Privacy Policy

This Privacy Policy describes how Ladders, Inc. (“Ladders,” “we” or “us”) collects, uses and discloses the information we collect about our users (“you”), when you use our website, including www.theladders.com, recruit.theladders.com and related pages (the “Site”) and the services available through the Site (the Site and our services, together are the “Services”), or when you otherwise interact with us, such as through our customer support channels or on social media.

This policy applies to personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. By using the Services, you consent to the information collection and use practices described in this Privacy Policy. Your use of the Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms & Conditions, including its applicable limitations on damages and the resolution of disputes. Please read this Privacy Policy to learn more about the ways in which we collect, use and share the information we collect about you.

• Information We Collect
• How We Use The Information We Collect
• Targeted Advertising and Analytics
• Disclosure of Personal Information
• User Reviews and User Generated Content
• How To Access and Update Your Personal Information
• Newsletters and Communications from Us
• Third Party Websites
• Additional Disclosures for Certain U.S. States
• Children
• Changes to this Privacy Policy
• Contact Us

Information We Collect

We may collect information about you directly from you and from third party sources, as well as automatically through your use of the Services.

Information We Collect Directly From You
We may collect information directly from you. For example, if you register for or use our Services, we may collect your name, email address, phone number, photograph, zip code, company name, current or past employers, dates of employment, employee referral information, income information, resumes, current salary, desired salary, desired job title, job location preferences, and any other information that you submit as part of your profile or that may be useful in helping us to match job seekers and employers; if you pay for our Services, we will work with a third-party payment processor to collect and process your payment information, including payment card number and billing address.

We will also collect any other information that you provide to us. This may include social networking links and media or news links or information about your contacts and connections if you share such information with us, such as to participate in a referral program or to list a reference. If you give a reference for someone else, we will collect information about that reference. If you participate in a survey or questionnaire, we will collect information about your answers and interaction with that survey or questionnaire. We will also collect the information that you provide to use when you request customer support or otherwise communicate with us. This may include your name, email address, telephone number, and any other information you choose to provide.

Information We Collect From Other Sources
We may also collect information about you from other sources, including recruiters and employers, publicly available information, social networking platforms, and other third parties.  You may be able to connect other social networking accounts (e.g., LinkedIn) with your Ladders account in order to share your contacts and connections with us.  If you do this, we will collect information about your contacts and connections (and any other information you grant us permission to access).  We will use this information as set forth below. You may also be able to log in to our Services through third party platforms (e.g., LinkedIn). If you connect to our Services through a third party platform, we will have access to certain information about you from that platform, such as email address, profile information and friends or contact list, in accordance with the authorization procedures determined by such platform.

In addition, we may collect information about you from a contact of yours or other Ladders users, such as when someone lists you as a reference or suggests you for a position.

Information We Collect Automatically
We automatically collect certain information about your interactions with us or the Services. We track clickstream data, viewing data, searches submitted through the Services, and other data to monitor utilization and to improve user experience.  We also automatically collect certain usage information through cookies, web beacons, log files, java script and other technologies, including: domain name; browser type and operating system; web pages viewed; link clicked; searches, including search terms; IP address; date and time stamp and the length of time using the Services; referring URL (of website that led you to our Site).  Generally, we use this information to help diagnose problems with our server, administer our Site, analyze trends, track users’ movement on our Site, gather broad demographic information for aggregate use in order for us to improve the Services, to deliver customized, personalized content, and to understand how users are interacting with our marketing communications. We also may track and use your location information to customize information that we provide to you, and to display targeted ads on the Services and on third party websites. Please see the Targeted Advertising and Analytics section below for more information about the cookies and other tracking technologies that we use, and the choices available to you.

Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are interested in certain services based on your browsing behavior.

How We Use The Information We Collect

As permitted by applicable law, we retain and use the information we collect about you for the following purposes:

• Provide the Services, Account Management, and Customer Support. To provide our Services to you, including to share information between and among job seekers, recruiters, and employers; to communicate with you about your use of our Services; to respond to your inquiries; to fulfill your requests; to authenticate users; to process payments; and for other customer service purposes.
• To Analyze and Improve the Services. To monitor and analyze trends, usage, and activities in connection with the Services and to improve our services (such as by suggesting resume revisions, helping with cover letters, and recommending jobs)  in order to improve the Services and respond to user desires and preferences.     
• Send Administrative Information. To send you technical notices, security alerts, support messages and other transactional or relationship messages.     
• Personalize Your Experience. To match users with potential employers; to tailor the content and information that we may send or display to you (such as by suggesting resume revisions, helping with cover letters, and recommending jobs); to offer location customization and personalized help and instructions; and to otherwise personalize your experiences while using the Services.
• Marketing and Promotional Communications. To send marketing and other promotional information, including information about jobs and third-party products and services in which we think you may be interested.
• Referrals. To make suggestions to you about your connections that may be potential referral candidates for open positions at your current place of employment or at other places; to allow you to refer others to positions at your employer; to communicate with you and other Ladders users about those referrals; and to allow you to reach out to potential references at a company to whom you wish to submit a job application.
• Targeted Advertising. To target advertisements to you on third party platforms and websites (for more information and to opt out, see Targeted Advertising and Analytics below).

