you can obtain information from the Digital Advertising Alliance [https://www.aboutads.info/] about the setting of cookies and make settings for this.

FACEBOOK PIXEL

Within our Site the “Facebook pixel” of the social network Facebook may be used, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), This cookie helps with the analysis, optimization and economic operation of our Site.

With the help of the Facebook pixel, it is possible for Facebook, on the one hand, to determine the visitors to our Site as a target group for the display of advertisements (“Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our Site or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (“Custom Audiences”). With the help of the Facebook pixel, we also ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook Pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our Site after clicking on a Facebook ad (“conversion”).

The processing of the data by Facebook takes place within the framework of Facebook’s data usage policy. Accordingly, general information on the display of Facebook ads, in Facebook’s data usage policy: https://www.facebook.com/policy. For specific information and details about the Facebook Pixel and how it works, see Facebook’s help section: https://www.facebook.com/business/help/651294705016616.

You can withdraw your consent to the Facebook Pixel collecting and using your data to display Facebook Ads. In addition, to set what types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions there for the settings of usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform independent, meaning that they are applied to all devices, such as desktop computers or mobile devices.

You can also opt out of the use of cookies for reach measurement and advertising purposes by visiting the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

FACEBOOK CUSTOM AUDIENCES RETARGETING

We also use the remarketing function “Custom Audiences” of Facebook Inc.. This allows users of the Site to be shown interest-based advertisements when visiting the social network Facebook or other websites that also use this procedure. In this way, we can show you advertising that is of interest to you in order to make our Site more interesting for you.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server. We have no influence on the scope and further use of the data collected by Facebook through the use of this tool. Facebook receives the information that you have accessed the corresponding web page of our website or clicked on an ad from us. If you are registered with a Facebook service, Facebook can assign the visit to your account. Even if you are not registered with Facebook or have not logged in, it is possible that the provider will learn and store your IP address and other identifying features.

Deactivation of the “Facebook Custom Audiences” function is possible via the settings in the cookie banner and for logged-in users at https://www.facebook.com/settings/?tab=ads#_.

HOTJAR

Hotjar is a service provided by Hotjar ltd, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta.

We use the services of Hotjar to better understand the needs of our users and to optimize the Site. With the help of these technologies, we get a better understanding of our users’ experiences (e.g. how much time users spend on which pages, which links they click on, what they like and what they don’t like, etc.) and this helps us to align our Site with our users’ feedback. Hotjar uses cookies and other technologies to collect information about our users’ behavior and their devices (in particular, device IP address (collected and stored anonymously only), screen size, device type (unique device identifiers), information about the browser used, location (country only), language preferred to view our website). This information is stored in a pseudonymized user profile. The information is neither used by these services nor by us to identify individual users or merged with other data about individual users. You can find further information in the respective data protection declarations: https://www.hotjar.com/legal/policies/privacy

You can also object to the storage of a user profile and information about your visit to our website by these services, as well as to the setting of tracking cookies on other websites, via this link: https://www.hotjar.com/policies/do-not-track/.

LINKEDIN

LinkedIn is a service of LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland. We use this service to analyze user behavior on our websites and thus to understand which content or offers are particularly popular. This enables us to continually improve our service and adapt it to the preferences of our users. When using our Site, a cookie or similar “code-snippet” from LinkedIn is stored on the user’s end device. This allows us to track the user’s interaction with our website and the content available there.

You can find further information in the respective data protection declarations of these providers:

https://www.linkedin.com/help/linkedin/answer/67595/linkedin-conversion-tracking-ubersicht?lang=de and https://www.linkedin.com/legal/privacy-policy

b) Duration of storage, possibility of objection and elimination

Cookies are stored on the user’s computer and transmitted by the user to our Site or to the aforementioned third parties. Therefore, you as a user have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. Should cookies be deactivated for our website, use of all website functions to their full extent may no longer be possible. Individual cookie storage and lifetimes can be found in the respective linked data protection declarations of the third-party providers.

