Privacy policy

Last updated: November 6, 2024

Assembled Inc. (“Assembled”, “we”, or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information in connection with our website, www.assembled.com (the “Site”), and our products, services, applications, and other functionality offered on or through the online services (collectively, the “Services”), and when you attend an Assembled event or otherwise interact with us. This Privacy Policy also applies to individuals registered on our Services (“Users”), including Users who are provisioned an account by our enterprise customers (“Customers”). Please read this Policy carefully to understand how we may collect, use, and disclose your information, and what choices you may have with respect to your information. This Privacy Policy does not address our privacy practices relating to Assembled employees and other personnel. This Privacy Policy is not a contract and does not create any legal rights or obligations.

When our Customers use our Services to submit, manage, or otherwise use content relating to our Customers’ data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective Customer, who is the “data controller”. This Privacy Policy does not apply to such processing and we recommend you read the privacy notice of the respective customer if their processing concerns your Personal Data.

What is Personal Data?

When we use the term “Personal Data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Information we collect from you and why

Sometimes we collect Personal Data automatically when you interact with our Services and sometimes we collect Personal Data directly from you. At times, we may collect Personal Data about you from other sources and third parties (e.g., GSuite, Zendesk, etc.), even before our first direct interaction.

Personal Data Collected from Site Visitors and Account Holders
We collect the following Personal Data submitted to us by visitors to our Site and account holders:

Account Information: When you register as an Assembled User, we may request you to provide Personal Data such as your name and email address. We also collect information, including Personal Data, that you submit to or provide on the Services. If your account is related to any of our Customers’ accounts, the Customers’ administrators (“Admins”) may also direct us to collect your work availability and other information. We use your Personal Data to provide the Services to you and our Customers and to respond to your inquiries.
Inquiry Information: If you express interest in obtaining information about our Services or in signing up for an event or webinar, provide our business partner with your information, or download certain content, we may require you to provide us with Personal Data such as your name, email address, address, phone number, title, company name, and other information. We use this information to provide you with promotional materials, such as Assembled newsletters, marketing, or other information that may be of interest to you. If you decide that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in the communications or the instructions provided in the “Your Choices” section below.
Survey Information: We may collect information from you in surveys that we may conduct in order to improve the Services.
Payment Information: We may accept financial and billing information in order to process your payment for use of the Services.
Employment Application Information: We may collect information you provide to us in connection with applying for a position through our Careers page, including your contact and demographic information, date of birth, photo, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
Contact and Other Information: We may collect your name, email address, mailing address, company, employer, phone number and communication preferences when you interact with the Services. We also collect any other information you choose to provide this information to us.

Personal Data Automatically Collected

As is true of most digital platforms, we and our third-party providers may also use (i) cookies or small data files that are stored on your computer or device and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect information, which may contain Personal Data, from your devices while you navigate our Services or interact with emails we sent to you.

When you use the Services, we may collect information about the devices you use to access the Services, including IP address, browser or device type, operating system, the website you visited before the Services, identifiers of your devices and location data (such as general geographic location based on the log data we or our third-party providers collect). We use this information to provide, improve, and protect the Services.
When you interact with our Services, we collect information about how you use the Services, including tracking Users’ activity in our Services. We use this information to provide and improve the Services, and to protect the Services. We may also provide our Customers’ Admins with this information.
Our third-party service providers may collect Personal Data from your device, browsing actions and site usage patterns automatically when visiting or interacting with our Services to provide, improve, protect, and promote our Services. For example, our Site uses Google Analytics, a web analytics service provided by Google LLC (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and nonadvertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.
We and our third-party providers may also utilize persistent cookies to save your username and password for future logins to the Services. We utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by visitors and Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Services. A tracking pixel is a unique identifier embedded in a website, online advertisement, or email. We use tracking pixels to understand how you interact with our websites and emails and they help us and our advertising service providers better promote our Services.
We also use HTML5 local storage objects (“HTML5 LSOs”) or Flash local storage objects (“Flash Cookies”) to store content information and preferences. Our Site does not respond to Do Not Track signals.

