THESE WOLVES PRIVACY POLICY

Last Updated: July, 2024

these wolves respects the privacy of its users, visitors and other individuals that use these wolves (each, “user”or “you”). This Notice describes how these wolves LLC. (54 Milwaukee Avenue, Bethel, CT USA) (“these wolves”, “we”) processes personal data in connection with the use of these wolves and the Site, as controller (within the meaning of the EU General Data Protection Regulation (“GDPR”)), and explains our privacy practices. Please read this Policy carefully to understand how we use personal information in connection with the use of these wolves.

By accessing or using www.thesewolves.com, or any other related sites, applications, services and goods, or any other website operated by these wolves that links to this policy (each, the “Site”or“these wolves”), you acknowledge that you have read and understood this Policy and how we process your personal information. This Policy may change from time to time; any changes we make to this Policy will be posted on this Site, we will also take any other steps, to the extent required by applicable law, including notifying you about material changes. Changes to this Policy are effective as of the stated “Last Updated” date. We recommend that you check the Policy periodically for any updates or changes.

1. THE SHORT’ISH VERSION

Information We Collect.
You directly provide us with most of the information we collect: when you register to the Site, use it and complete forms, we collect the personal information provided by you. We also collect information about your communications with us and communication with other users. We also automatically collect other usage information, as well as information from publicly available sources and third party vendors, partners or affiliates. Read More.

How Do We Use the Information Collected?
We use personal information to provide, operate, develop and improve the these wolves service and the Site; to prevent fraud, secure the Site and our services and to ensure marketplace integrity; to promote, advertise and expand the these wolves marketplace and to measure, improve and personalize our marketing activities to maintain appropriate business records, to comply with applicable laws and with lawful requests by public authorities. Read More.

Sharing Personal Information with Third Parties.
We share personal information with third parties set forth in this policy, including service providers and law enforcement officials if necessary. Read More.

How Long Do We Keep Personal Information.
We will keep personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some cases we will retain personal information for longer periods of time. Read More.

Where We Store Personal Information.
Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions whose laws may differ from the jurisdiction in which you live. Read More.

Children.
Our Site is not intended for children under 18 years of age and we do not knowingly collect personal information from children under 18. Read More.

Cookies.
We use cookies and similar technologies (such as web beacons, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyze website performance and for marketing purposes. Read More.

Do Not Track (DNT).
Our Site does not respond to Do Not Track (DNT) signals. Read More.

Updating Personal Information.
We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. Read More.

Specific Provisions for EU Users.
Where we process personal data related to EU users, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws, as detailed below. Read More.

Specific Provisions for California Residents.
If you are a California resident, you are entitled to specific privacy rights as detailed below. Read More.

Security.
We implement various technical and organizational measures in order to maintain the security of the Site and your information and to prevent unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. Read More.

External Links.
The Site contains links to third party sites and if you link to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under our control and are not subject to this Policy. Read More.

Contact Us.
You can exercise your rights over your personal information by contacting us atprivacy@thesewolves.com. More details about the rights applicable to you are in the long version of the Policy. Read More.

The above are just the highlights.
We encourage you to read more about the information we collect, how we use and share it, understand the meaning of cookies (no, you can’t eat them) and more in the long version of our Policy below.

2. THE REALLY LONG VERSION 2.1 Information We Collect

2.1.1. Information You Provide.
When you register to the Site we ask you to provide certain personal information, including a valid email address, social accounts (Google, Linkedin, etc.) account log in details, username and name. We will also ask you to provide, or we will otherwise collect additional information when you use the Site, complete forms, register to our programs and answer surveys. This information includes your profile details (including your photo, education, profession and expertise, portfolio, notable clients, etc.), telephone number or other contact details, physical address or billing information, payment information, taxpayer information and forms, details about other social networks linked accounts, transactional information, ratings and feedback, and additional authentication information. We also collect information about or contained in your communications with us, as well as any of your posts on our forums.

2.1.2. Information We Collect Automatically.
We automatically collect information while you access, browse, view or otherwise use the Site. This means, we are aware of your usage of the Site, including transactions and communications with other users of the Site, your searches, the pages you visited, as well as other actions on Site. We also collect, use and record other information relating to your usage, including geo-location information, IP address, device and connection information, browser information, web-log information, cookie data and the pages you’ve viewed or engaged with before or after using the Site. For this purpose we use cookies and similar technologies, as further detailed below.

