Pepelwerk, is a company that wants you to understand your role in maintaining control and visibility of information that you use online, or any other digital means, to describe, identify or contact your real self. It is also important to understand how pepelwerk will and can use the data you choose to provide to us when interacting with us, our customers, our business partners or our products or services.
About Pepelwerk and Our Approach Digital Data and Your Personalized Information.
About Pepelwerk.
Pepelwerk is a cloud software platform that individuals and organizations use to get, give and develop people for in-demand skills-based careers. This means pepelwerk customers—individuals representing themselves; and persons representing organizations (i.e. companies, schools, and governments)—use our software applications to develop the workforce.
Pepelwerk has a range of software applications and services which include People Hub or App (aka Artificial Intelligence Career Assistant), Work Hub, Guidance Hub and professional services that allow our customers to meet, match, plan, get reviews, feedback, recruit, hire, get hired, train/educate, enroll in education, coach, offer guidance, receive sponsorship, access grants or scholarships and market career centered information.
To learn more about Pepelwerk products, visit our Product page.
The Pepelwerk business model.
We operate a Software-as-a-Service (SaaS) business model and marketplace, which means that we sell the software as a service to customers based on subscriptions and various product offerings in the platform. Based on the customers’ requests and voluntary use of our platform, we will share information in our marketplace to our closed group of customers to monetize that data by providing introductions, products, job, or education opportunities. We do not sell our customers information to third-parties or data brokers. You, our customers and end users, control the data they input into our platform and services and choose which features and functions to use.
Community-Centered Data, Artificial Intelligence and Predictive Analytics
To provide you with shared actionable data about interests, availability, time, compensation and learning status we must leverage what we call, a community-centered data engine and artificial intelligence with predictive analytics. All visitors, users and customers contribute to the usefulness and validity of data and as such, we review accuracy intent and practicality of all personal digital data provided by you. We reserve the right to use de-identified data indefinitely to help all our visitors, users and customers plan for a better working and learning future to accomplish goals with less friction and cost. We also reserve the right to restrict use if any of our visitors, users or customers are found to use data that is not their own or that does not honestly and accurately represent their real selves.
Digital Identity versus Real Self
We want you to feel like you have flexibility in leveraging digital tools to create a distinction between your real self and your digital identity for the purposes of safety and reducing your exposure to digital fraud and other risks from overexposing your personal identifiable information online or through any other digital tool. Your real self includes your biometrics, legal name, your likeness/photo on government issued ID’s and your information that is associated with engaging in any form of communication with you. Your digital identity includes memes, characters, alternate names, samples of works that you produce not associated to a job, creative descriptions of yourself that are valid but not exact. This privacy policy covers, and your rights include personal information associated with your real-self and the combination of data that is used to identify your real-self.
What does this Privacy Statement cover?
Some data protection laws in various jurisdictions distinguish between “controllers” and “processors” of personal digital information when helping people understand privacy rights and responsibilities. We will use those concepts here.
A controller decides why and how to process personal information.
A processor only processes information on behalf of a controller based on the controller’s instruction; the processor does not make decisions about personal information.
Pepelwerk may be either a controller or a processor, depending on the scenario.
This Privacy Statement applies when pepelwerk is the data controller of your personal information (unless a different pepelwerk privacy statement is displayed when we collect your personal information), and explains how pepelwerk collects, uses, and shares your personal information for its own purposes. For example, this Privacy Statement covers when you:
- Visit a Pepelwerk website that links to this Privacy Statement
- Interact with Pepelwerk as a representative of a company that has (or is considering) a business relationship with Pepelwerk (e.g., you are our customer or our supplier)
- Create or use an account offered directly by Pepelwerk (as opposed to an account offered by our customers)
- Register for or attend a Pepelwerk marketing, learning, or training event or webinar
- Provide us with feedback about our products or services
- Receive a sales or marketing communication from us, including emails or telephone calls
This Privacy Statement does not cover how we process personal information on behalf of our customers as a processor, or unintentionally harmful use of other customers who are violating Code of Conduct or Terms of Use. Once customers agree to share data through various interactions provided by pepelwerk, the handling and use of that data is not the responsibility of pepelwerk.
Make sure that you do not share any information about your real self or your digital self that makes you uncomfortable at any time.