For more information on how to manage cookies and related data collection technologies, please see the “Your Choices” section below.

Personal Data from Third Parties

We also obtain Personal Data from third parties; which we often combine with Personal Data we collect either automatically or directly from you.We may receive the same categories of Personal Data as described above from the following third parties:

Our Customers: If you engage in our Services through any of our Customers, we may receive information from them such as name and contact information.
Social Media: When you interact with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
Service Providers: Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Data and often share some or all of this information with us.
Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Data we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual.
Third Parties Related to Employment Applications: If you apply for a job with Assembled, we may receive information from your current or past employers, background check providers, third-party social media platforms and other third parties we use to obtain information about job applicants.
Publicly Available Sources: We collect Personal Data about individuals that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from an individual directly. We use this information to contact individuals, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.‍
Google API Integrations: We may, from time to time, receive information from Google APIs, subject to user consent. For instance, if you elect to enable certain functions, Assembled may collect information from Google APIs. Assembled's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Information received from Google APIs is not shared with any third-party AI models.

Third Party Data Collection and Online Advertising

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider. Please see “Your Choices About Online Ads” below, to learn more about interest-based advertising.

Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies. We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Third Party Partners. We work with third-party service partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Site or Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On at https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

Your Choices

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Privacy Policy, Assembled will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to us as specified in the “Contacting Us” section below.

Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information”. Assembled will not use this information for a purpose other than the purpose for which it was originally collected or subsequently authorized by you unless Assembled has received your affirmative and explicit consent (opt-in).

You also have choices with respect to technologies we use to automatically collect information as described below:

Opt-Out Right. You have the right to opt-out of any the above uses of any Personal Information, at any time, by emailing: privacy@assembledhq.com.‍
Access to Your Device Information. You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your geolocation and to integrate with your other applications.‍
How to Control Your Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt-out of Services-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).‍
How to Control Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.‍
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@assembled.com. We may not be able to modify or delete your information in all circumstances.‍
Your Choices About Cookies: If you would prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Be aware that disabling cookies may negatively affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Services.

Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.To learn how to manage privacy and storage settings for Flash Cookies, please visit the Macromedia site. HTML5 LSOs can be managed using browser tools and settings.

Your Choices About Online Ads: We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.allaboutcookies.org. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

How We Use Information

We collect and use the Personal Data described above in order to:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions;
Manage our organization and its day-to-day operations;
Communicate with individuals, including via email, text message, social media and/or telephone calls;
Request individuals to complete surveys about our organization, organizations we partner with, and Services;
Market our Services to individuals, including through email, direct mail, text message, social media and telephone calls;
Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Site;
Facilitate customer benefits and services, including Customer support through our command center services;
Identify and analyze how individuals use our Services;
Conduct research and analytics on our Customer base and our Services;
Improve and customize our Services to address the needs and interests of our Customer base and other individuals we interact with;
Evaluate your candidacy for employment, communicate with you during the job application process, and facilitate the onboarding process;
Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
Help maintain the safety, security and integrity of our property and Services, technology assets and business;
Defend, protect or enforce our rights or applicable contracts and agreements;
Process a business transaction or reorganization;
Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
Comply with legal obligations.

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Data we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information provided at that time. We may aggregate or de-identify information submitted to or collected by use of the Services so that the information does not identify you. This Privacy Policy does not restrict our use or disclosure of aggregated or de-identified information that complies with applicable law.

