Privacy Policy

1. Introduction

Thank you for using Contra’s websites and services that link to this Privacy Policy. Contra.Work Inc. referred to as “Contra” “we”. or “us” and/or “our” provides a new professional community to allow you and other Contra platform users (“Users”) to connect and work the way you want. Users provide information to create profiles on the Contra Platform that enable Users to connect and provide freelancing services (“Work Projects”) or post Work Project opportunities.

This Privacy Policy describes how we collect, use, share and protect your personal data when you interact with us as a consumer of our Services. This Privacy Policy also explains your personal data choices and privacy rights if your jurisdiction provides them.

2. Scope

This Privacy Policy applies to personal information processed by us, including on our website and other online or offline offerings. To make this Privacy Policy easier to read, our website and other offerings are collectively called “Services.”

Contra is the controller (“Controller”) for the personal information we process, unless otherwise stated. For information on how to contact us, please refer to “Contact Us” below.

3. Personal information we collect

Personal Information means data that identifies you or could reasonably identify you. This includes your name, your business address, your email address and other types of identifying information. This Privacy Policy also applies to Sensitive Personal Information meaning a kind of personal data that carries increased risks to your privacy if disclosed. Sensitive Personal Information can include your social security number, your account credentials, your precise geolocation and more.

How We Collect Your Personal Information

We collect (i) information that you provide to us, (ii) information we obtain automatically when you use our Services, and (iii) information from other sources such as third-party services and organizations, as described below.

Personal Information means data that identifies you or could reasonably identify you. This includes your name, your business address, your email address and other types of identifying information. This Privacy Policy also applies to Sensitive Personal Information meaning a kind of personal data that carries increased risks to your privacy if disclosed. Sensitive Personal Information can include your social security number, your account credentials, your precise geolocation and more.

How We Collect Your Personal Information

We collect (i) information that you provide to us, (ii) information we obtain automatically when you use our Services, and (iii) information from other sources such as third-party services and organizations, as described below.

Information You Provide to Us Directly

We receive your personal information when you provide this to us, when you use our Services, complete a transaction via our Services or when you otherwise use our Services, including:

• Account Creation. We may collect information when you create an account, such as name, email business address, password, location and photograph.

• Verification of Identity. We use third parties, including Persona and Stripe, to verify your identity, comply with “Know Your Customer” (KYC) and Anti-Money Laundering (AML) requirements, and/or prevent fraud. These third parties may collect your name, birthdate, social security number, address and government identification pursuant to the terms of their privacy policies. If you choose to use our Services, you consent to the processing of your data by these third parties.

• Payment Information. We may collect personal information to facilitate payments between users, including payment information. Any payments made via our Services are processed by third-party payment processors. When you make a payment using your payment card, we do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details). If you utilize cryptocurrency to carry out a transaction, we may collect your cryptocurrency wallet address.

• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address (home or work) when you request information about our Services, request customer or technical support, apply for or post an opportunity, or otherwise communicate with us.

• Surveys & Interviews. We may contact you to voluntarily participate in surveys or User interviews. If you decide to participate, you may be asked to provide certain information which may include personal information.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., work portfolio, project requests, matchmaking services, referrals, videos, messaging and chat features, commenting functionalities, portfolio building events, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.

• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we may offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

• Live Events. We may collect personal information from individuals when we host in person events.

• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Information Collected Automatically

We automatically collect data about you when you visit our website and use our services. The types of data we automatically collect include:

• Device and Network Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, cookie identifiers, browser or device information, location information (including approximate location derived from IP address).

• Usage Information. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you and/or provide referrals and/or feedback regarding your work performance and project results and/or other interactions between you and a Client or Independent.

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below). For example, we may track your website activity, including recordings of your interactions with the website;

  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:

• Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

• PostHog. For more information, please visit PostHog’s Privacy Policy.

• Sentry. For more information, please visit Sentry’s Privacy Policy.

• Segment. For more information, please visit Segment’s Privacy Policy.

• ZoomInfo. For more information, please visit ZoomInfo’s Privacy Policy.

Social Media Platforms. Our Services may contain social media buttons such as Instagram, X (formerly known as Twitter), TikTok, and Pinterest (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

Information Collected from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. In addition, we may collect information about you from publicly available sources.