• Meeting Legal Requirements. As necessary to comply with our legal obligations, resolve disputes, enforce our agreements (including this Privacy Policy and the Terms of Use), protect or defend our rights, investigate, prevent, or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the safety of any person.
• Business Operations. We may also use information in the normal course of our business, such as for accounting, reporting, evaluation, and internal auditing.
• Aggregate or De-identified Information. We may also use aggregate or de-identified information about users for other marketing, research and other purposes.

For our Canadian users, please note that we may transfer your personal information across provincial or national borders to fulfill any of the above purposes, including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions. The applicable laws in those jurisdictions might permit foreign governments, courts, law enforcement or regulatory agencies to access the information in those jurisdictions.  You may use the contact information provided below to obtain information about our policies and practices regarding our transfer of data or use of service providers outside of Canada, or to ask questions about the collection, use, disclosure      or storage of personal information outside of Canada.

Targeted Advertising and Analytics

We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile applications. These entities may use cookies, web beacons, SDKs, device identifiers and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser and mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to display targeted ads and personalized content to users within the Services, deliver advertisements targeted to your interests on other companies’ sites or mobile apps, and to analyze and track data, determine popularity of certain content, and better understand your activity to help us improve our Services, performance, and user experience. You can usually adjust your browser settings to remove or reject all or some browser cookies, and depending on where you reside, you can opt out of cookie-based ad targeting on our website by following the prompts at Your Privacy Choices. Your opt-out choices will be linked to your browser only; therefore you will need to renew your opt-out choice if you visit the Site from a new device or browser, or if you clear your browser’s cookies.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance by visiting www.aboutads.info/choices, or if you reside in Canada, by visiting http://youradchoices.ca/choices/.

Disclosure of Information

We may disclose the information we collect about you, including your personal information, as explained below. You can make certain profile information private by logging into your account and adjusting your profile visibility.

• Other Ladders Users. To provide our Services, we  disclose the information we collect from about you with other Ladders users, subject to your preferences. Please see the Recruiters, Employers, and Job Seekers section below for more information about these practices and your choices.
• Publicly Available Information. Ladders users have the option to create a public profile with their names, positions, work history, education, social media profiles, and other information. Please see the User Reviews and User Generated Content section below for more information about these practices and your choices.      
• Marketing and Advertising Partners. We may disclose personal information to third parties to expand the reach and effectiveness of our marketing campaigns and other third parties for their own marketing purposes. Depending on where you reside, you may opt out of these disclosures. For more information about how to opt out, see Opt Out of Sales, Sharing, and Targeted Advertising below.     
• Affiliates. We may share the information we collect about you with any current or future subsidiaries, affiliated companies, or other companies under common control and ownership.
• Service Providers. We may share the information we collect with our vendors, contractors, and service providers who perform functions on our behalf, such as payment processing, data hosting, and content recommendation (for example, AI-based providers help us improve resumes, cover letters, and similar content).
• Legal Process. We also may disclose the information we collect about you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
• To Protect Us and Others. We also may disclose the information we collect about you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms & Conditions or this Privacy Policy, or as evidence in litigation in which we are involved.
• Business Transfers. We may disclose the information we collect about you to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of all or part of our business or assets, a bankruptcy proceeding, or as part of any other similar business transfer.

Other Third-Party Services with Your Consent and at Your Direction. We share personal information with third parties when we have your consent or you intentionally direct us to do so. For example, if you sign up for third party email job alert services on our site, we will share your personal information with the third party to provide you with such services.     

De-identified Information. We may also share information that is not reasonably capable of being associated with you with other users to help them better understand the types of users applying for a certain job. For example, we may share that a user with a certain job title, educational history, years of experience, areas of expertise, and salary range has applied for a certain job with other job seekers. We process, maintain, and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Recruiters, Employers, and Job Seekers

As noted above, Ladders works by disclosing information you provide and that we collect from other sources to other Ladders users to help job seekers find new jobs and employers find potential applicants. For example, we may disclose job seeker information to recruiters and employers, who are believed by us to be legitimately seeking applicants for available positions.  If you elect to allow recruiters to contact you, we will disclose your phone number or email address to them and they will use that information to contact you through phone call, text, or email. We may also disclose the information submitted by you through the Apply4Me feature to potential employers through the Apply4Me feature, as directed by you.

