Privacy & Data Protection Policy
We, MoonBase Zero Ltd, are specialized in people and organizational analytics and provides the online analytics service as well as in talent matching and recruitment services.
Welcome, and thanks for using our Service platform and related products and services (the “Services”). You agree that by purchasing, signing up for, or otherwise using the Services, you are entering into a legal binding agreement (even if you are using Services on behalf of a company).
0. Our Services
Our Services are provided by MoonBase Zero Ltd, 71 Baggot Street Lower, D02 P593, Dublin, County Dublin, Ireland or EuroPro Inc., 109 East 17th Street, Suite 25, Cheyenne WY 82001, U.S.A. or one of its affiliates (together the “Service Providers”). we support our customers with online analytics services as well as in talent development and job placement services. Some services or service components may be provided by 3rd party providers.
Welcome, and thanks for using our Service platform and related products and services (the “Services”). You agree that by purchasing, signing up for, or otherwise using the Services, you are entering into a legal binding agreement (even if you are using our Services on behalf of a company).
The Services allow postiing your personal profiles, support your hiring campaigns or analysis requests to be served on our service infrastructure or software or enabled third parties (collectively, %22Service Infrastructure%22), e.g., websites, online portals and mobile applications.
Our registered users (“Members”) share their professional experience, may engage with other members and visitors, exchange knowledge and insights, learn and develop skills, and find business and career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”).
To provide our Services, we might use own software tools and solutions as well as solutions from other service providers. Any third-party service is provided under the Privacy and Data Protection Policies of the respective service provider and are not of the responsibility of us.
We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
Data Controllers and Contracting Parties
If you are in the “Designated Countries”, by MoonBase Zero Ltd Ireland will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.
If you are outside of the Designated Countries, EuroPro Inc, U.S. or one of its affiliates will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.
We carefully select the partners and service providers we work with. However, the third-party services that add to or compose our services may collect, use and share your personal data, which is subject to their respective Privacy Policies and other documents, as well as updates. An overview of the most relevant service providers can be found HERE.
1. Data We Collect
1.1. Data You Provide To Us
To create an account with us you need to provide data including your name, email address and/or phone number, and a password. If you register for a Premium Service, you will need to provide payment (e.g., credit card) and billing information.
You create your personal profile (a complete profile helps you get the most from our Services).
You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. Some Members may choose to complete a separate Talent profile. To use our Services you will also provide the results of our assessment and analytics tools. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
Providing and Uploading Information
We collect personal data from you when you provide or upload it to our Services, such as when you fill out a form, (e.g., with demographic data, provide references or work experience), respond to a survey, or submit a resume or fill out a job application on our Services.
1.2. Data From Others
1.2.1. Contact Information
We receive personal data (including contact information) about you when others nominate you as a reference.
We receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application data.
1.3. Service Use
We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.4. Cookies and Similar Technologies
1.5. Your Device and Location
When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get an connection request, we track whether you have acted on it and might send you reminders. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement and other policies from our Services.
1.7. Workplace and Organization Provided Information
When your organization (e.g., employer or organization) buys a premium Service for you to use or you become a sales or promotion partner, they or you give us data about you.
Others buying our Services for your use, such as your employer or your organization, provide us with personal data about you and your eligibility to use the Services that they purchase for use by their workers, partners, or alumni. For example, we will get contact information for “Company Page” administrators or sales agents and for authorizing users of our Premium Services, such as our recruiting, analytics or learning products.
1.8. Sites and Services of Others
We receive information about your visits and interaction with services provided by others when you log-in with us or visit others’ services that include some of our plugins (such as “Apply here”) or our ads, cookies or similar technologies.
2. How We Use Your Data
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make so that our Services (including ads) can be more relevant and useful to you and others.
Our Services help you connect with others, find and be found for career and business opportunities, get analytics results about you or for your clients, get training and be more productive.
Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. We will use your data to recommend jobs or mentees, show you and others relevant professional contacts (e.g., who work at a company, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.
2.1.2. People & Business Analytics
Our Services allow you to use our advanced business and people analytics services to identify characteristics associated with successful hires and create and business relationships and apply rigorous processes to evaluate entities for those characteristics. The result is a faster process and a more diverse set of hires and business relationships with an increased likelihood of success. If your settings allow, we scan messages to provide “bots” or similar tools that facilitate tasks such as scheduling meetings, drafting responses, summarizing messages or recommending next steps. We may use automated systems to conduct surveys to help analyzing personality traits and behavioral profiles through direct tool-based surveys or surveys send to persons that have been nominated by you. Once the respective hiring decision is made or the analysis has been finalized, we will automatically anonymize all results after a defined time. You may also request the deletion of your personal information at any time by sending an email to [email protected] Please be aware that this might have a negative impact on being considered for a career opportunity and progressing with a business opportunity.