4. What personal data we collect

We collect categories of Personal Data, including:

• [Data Category]: [Specific Data We Collect]

• Identifiers: Name, alias, postal address, unique personal identifier, IP address

• Contact Data: Phone number, address, email address

• Financial data: Bank account information

• Special or Sensitive Data: Personal Information that reveals: Date of birth, gender; Social Security, driver’s license, state ID card, or passport number; Geolocation; or Processing biometric information for the purpose of uniquely identifying a consumer

• Audio, electronic, visual: Profile photos

• Internet or electric network activity data: Browsing history with our internet website

• Professional or employment-related data: Work history, prior employers, certifications, permits

• Education data: Academic records, qualifications

• Inferences: (Drawn from the Personal Information above to build a profile about an individual’s preferences, characteristics, behaviors, abilities, aptitudes, etc.)

• Written Signature: Written Signature

5. How we use your information

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

To Provide Our Services and Respond to Requests

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;

• Providing access to certain areas, functionalities, and features of our Services;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

• Processing your financial information and other payment methods for products or Services purchased;

• Processing applications if you apply for an opportunity we post as a Client on our platform; and

• Allowing you to register for events.

For Legitimate Interests/Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Services;

• Short-term, transient use;

• Improving, upgrading or enhancing our Services;

• Developing new products and Services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions and other compliance activities;

• Enforcing our agreements and policies

Compliance, Health, Safety, and Public Interest

We may also process Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law, for the establishment and defense of legal claims, where we must comply with requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent required or permitted under applicable law. Please see the How We Share Personal Data section for more information about how we disclose Personal Data in extraordinary circumstances.

As Permitted by Law

We may process your Personal Data for other purposes, as permitted by applicable laws including for our agreements and other policies.

Marketing and Advertising our Products and Services

We may use personal data to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

• Automated Decision Making. We may engage in automated decision making, including profiling, such as to present you with potential work opportunities that may be a match for your skills and experience and to better curate the content that is shown to you via the Contra feed. We may also use automated decision making for anti-fraud and anti-spam purposes. Contra’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless 1) such a decision is necessary as part of a contract we have with you; 2) we have your consent; or 3) we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

• De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.

• Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities related to sharing content. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

6. How we disclose your information

We may disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with identity verification, IT support, hosting and cloud service providers, payment processing, customer service, and related services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.

• Other Users/Website Visitors. As described above in “Personal Information We Collect,” our Services allow you to share your profile, user videos, and work portfolios with other Users.

• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

7. Your privacy choices and rights

Your Privacy Choices. The privacy choices you may have about your personal data are determined by jurisdiction, where you reside and applicable law and are described below.

• Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

• Mobile Devices. We may send you push notifications through a mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device. 

Your Data Protection Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;

• Request Correction/Rectification of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;

• Request Restriction of or Object to our processing of your personal information when processing is noncompliant;

• Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;

• Request Data Portability and receive an electronic copy of personal information that you have provided to us;

• Be informed about third parties with which your personal information has been shared; and

• Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

8. Security of your information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. 

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services or by sending an email to you. The files and records containing your Personal Information will be kept within our cloud service providers and only those employees that require it for the purposes of their duties will have access to this file. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

9. International data transfers

We may transfer, process, and store information anywhere in the world, including, but not limited to, the United States which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

By providing your Personal Information through the Services, you consent to the extent allowed by law to such transfer, storage, and processing.

The files containing your information will be on our servers and those of our service providers and will be accessible to persons that require it for the purposes of their duties. Information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about our policies and practices with respect to service providers outside of your country, please contact us as set forth below. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

10. Data retention

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Privacy Notice, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data: 

• Retention periods established under applicable law; 

• Industry best practices; 

• Whether the purpose of processing is reasonably likely to justify further processing; 

• Risks to individual privacy in continued processing; 

• Applicable privacy assessments; 

• IT systems design considerations/limitations; and 

• The costs associated with continued processing, retention, and deletion. 

We will review retention periods periodically and may delete, pseudonymize, or anonymize data held for longer periods.

11. Children's information

Our Services are intended for Users who are 18 and over, and we do not knowingly collect personal information from anyone younger than 18.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent you may contact us as set forth in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will use commercially reasonable efforts to delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

12. Other provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 

Updates to this Privacy Policy. We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

13. Contacts for questions or complaints

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Contra.Work Inc.
Data Privacy Officer
2261 Market Street #4650
San Francisco, California 94114
hello@contra.com

In the unlikely event you wish to lodge a complaint about our collection, transfer or processing of your personal data, you can lodge a complaint with your local data protection authority in the EEA and UK; contact information is available here (EEA) and here (UK).

This policy is effective as of 15 February 2024.