Privacy Statement.
How we collect and use your personal digital information.
Pepelwerk collects and uses digital personal information that users, visitors or customers provide to describe, or used to help pepelwerk make recommendations to you so you can describe, your real self, the organizations you represent or to complete activities available through the platform or services we provide. When we do so, we will use it in accordance with applicable laws.
Some jurisdictions, including the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland, require a legal basis—a reason why Pepelwerk is legally allowed to collect and use your personal information.
Below, we describe (1) in what instances we collect your information, (2) the categories of information we collect in those instances, (3) our purposes for collection, and (4) the legal bases for collection. If we need to collect other personal digital information from you, we will explain which information we need and why at the time we collect it.
Information provided by you.
Sometimes, we may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details to create an account with us, to complete activities in the platform or services, to subscribe to marketing communications from us, and/or to submit inquiries to us. In some cases, we combine the information you provide.
When you request information from us. When you fill out a contact form or otherwise contact us to express interest in obtaining information about Pepelwerk or our services, we may ask you to provide us with your contact information such as name, business and/or personal email, location you will access our products or services, telephone number, mobile number, company name, information about your job, personal goals, and physical address.
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests or your consent (where required by law) to:
- Fulfill your request and communicate with you
- Provide you with information about our products (including telemarketing calls and marketing emails, in accordance with your marketing preferences)
If you are our visitor, user, supplier, vendor, customer or prospective customer we collect legitimate information provided by you so we can communicate. This includes your digital name, your real person name, working verified email address, working verified telephone number, your physical location where you are conducting business, your digital location (aka IP address) where you are using products or services. If you represent an organization this includes the legal name of the organization, your role with the organization, your responsibilities, your work location, and the physical address of the company. We will also collect information about the reason for your inquiry and any other information you choose to provide to us.
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests or your consent (where required by law) to:
- Communicate with you and fulfill your request for information or support
- Manage your account, including payments and other account-related issues
- Provide you with information about our products, in accordance with your marketing preferences (including telemarketing calls and marketing emails, in accordance with your marketing preferences)
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests to:
- Manage your account, including payments and other account-related issues
- Communicate with you and respond to your inquiries
If you are an end user of a pepelwerk-owned account.
When you use a pepelwerk product sponsored by an organization or another Pepelwerk customer, your account is controlled and owned by that organization.
Purpose and Legal Basis Under Data Protection Law: We process your personal information to perform or enter contracts or terms of service with you, or if we do not have a contract directly with you, in reliance on our legitimate interests to:
- Manage your user account in accordance with the applicable terms of service
- Ensure that you can log in to use our services and access information you need securely and efficiently
- Deliver requested resources or services to you (including personalized interactions)
If you register for events and webinars. When you register for an event or webinar, we may ask you to provide us with your contact information such as your name, business email, telephone number, and company name; your health and safety information such as your emergency contact and your dietary preferences; and your billing information such as your billing name, billing address, and credit card number. If you use a Pepelwerk event-related mobile application, we may also collect additional information from your device, such as your photos, contacts, or geolocation data, in accordance with your device’s privacy settings.
Purpose and Legal Basis Under Data Protection Law: We process your personal information with your consent (where required by law), to perform or enter contracts or terms of service with you, or if we do not have a contract directly with you, in reliance on our legitimate interests to:
- Manage, plan, and host the event, including sending related communications
- Improve our future events and our mobile application
- Improve or enhance your (or your organization’s) experience interacting with Pepelwerk
- Provide you with information about our products (including telemarketing calls and marketing emails, in accordance with your marketing preferences)
If you participate in research with us or otherwise provide us with feedback. When you participate in or register for a pepelwerk study, survey, panel, or panel pool, or voluntarily submit certain information to us such as providing pepelwerk with feedback about our products and services, we may ask for certain biographical or demographic information, such as your name, email address, contact information, time zone, location, company, employment status, tenure, role, job information, gender, age group, and other information relevant to the study. For certain studies, we may also take photos, videos, or audio recordings (with your permission and in accordance with applicable laws).