2.2. Premium Services
Our premium Services help paying users to search for and contact Members through our Services, such as searching for and contacting job candidates, sales leads and co-workers, manage talent and to conduct personality and business analytics.
We sell premium Services that provide our customers and subscribers with customized-search functionality and tools (including psychological and business analytics tools) as part of our talent, analytics and match-making solutions. Customers can search,, compile and export limited information from your profile, such as skill profile, headline, professional experience, current title, and general location (e.g., Dublin), such as to manage offer career or business opportunities unless you opt-out. We do not provide contact information to customers – you will receive a message if a customer wants to contact you. The follow-up correspondence can be entertained through our services or outside our platform. The data stored about you by these customers is subject to the policies of those customers.
We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages.
We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.
We also enable communications between you and others through our Services, including for example invitations, groups and messages between connections.
We may serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.
We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:
• Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
• Member-provided information (e.g., profile, contact information, title and industry);
• Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
• Information from advertising partners, vendors and publishers ; and
• Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender; using your feed activity to infer your interests; or using device data to recognize you as a Member).
We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take a social action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the Services, that action may be mentioned with related ads.
We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads.
Info to Ad Providers
We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile).
However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.
2.6. Developing Services and Research
2.6.1. Service Development
We use data, including user feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.
2.6.2. Other Research
We seek to create economic opportunity for Members of the global workforce, business development and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends, such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.
Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
2.7. Customer Support
We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).
2.8. Insights That Do Not Identify You
We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.
2.9. Security and Investigations
We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members, Visitors or others.
3. How We Share Information
3.1. Our Services
Any data that you include on your profile and any analytics results (e.g., personality profile) you take on our Services will be seen by others, consistent with your settings.
Your profile is partly visible to all members and customers of our Services. Exceptions are your name and, your email address and phone number that will only be shared with your consent. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). As detailed in your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.
Communication and Messages
We let senders know when you act on their message, subject to your settings where applicable.
Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your job searches or personal messages.
Your employer may offer you access to our enterprise Services such as Recruiter, Analyst Account Manager, Learning or Campaign Manager. Your employer can review and manage your use of such enterprise Services.
Depending on the enterprise Service, before you use such Service, we will ask for permission to share with your employer relevant data from your profile or use of our non-enterprise Services. We understand that certain activities such as performance analytics and personal messages are sensitive, and so we do not share those with your employer unless you choose to share it with them through our Services (for example, by applying for a new position in the same company or mentioning your job hunting in a message to a co-worker through our Services).
Subject to your settings, when you use workplace tools and services (e.g., interactive employee directory tools) certain of your data may also be made available to your employer or be connected with information we receive from your employer to enable these tools and services.
3.2. Communication Archival
Some Members (or their employers) need, for legal or professional compliance, to archive their communications, and will use services of others to provide these archival services. We cannot archive messages by and to those Members outside of our Services.
3.3. Related Services
3.4. Service Providers
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
3.5. Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of us, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. To learn more see our Data Request Guidelines and Transparency Report.
3.6. Change in Control or Sale
4. Your Choices & Obligations
4.1. Data Retention
We keep most of your personal data for as long as your account is open, or, if you are not a Member, a defined time after a job campaign or analytics task has been completed.
If you are an employee of a customer that uses one of our Services and your personal data will be collected in the process of an analytics service request, we will keep your data as long as your employer requests it or has a valid user account with us. However, you can request a copy of the stored personal data or request the deletion (anonymizing) of your personal data through your employer or directly from us by sending a message to [email protected]
We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases, we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.
4.2. Rights to Access and Control Your Personal Data
We provide many choices about the collection, use and sharing of your personal data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.
For personal data that we have about you, you can:
Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you). The deletion will be performed through anonymizing all personal data (e.g. by replacing your name, address, and contact information with a randomized set of characters or numbers). This step cannot be reversed, and your personal data cannot be restored. This usually also leads to a deletion of your account.
Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine-readable form.
You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.
Residents in the Designated Countries and other regions may have additional rights under their laws, which we will respect.
4.3. Account Closure
If you choose to close your account with us, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Professional Community Policies), enforce our User Agreement, or fulfill your request to %22unsubscribe%22 from further messages from us. We will retain de-personalized information after your account has been closed.
Information you have shared with others will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
5. Other Important Information
We monitor for and try to prevent security breaches. Please use the security features available through our Services.
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
5.2. Cross-Border Data Transfers
We may process data both inside and outside of the United States or Europe and rely on legally provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.