2.1.3. Information We Collect from Third Parties.
We collect information from publicly available sources and third party vendors, partners or affiliates, such as:

• Third party vendors who provide us data to supplement enrich the information we collect about you. For example, we receive fraud warnings from service providers for our fraud prevention and risk assessment efforts. We also receive information from enrichment service providers to enhance and personalize your experience as well as from analytics and marketing partners in order to manage and measure our campaigns.
  
• If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, LinkedIn), we receive certain information, such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  
• We also receive certain information about you, if you are invited to these wolves by another user. In such a case, we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with the terms of this Privacy Policy.
  
• We receive information from other partners when you provide your explicit consent to transfer the data.

We combine the personal information provided by you, with information we collect automatically or obtain from such third parties and use it for the purposes detailed in this policy.

2.2. How Do We Use the Information Collected?

2.1.1. We will use your personal information for the following purposes:

• To provide, operate, develop and improve the these wolves service and the Site. For example, we use personal information to establish and set up your account, verify or re-issue a password, verify your identity, log your activity, process payments and complete transactions, perform our obligations to you, enable your use of these wolves and communications with other users, create teams of a talent for projects, provide customer support and contact you from time to time with communication related to your account. We also use personal information to develop and improve our services, to understand and analyse our performance as well as your preferences and performance and to customize and personalize your experience (including by making project suggestions, ranking search results, etc.).
  
• To prevent fraud, secure the Site and our services and ensure marketplace integrity. For example, we use personal information to track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We may conduct certain behavioural analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to the these wolves marketplace, other users, our community, or third parties, automated processes may restrict or limit your ability to use these wolves. If you would like to challenge any such decision, please contact us at privacy@thesewolves.com.
  
• To promote, market and expand our services and to measure, improve and personalize our marketing activities.For example, we use personal information for the purpose of sending direct marketing messages (as detailed below) and other information based on your preferences, to organize and facilitate referral programs, contests, or other promotional activities or events. We also may use personal information to measure, improve and personalize our marketing activities and to identify new customers;
  
• To contact you. As requested by you, or as otherwise approved by you or permitted according to this Policy.
  
• To maintain appropriate business records, to comply with applicable laws and with lawful requests by public authorities.
  2.2.2 We will ask for your consent before using information for a purpose other than those set out in this Policy.
  2.2.3 Direct marketing:
  
• We use your personal information to send you direct marketing communications about our products, services or promotions from these wolves that may be of interest to you or our related services. This may be via email, post or targeted online advertisements.
  
• Our processing of your personal information for marketing purposes is based on our legitimate interest or on your consent or as otherwise permitted according to applicable laws. You have a right to prevent direct marketing of any form at any time - this can be exercised by following the opt-out link attached to each communication or by sending an email to privacy@thesewolves.com.
  
• We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you.

2.3 Sharing Personal Information with Third Parties

2.3.1 We share your personal information with third parties as detailed below:

• Data made public by you or shared with other users and Site visitors. Once you register, your username, country and additional profile information is made visible to other users of the Site. This information includes your photo, experience and portfolio and additional profile and usage information. Your information will also be shared with other users when you message or otherwise communicate with such users.
  We also offer you the opportunity to participate and post content publicly in forums, and on other similar features. Your username and profile, together with the content uploaded by you, may be publicly displayed when you use such features.
  Please note, when you publish your information and/or share your data with other users, you do so at your own risk. If you choose to share personal information with other users, including to talent providing you a service via these wolves, such personal information is shared with the other user as separate controllers. While we are committed to protecting your privacy, we cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards.
  
• With users with whom you transact. We share personal information to help facilitate interactions between users. Such sharing of information is limited in scope and will not include personal information which is not already available to the other user via the these wolves Marketplace;
  
• With service providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, fraud detection providers, CRM systems, forum hosting, community management services, data and cyber security services, web analytics and performance tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants). Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information;
  
• With social media partners. Our Site includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as Facebook, Google,and LinkedIn to promote these wolves. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies;
  
• For legal reasons. We will share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is necessary to comply with legal processes; when we believe it is necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of these wolves, our customers, or the public;
  
• With our corporate affiliates.We share personal information with these wolves’ corporate affiliates that are related by common control for the purpose of operating the Site, providing our services to you and for other purposes listed herein.
  