Information Sharing and Disclosure

We disclose Personal Data in the following ways:

Customers and Other Users: If your User account was provisioned by a Customer, the Customer’s Admin may have access and control over the information associated with your account. The Customer may have its own policies governing access and use of information in your User account. Additionally, depending on the Customer’s settings and your choices, we will share certain information with other Users that are also part of the associated Customer’s account.
Service Providers: Assembled engages certain third-party service providers that perform business or operational services for us on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, marketing and advertising services, administrative services and employment application-related services.
Associated Third Party Services: You or your applicable Customer’s Admin may provide a third-party service with access to your information. The use of such information by a third-party service will be governed by the third-party service’s privacy policy.
Affiliates: We may share your information, including Personal Data, with Assembled’s affiliates to provide, improve, protect, and promote the Services, or communicate with you.
Other Businesses as Needed to Provide the Services: We may share Personal Data with third parties that an individual engages with through our Services or as needed to fulfill a request or transaction.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership.
Legal Obligations and Rights: We may disclose your information to third parties, such as legal advisors and law enforcement: (a) to comply with applicable law, regulation, legal process, or government request, (b) to protect the health and safety or us and others, or any person from death or serious bodily injury, (c) to detect, suppress or prevent fraud, abuse, or any security issue of Assembled or others, (d) to protect Assembled’s or its licensors’ rights, property, safety, or interest, including to enforce our agreements and policies, and (e) in connection with the establishment, exercise, or defence of legal claims.

Upon request, you are able to access your personal information that Assembled holds and are able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the your privacy in the case in question, or where the rights of persons other than you would be violated.

If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Please contact us at privacy@assembled.com to submit such a request.

For EU, UK, and Swiss Individuals: Notice for Personal Data Transfers to the United States

Assembled complies with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework for the collection, use, and disclosure of certain personally identifiable information that we receive in the U.S. from the European Union ("EU Personal Data"), the United Kingdom ("UK Personal Data"), and Switzerland (“Swiss Personal Data” and combined with EU, UK, and Swiss Personal Data, “Personal Data”).

Assembled has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Assembled has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of any personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF Principles, the Principles shall govern.To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Assembled recognizes that the EU, UK, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EU, UK and/or Switzerland. To provide adequate protection for all Personal Data regarding consumers, clients, suppliers, business partners, job applicants and employees received in the U.S., Assembled has elected to self-certify to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) administered by the U.S. Department of Commerce. Assembled adheres to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

Assembled is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Further, Assembled is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Assembled commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States. EU, UK, and Swiss individuals with inquiries or complaints should first contact Assembled by email at privacy@assembled.com or via post at:

2525 16th Street
Suite 310
San Francisco, CA 94103

Assembled has further committed to refer unresolved privacy complaints to an independent dispute resolution mechanism, BBB Data Privacy Framework Services, operated by BBB National Program. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your inquiry cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Home (dataprivacyframework.gov)

To review Assembled’s representation on the Data Privacy Framework List, see the U.S. Department of Commerce's Data Privacy Framework List located at https://www.dataprivacyframework.gov/s/participant-search.

Assembled remains responsible and liable under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Assembled proves that it is not responsible for the event giving rise to the damage.

Links to Third Party Websites or Services

Our Services may contain links to, or interoperate with, third-party services. When you click on a link to any other website or location, such as if you or one of our Customers provides a third-party service with access to information in your account, that third-party may then collect or access information from you or the associated Customer. The use of such information, including Personal Data, by the third-party service will be governed by the third-party service’s privacy policy. We have no control over, do not review, and cannot be responsible for, these third-party services. We encourage you to read the privacy policies of every website you visit and every third-party service you use.

Our Policy on Children

The Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Data from individuals under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any Personal Data either directly or by other means. If a child under the age of 13 has provided Personal Data to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Data from our systems. If Assembled becomes aware that a child under the age of 13 has submitted information to us, we will promptly delete the information. If you believe that we may have any information from a child under the age of 13, please contact us at privacy@assembled.com.

Modification of this Privacy Policy

Assembled may modify this Privacy Policy from time to time. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. If we make material changes to this Privacy Policy, we will notify individuals by email by prominent posting on our Services or through other appropriate communication channels. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the website.

Contacting Us

If you have questions about this Privacy Policy, please contact us privacy@assembled.com or at our mailing address below.

2525 16th Street
Suite 310
San Francisco, CA 94103