Newsletter: We send newsletters, emails and other electronic notifications with promotional information (“newsletter”) only with the consent or legal permission of the recipient.

Once we have collected your email address as part of the purchase of our services, we may opt to send you email newsletters for offers similar to those services you have purchased from us unless you have opted out of receiving such newsletters.

You can opt out of or revoke your consent to receiving newsletters from us at any time without incurring any costs other than the transmission costs according to the basic rates (i.e. the costs of your Internet provider, for example). We will inform you about your right to opt out when collecting the email address and in the respective newsletter. We provide a link to cancel the newsletter at the end of each newsletter.

8.    Your Rights

If you are located in countries that fall under the scope of the European General Data Protection Regulation (“GDPR”), data protection laws give you rights with respect to your personal data, subject to exemptions provided by law. These rights include:

Right of access – you have the right to request information about the personal data we process or store.

Right to rectification – you have the right to request that we correct or complete inaccurate or incomplete data relating to you.

Right to erasure – you have the right to request that we erase your data in certain circumstances.

Right to restrict processing – you have the right to ask us to restrict the processing of your data in certain circumstances.

Right to object – you have the right to object to the processing of your personal data in certain circumstances.

Right to data portability – you have the right to request that we disclose or release your personal data to another data controller or to you in certain circumstances.

Your right of appeal – you maylodge a complaint with a data protection authority.

You have the right to object at any time, without giving reasons, to the processing of your personal data for the purpose of direct marketing; this also applies to profiling insofar as it is related to such direct marketing.

Should you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Lionstep strives to provide these rights to all visitors and users. Please email us at privacy@lionstep.com with any requests, questions, or concerns.

9.    Children and Privacy

This Site is NOT directed towards children under the age of 16. Lionstep recognizes the importance of maintaining the privacy of children, especially those under the age of 16. Lionstep is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. § 6501, et seq.

Except in limited circumstances allowed by COPPA, Lionstep does not and will not knowingly request, collect, store, maintain, or share any personally identifiable information of children under the age of 16, without first obtaining the consent of a legal guardian. In those limited instances, Lionstep will only collect reasonably necessary information, and Lionstep will not share with third parties any personally identifiable information of a child under the age of 16 without the explicit consent of a legal guardian, or as permitted by COPPA or other applicable law.

You may revoke your consent and request the removal of your child’s information at any time. If you are the legal guardian of a child under the age of 16 and discover that your child has submitted their personally identifiable information without securing your consent, Lionstep will use commercially reasonable efforts to remove this information. If at any point you wish to review, amend, or request the removal of your child’s information, please send an e-mail to privacy@lionstep.com and provide the name and account information for your child’s user account.

10. Changes to this privacy policy

Due to the dynamic development of the Internet, new technologies and possibilities are constantly evolving. To allow you to benefit from these opportunities and technologies, we reserve the right to change this policy in the future if or as we introduce new or additional services or change or expand existing services or service elements.

To the extent that the change to the data protection policy affects only the use of data in general terms and not the use of data in the context of a user profile, any new data protection policy will apply from the date it is updated on the Lionstep website.

A change to the policy that relates to the use of data already collected and stored for the purpose of sending newsletters will only be made if it is reasonable to do so. If and insofar as changes to the data protection declaration relate to the use of the data already collected and used for sending newsletters, we will notify you by email, on our website, or in another form. In said notification, we will inform you of your right to object and designate a period of objection. Should you do not object within the designated period, you will be deemed to have accepted the amended data protection policy.

11.       Notice to California Users

California Civil Code Section 1798.83 permits users who are California residents and who have provided with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, or how the Lionstep reviews and processes any request from you to amend your personal information, please contact us as privacy@lionstep.com.

12.       Contacting Us

If there are any questions regarding this Privacy Policy you may contact us using the information below.

Lionstep Inc.
Attn: Legal Department
privacy@lionstep.com

Last Modification: This Privacy Policy was last modified on 5.October, 2021.