• In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of these wolves’ assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.

2.4 How Long Do We Keep Personal Information?

We apply a general rule of keeping personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some circumstances we will retain your personal information for longer periods of time. We will retain your information, including personal information for the following purposes:

2.4.1 as long as it is necessary and relevant for our operations e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge;

2.4.2 in relation to personal information from closed accounts, to comply with the applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law;

2.4.3 to comply with statutory or other obligations to which we are subject, in particular statutory retention periods which can result from; and

2.4.4 if and to the extent necessary, we need it to preserve evidence within the statutes of limitation.

2.5 Where We Store Your Personal Information

Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions whose laws may differ from the jurisdiction in which you live. There are also transfers of personal information from the European Economic Area (“EEA”) to countries not deemed to provide an adequate level of data protection from a European data protection perspective. For example, we transfer your personal information to the United States for which an adequacy decision by the European Commission does not exist. With regard to data transfers to such recipients outside of the EEA we provide safeguards, in particular, by way of entering into European Union (EU) standard contractual clauses as amended from time to time, and/or equivalent data transfer mechanism. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

2.6 Children

Our Site is not intended for children under 18 years of age. No one under age 18 should provide any personal information to or on the Site. We do not knowingly collect personal information from children under 18. Parents and guardians should at all times supervise their children's activities. If we learn we have collected or received personal information from a child under 13, we will delete that personal information. If you believe we might have any information from or about a child under 13, please contact us at privacy@thesewolves.com.

2.7 Cookies

We use cookies and similar technologies (such as web beacons, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyze website performance, and for marketing purposes, as further detailed below.

A cookie is a piece of information (text file) stored on your device. When you visit our site, we set our own cookies (called first-party cookies) to store information on your device, such as your language preferences or login information. We also use 3rd-party cookies, which are cookies set by our partners (such as Facebook, Linkedin, Google, etc.). The duration of a cookie depends on its function. “Session cookies” are only active during your online session, while “persistent cookies” will stay active on your device after closing your browser.

We use the following types of cookies:

2.7.1 Essential cookies. Cookies that are essential for our service to function. They are used to enable core functionality, such as authentication, security, connection stability, etc. You can always set your browser to block or alert you about these cookies, but this may affect how the website functions.

2.7.2 Analytics cookies. Cookies that help us know which pages are popular and how visitors move around the site. We use them to count visits, check traffic sources, and measure and improve the website’s performance.

2.7.3 Marketing Cookies. Certain 3rd-party service providers and advertising partners manage our advertising on other websites. Such 3rd parties use cookies through our site to provide you with advertising on other websites based on your interests and preferences.

Find more information about deleting or controlling cookies at www.aboutcookies.org. (Note that this website is a third-party website. Therefore, we cannot ensure its accuracy, completeness or availability).

It is also possible to set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. You can do this through the browser settings page of your the browser you use.The following links may assist you in managing your cookies settings, or you can use the 'help' option in your internet browser for more details:

Internet ExplorerGoogle ChromeFirefoxSafari (OS X)Safari (iOS)Android

You can prevent Google Analytics from collecting and using data about you by downloading and installing the browser plug-in availablehere. This creates an opt-out cookie that prevents the processing of your data. For more information about Google Analytics cookies, please see Google's help pages and privacy policy.

2.8 Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We do not honor browser requests not to be tracked online (known as “Do Not Track”), but our cookie policy below describes how you can opt out of receiving cookies.

2.9 Updating Personal Information

We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it - unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we will ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information, please contact privacy@thesewolves.com and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws.

You can review and change your personal information by logging into the Site and visiting your account profile page.

If you delete your User Generated Content (“UGC”), as defined in the these wolves Terms of Service, from the Site, copies of your UGC may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including UGC, is governed by our Terms of Service.

2.10 Specific Provisions for EU Users

2.10.1 This section of the Policy applies to you if you are in the EU.

• 2.10.2 Where relevant under applicable laws, all processing of your personal information will be justified by a "lawful ground" for processing. In the majority of cases, processing will be justified on the basis that:
  you have provided your consent for us to use your personal information for a specific purpose;
  
• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with our services or services which you have purchased);
  
• the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
  
• the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.