5.3. Lawful Bases for Processing
At any time, you can withdraw consent you have provided by going to settings.
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested) and “legitimate interests.”
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer by sending a message to [email protected]
5.4. Direct Marketing and Do Not Track Signals
We currently do not share personal data with third parties for their direct marketing purposes without your permission. Learn more about this and about our response to “do not track” signals.
5.5. Contact Information
If you have questions or complaints regarding this Policy, please first contact us online. You can also reach us by physical mail. If contacting us does not resolve your complaint, you have more options. Residents in the Designated Countries and other regions may also have the right to contact our Data Protection Officer by sending a message to [email protected] If this does not resolve your complaint, Residents in the Designated Countries and other regions may have more options under their laws.
6. How To Contact Us
For general inquiries, you may contact us online. For legal notices or service of process, you may write us at these addresses:
MoonBase Zero Ltd, 71 Baggot Street Lower, D02 P593, Dublin, County Dublin, Ireland
EuroPro Inc., 109 East 17th Street, Suite 25, Cheyenne Wy 82001, U.S.A.
Valid from: 19th July 2021
California Consumer Privacy Act
Notice for California Consumers
This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses like us, that receive information from more than fifty thousand California consumers, to provide certain information to them.
This notice contains the following four parts:
• We Do Not Sell Your Personal Information
• Your CCPA Rights
• The CCPA Categories of Personal Information We Collect and the Sources
• The CCPA Categories of Personal Information We Share for a “Business Purpose”
1. We Do Not Sell Your Personal Information
The CCPA requires us to disclose whether we sell your personal information. We do not sell your personal information.
2. Your Rights Under the CCPA
The CCPA provides Californians with the following rights:
2.1 Requests for Information
Like all of our members, you (or your authorized agent) can request a copy of your personal information by sending an email to [email protected] Under the CCPA, you can also request that we disclose how we have collected, used, and shared your personal information over the past 12 months, including the categories of personal information we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so. Companies that sell personal information (we do not) must make additional disclosures.
If you are not an member, you can submit your request by sending an email to [email protected]
2.2 Your Right to Opt Out of Sales
We do not sell personal information, so we don’t have an opt out.
2.3 Your Right to Notification
Under the CCPA, a company like us cannot collect new categories of personal information or use them for materially different purposes without first notifying you.
2.4 Nondiscrimination for exercising your CCPA Rights
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.
2.5 Your Right to Delete Personal Information
Like all of our members, you can request that we delete your personal information by closing your account with us. You also can request that we delete specific information. We honor such requests, unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
3. The CCPA Categories of Personal Information We Collect and the Sources
CCPA Personal Information Category
Sources of this Information
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
Vendors that provide information to help us serve members relevant ads and understand the ads’ effectiveness
Information from other members or customers
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”)
Information you provide to us directly and inferences we make based on that information
Information from our customers
Commercial information (e.g., information regarding products or services purchased, obtained, or considered)
Information you provide to us directly, such as to buy a Premium service
Your interactions with our Services
Information from our partners and customers
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)
Your interactions with our Services
Your visits to third party sites that offer our autofill, follow or “Apply Now” functionality, as needed for fraud prevention and security purposes.
If you are a member, your interactions with the services of partners and customers that use our BrandTag or similar technologies
Professional or Employment-Related Information
Information you provide to us directly Information from our customers, partners, or from other members (e.g., if a connection endorses you)
Information you provide to us directly or through your interactions with our Services Information from our customers and partners
Personal information described in Cal. Civ. Code §1798.80(e) (such as name, address, telephone number, education, employment history, credit card or debit card number)
Information you provide directly or through your interactions with our Services Information from our customers or partners
Audio, electronic, visual or similar information
Information you provide directly or through your interactions with our Services, customers or partners
4. The CCPA Categories of Personal Information We Share for a “Business Purpose”
4.1 Auditing Interactions
We may share the types of personal information listed in Section 3 with partners, service providers and related companies, in order to audit interactions and transactions, such as to count or verify the positioning and quality of ad impressions.
4.2 Security Purposes
In order to secure our Services, including to detect, prevent and investigate security incidents or violations of our Professional Community Policies or applicable laws, we may share the types of personal information listed in Section 3 with our partners, service providers, law enforcement and related companies.
4.3 Service Improvements
In order to improve our Services (such as to identify bugs, repair errors or ensure that services function as intended) or conduct internal research and analysis to improve our technology, we may share the types of personal information listed in Section 3 with our partners, service providers and related companies.
4.4 Service Providers and Other Notified Purposes
We may share the types of personal information listed in Section 3 with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).
Last modified: 20 May 2020