Privacy Policy

The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.

This policy applies to all products and services built and maintained by DTH Holdings, LLC.

Please carefully review our Terms of Use as they also contain information about how we protect your data. Any terms that are capitalized in this policy, but are not defined in the policy, have the meanings described in our Terms of Use.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity and Access

When you sign up to use Client CV Services, we typically ask for identifying information such as your name, email address, and a company name. That’s just so you can personalize your account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our Services, but we do not normally look at or access that picture. However, to ensure your compliance with our Terms of Use, we may view your picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing Information

When you pay for services within Client CV, we ask for your credit/debit card and billing information. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit/debit card is passed directly to our payment processor and doesn't ever go through our servers. We may store a record of the payment transaction, including the last 4 digits of the credit/debit card number and as-of billing address, for account history, invoicing, and billing support. We may store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit/debit card transactions, and to print on your invoices.

Geolocation Data

We may log access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.

We also may log full IP addresses used to sign up a product account. We keep this record forever because they are used to mitigate spammy signups.

Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses.

Website Interactions

When you browse all pages of our applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and can be tied to your geolocation. We currently use Google Analytics to gather and track this information.

Cookies

We use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support third-party analytics. Our third-party partners such as (but not limited to) Stripe and Cloudflare may also store cookies. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.

Voluntary correspondence

When you write Client CV with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide this data voluntarily, such as if you include a pronoun preference in your email signature when writing to our Support team.

We also do not collect any biometric data. You may be given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.

When we access or share your information

Our default practice is to not access your information. The only times we’ll ever access or share your info are:

To provide products or services you've requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. No Client CV human looks at your data for these purposes.

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our Services for a restricted purpose, we will report the incident to the appropriate authorities.

When required under applicable law.

DTH Holdings, LLC is a US company and all data infrastructure is located in the US.

• If US law enforcement authorities have s legally enforceably warrant, criminal or civil subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. In the event a government authority outside the US approaches Client CV with a request, our default stance is to refuse unless the US government compels us to comply through procedures outlined in a mutual legal assistance treaty or agreement. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
• Similarly, If Client CV receives a request to preserve data, we refuse unless compelled by either the US Federal Stored Communications Act, 18 U.S.C. Section 2703(f) or a properly served US subpoena for civil matters. In both of these situations, we have to comply. In these situations, we notify affected customers as soon as possible unless we are legally prohibited from doing so. We do not share preserved data unless absolutely required under the Stored Communications Act or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we destroy any preserved copies we made of customer data once the preservation period lapses.
• If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their account, please contact [email protected].

Finally, if DTH Holdings, LLC is acquired by or merged with another company, we’ll notify you well before any info about you becomes subject to a different privacy policy.

Location of Site and Data

Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

Your Rights With Respect to Your Information

At Client CV, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Client CV recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:

• Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
• Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
• Right to Correction. You have the right to request correction of your personal information.
• Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Client CV services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
• Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en to identify your specific authority or find out more about this right.
• Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
• Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
• Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
• Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
• Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our Services, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact us at [email protected]. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.

For all products, most data is not encrypted while live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.

When you delete data in your account

In our application, we give you the option to delete data. Anything you delete from your account will be permanently deleted from our system, outside of what has been stored in a database backup that is periodically deleted.

When transferring personal data from the EU

The GDPR requires that any data transferred out of the EU must be treated with the same level of protection as EU privacy laws grant. The privacy laws of the United States generally do not meet that requirement. Therefore, we provide a standard Data Processing Addendum (DPA) that is GDPR-compliant to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed.

EU-US and Swiss-US Privacy Shield policy

Privacy Shield is an agreement between certain European jurisdictions and the United States that allows for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary.

We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States

Client CV complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States, respectively. We’ve certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles take precedent. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Client CV is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.

The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:

• Individuals have the right to access their personal data and to update, correct, and/or amend information that is incomplete. Individuals also have the right to request erasure of personal information that has been processed in violation of the principles. Individuals wishing to exercise these rights may do so by by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at [email protected].
• We do not sell personal data nor do we permit it to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide individuals with opt-out or opt-in choice as appropriate.
• We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

Changes and Questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at [email protected] and we’ll be happy to answer them!

This Privacy Policy has been adapted from the Basecamp open-source policies / CC BY 4.0.