2.10.3 Under applicable EU regulation you have the following rights in respect of your personal information:

• to obtain information about how and on what basis your personal information is processed and to obtain a copy;
  
• to rectify inaccurate personal information;
  
• to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
  
• to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
  
• to object to decisions which are based solely on automated processing or profiling;
  
• where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
  
• to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

2.10.4 Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purpose.

2.10.5 In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.

2.10.6 Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

2.10.7 To exercise your rights please contact us, at one of the methods stated under the Section titled “Contact Us”.

2.10.8 We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

2.11 Specific Provisions for California Residents

2.11.1 This section of the Policy applies to you, if you are a California resident.

2.11.2 During the last twelve (12) months we have collected the following categories of personal information from:

• Information that you chose to upload or otherwise provided by you, which may include:
  Identifiers and personal information, such as name, postal addresses, online identifiers, email addresses, passport number or driving license number, social security number;
  
  • Characteristics of protected classifications, such as gender; facial image; audio, electronic or similar information;
    
  • Professional or employment-related information;
    
  • Education information;
    
  • Commercial information;
    
  • Audio or other sensory information.
    
• Information that we collect when you use the Site, including:
  
  • Identifiers and personal information, such as online identifiers, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions.
    
  • Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    
  • Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures.
    
  • Location information.
    
• Information that we collect or receive from third parties, such as service providers, advertisers, and third-party accounts, including:
  
  • Identifiers and personal information, such as name, postal addresses, online identifiers, demographic information, email addresses, online identifiers, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions;
    
  • Professional or employment-related information;
    
  • Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures; and
    
  • Location information
    
• Inferences drawn from any of the information identified above to create a profile about you.

2.11.3 We use the personal information that we collect or receive for the business purposes as described above under the Section titled “How Do We Use the Information Collected?”.

2.11.4 We may disclose the above-listed categories of personal information to third parties for business purposes as described above under the Section titled “Sharing Personal Information with Third Parties” in the Privacy Policy. In the preceding twelve (12) months, we have disclosed all the categories of personal information detailed above for business purposes.

2.11.5 We do not “sell” (as such term is defined in the CRPA) personal information.

2.11.6 You are entitled to the following specific rights under the CRPA in relation to personal information related to you:

• you have a right to request that we will disclose certain information to you about our collection and use of personal information related to you over the past 12 months. After verifying your request, we will disclose to you:
  The categories of personal information that we collect about you.
  
  • The categories of sources from which the personal information is collected.
    
  • The purposes for collecting, using, or selling that personal information.
    
  • The categories of personal information that we disclosed for a business purpose or sold, and the categories of third parties to whom we disclosed or sold that particular category of personal information.
    
  • The specific pieces of personal information that we have collected about you.
    
  • If we disclosed your personal information for a business purpose, the categories of personal information we have disclosed.
    
• You have a right to request that we delete personal information related to you that we collected from you under certain circumstances and exceptions.
  
• You also have a right not to be discriminated against for exercising your rights under the CRPA.
  
• You also have a right to submit your request via an authorized agent. Should you choose to do so, we may request proof of your authorization

2.11.7 To make such requests, we kindly ask that you to contact us at privacy@thesewolves.com.

We will verify your request using the information associated with your account, including email address. Government identification may also be required. A request for access can be made by you only twice within a 12-months period. Any disclosures that we provide will only cover the 12-months period preceding receipt of your request. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

2.12 Security

We implement various technical and organizational measures in order to maintain the security of the Site and your information and to prevent unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. In addition, we contractually ensure that any third party processing your personal information equally provide for confidentiality and integrity of your data in a secure way. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access. However, we do not guarantee the absolute protection and security of your personal information. Further information about our data security practices can be provided on request.

Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party. We encourage you to set strong passwords for your account and avoid providing us or anyone with any sensitive personal information.

2.13 External Links

Please note that the Site contains links to third party sites and if you navigate to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under our control and are not subject to this Policy. You should consult the privacy policies of each site you visit. This Policy applies solely to personal information collected by our Site. If you upload content, including personal information, to a social network and then tag the Site, your submission will be subject to that social network's terms of use and privacy policy. We do not have control over these terms of use and privacy policies and have not reviewed their adequacy. You should therefore review these before submitting any personal information.

2.14 Contact us

To exercise any of your rights in connection with your personal information, please contact us at privacy@thesewolves.com.

If you have any questions (or comments) concerning this Policy, please email our team at privacy@thesewolves.com, and we will make an effort to reply within a reasonable timeframe.