Purpose and Legal Basis Under Data Protection Law: Where you have entered into a free or subscription service with us, we will process your personal information for the performance of such contract. If we do not have a contract directly with you, or otherwise obtain your consent, we rely on our legitimate interests to:
- Fulfill the purpose set out in the study or survey
- Improve your (or your organization’s) experience interacting with Pepelwerk
- Identify the Pepelwerk research studies best suited to you based on your attributes and invite you to participate via email
- Identify potential product improvements or future product developments for the workforce
- Contextualize your feedback and experience with our products and services so that we can improve them
- Improve how we conduct research
If you participate in a sales call, online meeting or product demo with Pepelwerk. We may record sales phone calls and online meetings (including audio and video content where applicable) for training, quality assurance, and administration purposes. This includes analyzing the content of such calls and online meetings using AI-powered tools to gain better insights into our interactions with our customers and prospects. We will always notify you before a call will be recorded and will obtain your consent where required by law. We also collect information about your interaction with product demos (such as demos you access, share, and view with others) to understand your product interests and provide you with more relevant information.
Purpose and Legal Basis Under Data Protection Law: We process your personal information with your consent where required under applicable law or in reliance on our legitimate interests to:
- Maintain high-quality sales calls, demos and engagements with prospects and customers
- Provide training and coaching to our sales teams
- Generate automated call transcripts
- Keep our records up to date (for example, in relation to follow-up meetings, sales opportunities, and updating customer contact details)
- Improve our sales processes and make our sales calls and product demos more impactful
Information collected automatically.
We also collect certain information related to your use of our websites. In some jurisdictions in the United States and countries in the EEA, the UK, and Switzerland, this information may be considered personal data under applicable data protection laws. We may combine this information with personal information provided by you.
In particular, we collect the following personal information from you automatically:
When you access our websites or content. When you visit our websites, we collect information about your device and your usage. The information collected may include your IP address, device type, unique device identification numbers, browser type, broad geographic location (for example, country or city-level location based on your public IP address), performance, and other usage and technical information. We also collect information about how you interact with our websites (for example, referring web page, pages visited, features used), emails, content, or other features (for example, when you open a marketing email or click on an embedded link, or if you watch videos on our site, or interact with/message using our chat function). Some of this information may be collected using cookies and similar tracking technology, as further explained in our Cookie Notice. We do not collect “sensitive personal information” as the term is defined by California law beyond what is necessary to provide your requested services. Accordingly, we do not provide a mechanism for you to request that we limit our use of sensitive personal information.
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests to:
- Better understand the visitors who come to our websites, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our websites to our visitors.
- Provide, operate, and maintain our websites, including providing access to content you have requested and displaying country-specific information.
- Protect the security and prevent misuse of our websites and services by tracking use of our websites and services, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies.
When you use the Pepelwerk mobile application. When you use our mobile app, we collect certain information from your device such as your device make, model, and memory. Our application will assign a unique identifier to your device to help us improve the performance of our applications. Pepelwerk does not use information collected from our mobile app for targeted advertising.
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests to:
- Detect crashes, undertake troubleshooting, and understand and improve end-user experience with our mobile applications
- Remotely enable or disable features within the mobile application
If you are an end user of a Pepelwerk product through a Pepelwerk customer. When you use our products and services sponsored by an organization or another Pepelwerk customer, we log certain systems usage information automatically. This information may include system-generated identifiers such as IP address, operating system type and version, whether service tasks and notifications complete, date and time stamps, and details about which of our products you are using. We do not identify you from this systems usage information unless your organization first provides us with instructions to do so, and provides us with certain information about your end-user account. This may happen in the context of a customer support request (e.g., when you or your organization ask us to help you resolve an issue you are having with our products and services).
Purpose and Legal Basis Under Data Protection Law: To the extent our systems usage information is treated as “personal information” under applicable data protection laws, we process this personal information in reliance on our legitimate interests to:
- Provide and maintain the functionality of services and products you and/or your organization request
- Assess and analyze your (and your organization’s) experience interacting with Pepelwerk’s services
- Undertake research and development considering this assessment in order to improve performance of the services
- Protect security and prevent misuse of our services by investigating suspicious activity and enforcing our terms and policies
Information obtained from other sources.