Recruiters and employers may also share jobseeker information with others in connection with their search for candidates for available positions, and their use is not subject to this Privacy Policy.  We may share recruiter and employer information, including profile, posted content or job opportunity details, with jobseekers seeking job opportunities and other visitors of the Site. In addition, your profile may be indexed and displayed through third party public search engines, whose use of your information is not subject to this Privacy Policy, and your activity on the Services (e.g., searches, clicks, profile views, etc.) may be disclosed to jobseekers.  This privacy policy does not apply to, and we are not responsible for, the treatment of user information by other users.

Individual users can adjust their profile settings within their account, to limit how certain information is shared or to prevent recruiters from calling, texting, or emailing them. If you ever have any questions or concerns about how recruiters or employers are using your personal information on Ladders, please contact us at [email protected].

User Reviews and User Generated Content

In some instances we may select and post user reviews on the Services which may contain personal information such as the user’s name. We will obtain your consent to use your name, prior to posting the review.

You may also create a public profile that includes your name, title, job history, phone number, email address, photograph, or other information, or we may otherwise invite you to post content on our Site, including your comments, pictures, and any other information that you would like to be available to other users or recruiters on our Site. If you post such content, it will be available to recruiters and other users of the Site, and may also become public.  Ladders cannot control how third parties or other users use this information.

If you would like us to remove your profile, name, review or other content from our Site, you may contact us at [email protected]; please be sure to describe and identify the location of the content that you are referring to in your request. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time, and may be maintained by us as a part of our records.

How To Access, Update and Delete Your Personal Information

We give you access to and control over your personal information, regardless of where you live. If you live in certain jurisdictions, you may have legal rights with respect to your information, which you can exercise as outlined below.

Accessing Your Personal Information. By logging into your account, you can access much of your personal information. You may also email our Customer Support team at [email protected], and upon written request and authentication of identity, we may provide you with your other personal information under our control, information about the ways in which that information is being used and a description of the types of individuals and organizations to whom that information has been disclosed.  In some situations we may not be able to provide access to certain personal information.  This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor or attorney/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information. When an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

Editing and Deleting Data. By logging into your account, you can change and delete your personal information or cancel your account. You may also email our Customer Support team at [email protected] (to make a change) or [email protected] (to cancel). Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time, and we may maintain copies of this information as part of our business records as well.

Newsletters and Communications From Us

We may send newsletters or other promotional or informational emails to you. These emails may include promotions for our Services and the services of third parties. If you click on a link in an email promoting a third-party service, that link may take you to the third party’s website. Please see the Third Party Websites section below for more information. You may opt-out of such communications by following the opt-out instructions contained in the email, or by changing your Account Settings.  In your Account Settings, you may indicate from which distribution lists you would like to have your name removed. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Third Party Websites

Our Services and emails may contain links to other websites. Please note that when you click on one of these links, you are entering another website over which Ladders has no control and will bear no responsibility. Often these websites require you to enter your personal information as you apply for a job directly with the hiring company. We encourage you to read the privacy statements on all such websites as their policies may differ from ours.

Additional Disclosures for Individuals in Certain U.S. States

Certain U.S. states, including California, have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). If you are a resident of one of these states, this section applies to you.

Additional Disclose

Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices.  Below, we use two different tables to explain this same information in accordance with the State Laws. The tables describe our data practices now and over the past 12 months.

Collection, Use, and Disclosure of Personal Information for Business Purposes 

Category of Personal Information	Categories of Recipients	Use of Personal Information
Identifiers, such as name, email address, mailing address, phone number, and IP address	Service providers; recruiters; potential employers; other users if you choose to create a public profile; others with your consent or at your direction;	Provide the Services, account management, and customer support Analytics to improve the Services Send administrative information Personalize your experience Send marketing and promotional communications Facilitate referrals Meet legal requirements For our business operations
Commercial information, such as records of purchases and payment information	Service providers.
Electronic, visual, or similar information, such as photos	Service providers.
Internet or other electronic network activity information, such as log data, and information about the devices and computers you use to access the Services	Service providers.
Professional or employment-related information	Service providers; recruiters; potential employers; other users if you choose to create a public profile;
Education information	Service providers; recruiters; potential employers; other users if you choose to create a public profile;
Other information you provide, such as demographic information, responses to surveys, or messages to customer service	Service providers.
Inferences drawn from any of the above, including about the content or ads that may be of interest to you	Service providers.

