Privacy Policy

Above Data, Inc. (“Above Data,” “we,” “us,” or “our”) is committed to addressing privacy issues and wants you to be familiar with how we may collect, use and disclose your Personal Information. This Website Privacy Policy (“Policy”) describes our practices in connection with Personal Information that we collect through our websites from which you are accessing this Policy (the “Website”) as well as through email messages that we may send to you that link to this Policy. “You” or “your” refers to a visitor to or user of our Website as well as job applicants and others who contact us about employment opportunities at Above Data. By providing Personal Information to us, you acknowledge that you understand and agree to this Policy.

This Policy applies only to Personal Information collected by or through our Website or other similar channels. It does not apply to Personal Information processed in connection with products and services we provide to enterprise customers (“Products”). To learn more about our privacy practices with respect to our Products, please see our Products Privacy Policy.

As a company focused on serving the needs of businesses, our Website is not directed to minors and we do not promote or market our Products to minors. Please see Section 10 below and our Terms of Service for additional information regarding use of our Website by minors.

If you are located in the European Union, please see additional information in our European Privacy Notice below. If you are a California resident, please see our Products Privacy Policy to learn more about your California privacy rights.

Above Data, Inc. is responsible for the processing of your Personal Information under this Policy. Please direct any questions regarding the processing of your Personal Information as indicated below under the “Contacting Us” section below.

1.    PERSONAL INFORMATION WE MAY COLLECT 

“Personal Information” means any information relating to an identified or identifiable individual. We may collect the following categories and specific elements of information that, alone or in combination, may be Personal Information depending on the applicable laws in your location:

Contact Information, such as: name, postal address, telephone number and email address.

Electronic Information, such as: IP address, cookie ID, hardware identifier, mobile identifiers, browser and device information for the device you used to access the Website and demographic information. Social Media Information, such as: social media URL, social media alias, social media profile data and other information depending on the social media platform.

If you choose to apply for job openings or otherwise contact us regarding employment opportunities, we may collect the following:

  • Contact Information, such as: name, mailing address, phone number and email address.

  • Employment Information, such as: prior employers and dates of employment.

  • Education Information, such as: education history, degrees earned and institutions attended.

  • Job Qualification Information, such as: resume, CV, educational transcripts and any information contained in or with such documentation.

  • Work Eligibility Information, such as: country of residence, visa and immigration status and citizenship.

  • Reference Information, such as: name and contact details of your references and information your references provide.

  • Compensation Information You Voluntarily Provide, such as: past compensation details and desired compensation details. Note that we do not request past compensation details and any and all such information is provided voluntarily at your election.

  • Social Media Information You Voluntarily Provide, such as: social media URL, social media alias, social media profile data and other information depending on the social media platform.

  • Background check information, subject to applicable law.

  • Sensitive Personal Information, such as: race, disability status and nationality that you provide voluntarily or which we collect on a non-mandatory basis in order to comply with applicable law.

In some instances, we may combine information above that is not identifiable with Personal Information. If we so combine information such that it is Personal Information, the combined Personal Information will be treated by us as Personal Information as long as it is so combined.

We may use a third-party payment service to process payments made through the Website. If you wish to make a payment through the Website, your Personal Information, including payment details, may additionally be collected by the third party, and not by us, and will be subject to such third party’s privacy policy and other terms, rather than this Policy or our Terms of Service. We have no control over, and are not responsible for, such third party’s collection, use, and disclosure of your Personal Information.

If you submit any Personal Information relating to other people to us or to our service providers, such as contact information of references provided in connection with a job application, you are responsible for providing any notices and obtaining any consents that may be necessary for us or our service providers to process such information, and you represent that you have the authority to do so and to permit us and our service providers to use such information in accordance with this Policy.

2.    SOURCES OF PERSONAL INFORMATION

We may collect or source Personal Information from the following categories of sources:

FROM YOU THROUGH THE WEBSITE: We may collect Personal Information directly or indirectly from you through the Website, e.g., when you sign up for a newsletter, create an account, otherwise use our Website, contact us through our communication channels, communicate with us through social media platforms, or interact with us at in-person at events or over the phone. Some information may be collected using cookies or other similar technologies. Please review the section below “Cookies And Other Technologies” for further information.

FROM OTHER SOURCES: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; marketing service and data providers; social media platforms; and from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.

3.    HOW WE MAY USE PERSONAL INFORMATION

We may use Personal Information for the following business and other purposes:

  • To respond to your inquiries.

  • To send administrative information to you, for example, information regarding the Website and Products we offer, and changes to our terms, conditions and policies.

  • To complete and fulfill your orders, for example, to process your payments, deliver your order to you, communicate with you regarding your order and provide you with related customer service and support.

  • To send you marketing communications that we believe may be of interest to you and otherwise for our marketing, advertising and promotion activities related to our Website.

  • To operate, maintain, secure and protect our Website.

  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Website and Products, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

  • To process your job application(s) or otherwise respond to you regarding employment inquiries.

  • To engage in other legitimate purposes as required or permitted by applicable law.

  • To comply with applicable laws and regulations.

4.    HOW WE MAY SHARE INFORMATION

Your Personal Information may be disclosed to the following categories of third parties:

  • To any affiliates and subsidiaries for the purposes described in this Policy.

  • To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure services, customer service, email delivery and other advertising and marketing services, auditing and other similar services.

  • To identify you to anyone to whom you send messages through the Website.

  • To otherwise share your Personal Information with your consent or pursuant to your instructions.

  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

  • To a competent authority in response to a request for information if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process, including to meet national security or law enforcement requirements.

  • To law enforcement officials, government authorities or other third parties as necessary to protect our or your rights, property or safety, or that of our business partners, or as otherwise required by applicable law, for example to investigate fraud.

  • In an aggregated and de-identified or anonymized form.

  • For other legitimate purposes permitted by applicable law.

5.    COOKIES AND OTHER TECHNOLOGIES 

Cookies are randomly-generated alphanumeric pieces of information that a website transfers to your computer used to browse a website. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, language preferences and other internet traffic data. Similar technologies may be used instead of or in conjunction with cookies, such as web beacons, which are small, non-recognizable pictures downloaded to your computer when a specific website is loaded.

We use information from cookies and similar technologies for the following purposes:

  • To help maintain the security of our Website.

  • To facilitate navigation, display information more effectively and to personalize your experience while using the Website, including recognizing you as a unique visitor (with a random alphanumeric identifier).

  • To conduct Website analytics to understand how users use our Website and improve the Website.

  • To assist your use of the Website.

  • To help us resolve questions and other inquiries regarding the Website.

  • To allow us to tailor content or advertisements to match your preferred interests.

  • To avoid showing you the same advertisements repeatedly.

  • To support sales and marketing activities such as campaign analytics and provide direct marketing communications to you if you have consented to receive such communications, where applicable.

TYPES OF COOKIES

Required Cookies: Required cookies are necessary for the operation, maintenance and/or security of our Website.

Functionality Cookies: These cookies collect information about how visitors use our Website, such as which pages visitors go to most often and if they receive error messages from web pages. As set forth above, we may use third parties to help us understand how visitors engage with our Website. This means that when you engage with our Website, your browser automatically sends certain information to these third parties. This includes, for example, the web address of the page you’re visiting and your IP address. These cookies additionally remember choices you make (such as your language or the region you are in) and provide enhanced or more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages you can customize.

Targeting and Advertising Cookies: These cookies are used to deliver advertising more relevant to you and your interests. They are also used to limit the number of times you see a certain advertisement as well as help measure the effectiveness of the advertising campaigns. They may be placed by third-party advertising networks with our permission. They remember that you have visited a website and may share this information with other organizations such as advertisers.

Two types of cookies may be used on our Websites: session cookies (which are temporary cookies that remain in the cookie file of your browser until you leave the site) and persistent cookies (which remain in the cookie file of your browser for longer, though the time period will depend on the lifetime of the specific cookie).

Disabling and Enabling Cookies

You can use your browser or device settings to review and erase or delete cookies at any time. Note that by disabling certain categories of cookies you may be prevented from accessing some features of our Websites, certain content or functionality may not be available, or the Websites may not operate correctly.

Depending on your location, you may also opt out of third-party cookies relating to behavioral advertising by visiting the following websites:

  • European Interactive Digital Adverting Alliance (EDAA): www.youronlinechoices.eu and http://www.edaa.eu/

  • Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/

  • Network Advertising Initiative (NAI): http://optout.networkadvertising.org

Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your browsing preferences and usage patterns. You may temporarily continue to see some tailored ads produced from ongoing advertising campaigns.

The above opt-out tools rely on the use of cookies, and to the extent your browser settings impact use of third-party cookies, the above tools may not operate correctly. The above tools also apply only to the browser on which they are exercised. If you want to apply these tools to multiple devices or multiple browsers, you must exercise these tools on each browser and/or device.

Do Not Track

There are different ways to prevent tracking of online activities. Some web browsers may allow you to enable a do-not-track feature that alerts the websites you visit that you do not want your online activities to be tracked. Our Website may not recognize or react in response to do-not-track signals. At present, no generally accepted standards exist on how companies must respond to do-not-track signals. In the event a final standard is established, we will assess and provide an appropriate response to these signals.

GOOGLE ANALYTICS AND OTHER GOOGLE SERVICES

We use Google Analytics to understand how users use our Website. To learn more about Google Analytics and its practices, please visit the Google Analytics web page or the Google Analytics “Safeguarding your data” web page. To learn about adjusting your Google Analytics cookie settings, please visit the Google Analytics browser privacy settings website.

The Website uses font files from Google Fonts and Adobe Fonts. To properly display the Website to you, servers where the font files are stored may receive personal information about you, including:

  • Information about your browser, network or device

  • Your IP address

SQUARESPACE ANALYTICS

We use Squarespace, our website analytics provider and hosting platform, to learn about Website traffic and activity. For more information regarding these analytics and cookies, please visit The cookies Squarespace uses.

  • Functional and required cookies are used by Squarespace, our hosting platform, to securely serve the Website to you.

  • Analytics and performance cookies are used on the Website, as described below, only when you acknowledge the cookie banner. We use analytics cookies to view site traffic, activity and other data.

6.    THIRD PARTY SERVICES

This Policy does not address, and we are not responsible for, the privacy, information, security, data protection or other practices of any third parties, including any third party operating any site or service that links to the Website. The inclusion of a link on the Website does not imply endorsement of the linked site or service by us or by our affiliates. We are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, including social media platforms, such as Facebook, Instagram, Twitter, Apple, Google, Microsoft or any other application developer, application provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations.

7.    SECURITY

We implement appropriate physical, technical and administrative measures designed to protect your Personal Information that we maintain within our organization against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

If we learn of and confirm the occurrence of a security incident leading to the misappropriation or accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal information transmitted, stored or otherwise processed on our systems that compromises the confidentiality, integrity or availability of your Personal Information, we may attempt to notify you electronically by posting a notice on our Website or by sending you an email or otherwise in accordance with applicable law.

8.    YOUR CHOICES

In this section, we describe the rights and choices available to you.

Choosing not to provide your Personal Information. You may choose not to provide Personal Information. If you choose not to provide Personal Information (or ask us to delete it), we may not be able to provide you with certain Website functionality or other services.  We will tell you what information you must provide to receive the service by designating it as required at the time of collection or through other appropriate means.

Opt out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected]. If you opt out of marketing communications, you may continue to receive service-related and other non-marketing emails.

Cookies & browser web storage and targeted online advertising.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Website and third party websites. If business partners collect information about your activities on or through the Website, they may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. For more details, see Section 5 above.

Do not track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

9.    RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by applicable law.

USE OF WEBSITES AND PRODUCTS BY MINORS

The Website is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Website. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our Website without appropriate consent, please notify us as set forth below so that we may immediately delete the information from our servers and make any other necessary corrections. Please see our Terms of Service for more information on use of our Website by individuals under 18.

10. CROSS-BORDER TRANSFER

The Website is controlled and operated by us from the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Website you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data privacy and data protection rules than those of your country. To the extent Personal Information is transferred to a recipient in a country that does not provide an adequate level of protection for Personal Information, we will take measures designed to adequately protect your Personal Information in accordance with applicable law.

11. SENSITIVE INFORMATION

Do not send us, directly or indirectly, any sensitive or special categories of Personal Information (e.g., social security numbers or other national identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Websites or otherwise. We do not require and do not request any sensitive or special categories of Personal Information in connection with our provision of the Website.

12. EU PRIVACY RIGHTS

To the extent that European Union (“EU”) data protection laws apply to the processing of your Personal Information, you may have certain choices and means and other rights with respect to the processing of your Personal Information, as outlined below.

To exercise these rights and controls, please contact [email protected].

  • Access: You have the right to access a copy of the Personal Information that we hold about you in machine-readable form.

  • Correction: You may correct some of your Personal Information if it is inaccurate or it needs to be updated.

  • Deletion: You may secure the deletion of some of your Personal Information, subject to certain legal obligations or exceptions.

  • Objections or Restrictions on use: You may object to our processing of some of your Personal Information or restrict or limit our use of some Personal Information about you.

  • Portability: If you wish to transfer your Personal Information to another data controller, you may ask us to do so, and we will send it directly to them to the extent feasible.

  • Withdrawal of consent: You may withdraw any consents you previously gave us.

Please note that some functionalities may not be available, or we may not be able to fulfill your request, depending on our legal obligations.

Certain other details regarding the processing of Personal Information that individuals located in the EU may be entitled to receive are contained in other provisions of this Policy.

As a security measure, we may need to request specific information from you to help us verify your identity and ensure your right to access your personal information (or to exercise any of your other rights). 

Personal Information collected on or about individuals located in the EU is collected on the following legal bases for processing

  • Necessary for Performance of a Contract: If we or our affiliates have entered into a contract with customers, partners, suppliers or other third parties, we may need to process your Personal Information.

  • Consent: Where you have provided your consent for us to engage in marketing activities with you, we may need to process your Personal Information.

  • Legitimate Interest: We may need to process your PersonalInformation where we have a legitimate interest in doing so, such as: (1) to communicate with you in response to your requests, questions, inquiries, and submissions; (2) to conduct advertising, marketing and promotional activities in connection with operating our business; (3) for research and development, security and optimization of our Products and Websites; and (4) to process a job application and communicate with you regarding your interest in employment with us.

  • Comply with Legal Obligations: Where we are required to comply with laws or legal obligations.

Note that we may process your Personal Information using more than one legal basis depending on the specific purpose for which we are using your personal information.

Your Personal Information will be hosted in the United States and will therefore be transferred and stored outside of the European Economic Area (“EEA”). For the purpose of applicable EU laws, such third countries (including the United States) may not offer the same level of data protection as your country of residence.  For further information about the safeguards used, please contact us as set forth below.

Should you wish to lodge a complaint with regards to how your Personal Information has been processed by us, you may contact your local supervisory or data protection authority. 

13. UPDATES TO THIS POLICY

We may update this Policy from time to time. If we believe that the changes are material, we will notify you by an appropriate means. The most current version of this Policy is located on this web page.

14. CONTACTING US

If you have any questions about this Policy, please contact us by email at [email protected]

October 2020 Update