We also collect information about you from other sources including third parties, individuals at your organization, or publicly available sources. We may combine this information with personal information provided by you. Specifically, we collect personal information from the following other sources:
From third-party sources. Pepelwerk may collect business contact information about you from other sources including Pepelwerk partners, co-sponsors of events attended by Pepelwerk, third parties from whom we have purchased business contact information, and from publicly accessible websites, such as your company’s website, professional network services, or press releases. Business contact information may include: first name, last name, business email, telephone number, company name, job related information, education related information, physical street address, digital address and online identifier, as well as background information related to criminal activity and work history. The way in which these third parties collect personal information is detailed in their own privacy policies, available on their websites.
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests or with your consent (where required by law) to:
- Provide you with information about our products (including telemarketing calls and marketing emails, in accordance with your marketing preferences)
- Understand our market and identify potential customer opportunities
From your organization. We also may receive information about you from your organization for the purposes of obtaining or providing services or to recommend individuals to participate in our research studies. For example, another individual at your organization may provide us with your business contact information so that we can give you access to training materials purchased by your organization, or to grant you certain administrative privileges. If your organization is a Pepelwerk supplier, your organization may also provide us with your name and email address so that we can contact you about the services your organization supplies to us.
Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests to:
- Communicate with you about the goods and services provided
- Manage your (or your company’s) account and provide the requested services to you or your company
Disclosing your personal information.
Pepelwerk may share or make accessible your personal information to third parties as follows:
Pepelwerk Affiliates. Pepelwerk may disclose any of the categories of personal information described above to affiliates within the Pepelwerk group where necessary to fulfill a request you have submitted or for customer support, marketing, technical operations, event registration, and account management purposes.
Service providers. Pepelwerk may disclose the categories of personal information described above to third- party service providers or vendors contracted to provide services on our behalf (for example, IT and hosting, data analytics, event services, customer support, call recording, chatbot technology, data enrichment, email fulfillment, and payment services). These third-party service providers may use personal information we provide to them only as instructed by Pepelwerk.
Event Sponsors. When you participate in webinars, events, and other activities where Pepelwerk collaborates with third parties, we may disclose the information described under “if you register for events and webinars” above, such as your contact information and interests in these offerings or services to these approved third parties to communicate with you.
Pepelwerk partners. Pepelwerk may share your personal information with certain partners that offer supplementary services to those provided by Pepelwerk, such as partners that resell Pepelwerk services, to the extent you consent to such sharing (where required by applicable law) or direct us to intentionally interact with such third parties.
Your organization. Where your organization is a customer or potential customer of Pepelwerk, we may disclose your personal information to relevant people within your organization. For example, we may share a list of individuals attending a Pepelwerk event, information about Pepelwerk Training courses you have completed, or inquiries from end users that should be addressed directly by the organization rather than Pepelwerk.
Advertising. When you visit our website, we may enable third parties to use cookies and other trackers to show you ads on third-party websites that are more relevant to you. Under some data protection laws, our disclosure of this information to third parties through cookies and other trackers for targeted advertising may be considered a “sale” or “share” of personal information. Please see our Cookie Notice for more information about the types of cookies we use or click “Cookie Preferences” (link located in the footer of our Website) to set your preferences and opt-out of the sale or sharing (for targeted advertising) of your data. Pepelwerk does not have actual knowledge that it “sells” or “shares” the personal information of individuals under 16 years of age.
Additional disclosures: Pepelwerk may disclose data if we have a good-faith belief that such action is necessary to (a) conform to legal requirements or comply with legal processes; (b) protect and defend our rights or property; (c) enforce our website Terms and Conditions; and/or (d) act to protect the interests of our customers, users, or others. If Pepelwerk goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information may be among the assets transferred, provided that we inform the actual or potential buyer (or its agents and advisors) thatit must use your personal information only for the purposes disclosed in this Privacy Statement. Pepelwerk may also ask for your consent to disclose your information to other unaffiliated third parties that are not described elsewhere in this statement.
Protecting your personal information.
We use technical and organizational measures that provide a level of security appropriate to the nature of the digital personal information you provide and the risks that are presented by processing your personal information. However, the security of information transmitted through the internet can never be guaranteed. You are responsible for maintaining the security of your password or other forms of authentication involved in accessing password-protected or secured resources.
Transferring your personal information internationally.