Personal Information That We “Sell,” “Share,” Or Use For “Targeted Advertising”

As described in this Privacy Policy, we work with marketing and advertising partners who collect information through cookies and other tracking technologies so that they can help us promote our Services. We may also purchase information about potential employers and disclose that information to Ladders job seekers so that such job seekers may contact those potential employers. These activities may constitute “selling” or “sharing” your personal information or using it for “targeted advertising” under certain State Laws, and you may opt out by following the prompts at Your Privacy Choices.           

The categories of personal information we may have disclosed for purposes that may constitute “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Laws and the categories of recipients are set out in the table below:

Category of Personal Information	Categories of Recipients
Directly identifying information of individuals in their capacity as employers, including name, job title, professional email address, professional mailing address, and professional phone number.	Ladders users in their capacity as job seekers.
Identifiers (such as cookie IDs, IP address, and a hashed version of your email address or phone number)	Marketing and advertising networks and partners.
Commercial information (such as records of purchases)	Marketing and advertising networks and partners.
Internet or other electronic network activity information (such as information about your activity on the Site)	Marketing and advertising networks and partners.
Inferences drawn from your personal information to create a profile, including about the content or ads that may be of interest to you	Marketing and advertising networks and partners.

We do not sell the identifying information of job seekers who register for our Services. We do, however, disclose such information to Ladders users in accordance with your preferences, as described in the Recruiters, Employers, and Job Seekers section above. You can always adjust your account profile settings to limit how certain information is shared or to prevent recruiters from contacting you. We also share certain information that doesn’t identify you personally to promote our services, as described in the Advertising and Analytics section above and in the “Opt Out of Sales, Sharing, and Targeted Advertising” section below, which also provides information about how you can opt out of such disclosures.   

Other Details About Our Information Practices

• We collect personal information directly from you (for example, when you register for, use, or pay for our Services), from third-party sources such as recruiters and employers, and automatically when you access or use the Services, each described in more detail in the Information We Collect section above.
• We do not knowingly, collect, sell, or share personal information about consumers under the age of 16.
• We generally do not collect information that is considered “sensitive” under State Laws and we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. 
• We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this Privacy Policy.

Your Privacy Rights.

Opt Out of Sales, Sharing, and Targeted Advertising

Some of the activities described in the Targeted Advertising and Analytics section above may be considered “sales” or “sharing” of your personal information or use of your personal information for “targeted advertising” under the law that applies to you. In addition, we may share a hashed version of your email address (that does not identify you personally but can be used to show you ads on other websites, such as social media properties) with certain ad partners so that they can show you ads promoting Ladders and understand the effectiveness of those ads. You may opt out of these disclosures by following the prompts at Your Privacy Choices. Depending on where you reside, you can also opt out by visiting the Site with a legally-recognized universal choice signal enabled (such as the Global Privacy Control). Please note that depending on whether you are logged into your account with us, our processing of the signal may be limited to the specific browser or device that you are using. 

In addition to these advertising-related uses and disclosures, we may disclose identifiers of individuals in their capacity as employers, such as name, job title, professional email address, professional mailing address, and professional phone number, to Ladders users in their capacity as job seekers so that such job seekers may contact those potential employers. This may constitute “selling” personal information under applicable law. You can opt out of having your information disclosed for this purpose by filling out our web form.

Access, Correction, and Deletion

Depending on where you reside, you may have the right to (1) know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. You may exercise these rights by following the steps outlined in the How to Access, Update, and Delete Your Personal Information section above. In order to exercise these rights, you will need to verify your identity by clicking on a secure link sent to the email address we have on file for you, in order to protect your security and personal information. Note that even if we honor your request to delete your information, we may retain certain information as required or permitted by law.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

Appeals

If we deny your request, you may appeal our decision by contacting us at [email protected]. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.     

Authorized Agents

If we receive your request from an authorized agent we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us at [email protected].

Children

Our Services are not targeted to children under sixteen (16) years of age and we do not knowingly collect personal information from children under 16. If we discover that a child under 16 has provided us with personal information, we will promptly delete such personal information from our systems.

Changes to This Privacy Policy

This Privacy Policy is current as of the Updated Date set forth above. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the data at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you by sending an email to the email address you have provided in your account (if any), and by other means where appropriate.

Contact Us

If you have questions or concerns regarding this Privacy Policy, you should contact our privacy officer at [email protected] (jobseekers), [email protected] (recruiters) or at 244 Fifth Ave, Suite D100, New York, NY 10001, ATTN: Legal.