Pepelwerk operates as a global business and complies with applicable legal requirements when we need to transfer, store, or process your personal information in a country outside your jurisdiction.
We take appropriate safeguards to protect your privacy, your fundamental rights and freedoms, and the ability to exercise your rights.
Retaining your personal information.
We retain your personal identifiable information for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). We reserve the right to retain your de-identified information for the purposes of long-term data collection and studies to improve pepelwerk’s ability to deliver better services and experiences. Examples of de-identifiable information includes but is not limited to your picture without your name, your name separate of your address, and any other profile or data
The criteria used to determine appropriate retention periods for personal information include:
- The length of time we have an ongoing business relationship with you
- The amount, nature, and sensitivity of the personal information we process
- Whether we have a legal obligation to retain personal information or whether retaining personal information is necessary to resolve disputes, including the establishment, exercise, or defense of legal claims
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Certifications.
Data Privacy Framework.
Pepelwerk adheres to the principles of 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) as set forth by the U.S. Department of Commerce. Pepelwerk relies on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF as a legal basis for transfers of personal information. To learn more, visit our Data Privacy Framework Notice here.
APEC Cross-Border Privacy Rules System.
Pepelwerk’s privacy practices, described in this Privacy Statement, comply with the APEC Cross-Border Privacy Rules (CBPR) System. The APEC CBPR System provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here.
Your privacy rights.
Depending on where you are located and how you interact with Pepelwerk, you may have certain legal rights over the personal information we hold about you, subject to local privacy laws.
These may include the right, depending on your jurisdiction, to:
- Obtain access to your personal information that is being processed by us.
- Correct inaccurate personal information.
- Request the deletion of your personal information.
- Opt out of the sale or sharing of personal information for targeted advertising.
- Object to the processing of your personal information carried out on the basis of our legitimate interests in the EEA, UK, and Switzerland, and ask us to restrict the processing of your personal information.
- Request the portability of your personal information in a structured, commonly used, and machine-readable format.
- Withdraw your consent at any time, if we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Opt out of marketing communications sent by Pepelwerk.
Exercising your Privacy Rights.
To exercise your rights with respect to information covered by this Privacy Statement, please contact us using the contact details at the bottom of this Privacy Statement or by submitting a request to info@pw.codegrind.pro. You must provide the information listed in the Request Portal so that Pepelwerk can verify your identity. Pepelwerk will take steps to verify your identity, including validating your name and the email you use when interacting with Pepelwerk. You may also authorize another person or third party to submit a request to exercise your rights by providing written permission in conjunction with the submission of the requested information or by giving the third party your power of attorney. We will acknowledge your request and provide a follow-up substantive response within a time period permitted by applicable law. In the event that Pepelwerk needs an extension to fulfill a request, we will notify you. If we deny your request, we will provide reasons for that denial.
You may opt-out of the sale or sharing of your personal information for targeted advertising by clicking the “Your Privacy Choices” or the “Cookie Preferences” link in the footer of our Website and opting out of the Functional and Advertising Cookies, or by implementing the Global Privacy Control (GPC). For instructions on how to download and use GPC, please visit https://globalprivacycontrol.org. See our Cookie Notice for more information.
Pepelwerk will not discriminate against you for exercising your rights. Pepelwerk does not make decisions based solely on automated processing that produces legal or similarly significant effects as part of the processing activities covered by this Privacy Statement.
If your personal information has been submitted to us by or on behalf of a Pepelwerk customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly.
Lodging a complaint.
You may lodge a complaint with a data protection authority such as the supervisory authority of your usual place of residence. A full list of EEA data protection authorities is available here.
Contact us.
If you have any questions about this Privacy Statement, or wish to exercise your rights, please submit your request to info@pw.codegrind.pro. You may also contact us at1-844-477-5975 or at the mailing addresses below:
17250 Dallas Parkway
Dallas,Texas 75248
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily or you wish to appeal, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Changes to this Privacy Statement.
This Privacy Statement may be amended or revised from time to time at the discretion of Pepelwerk. Changes to this Privacy Statement will be posted on the website and links to the Privacy Statement will indicate that the statement has been changed or updated. If we propose to make any material changes, we will provide notice on this page prior to the change becoming effective. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices.