Traba, Inc. and/or Labor That Works, LLC (as applicable) (“Traba,” “we”, “us,” or “our”) provides the Traba service that allows businesses to connect with shift workers for on-demand job shifts.
This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
1. SCOPE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. HOW WE DISCLOSE YOUR INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. INTERNATIONAL DATA TRANSFERS
7. RETENTION OF PERSONAL INFORMATION
8. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
9. CHILDREN’S INFORMATION
10. OTHER PROVISIONS
11. CONTACT US
SCOPE
This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.” Traba is the data controller for the personal information we process, unless otherwise stated. For information on how to contact us, please refer to “Contact Us” below.
PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on whether you use our Services on behalf of a business (“Business”) or as (1) an individual Traba contractor or (2) a Labor That Works, LLC worker (each a “Worker”), and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
Account Creation. We may collect information when you create an account:
Business account. We may ask for your work email, name, company address, company name,
phone number, and details about the work shifts you need filled, including photos of locations or
machines used to complete the work, and/or the name of any supervisor who will oversee the
work. We will also collect your business’ financial information to facilitate billing, and information
from your business to facilitate staffing and audit purposes.
Worker account. We may ask for your email address, name, mailing and/or physical address,
phone number, government identification numbers, date of birth, photograph, and information
about your professional background, including via background checks. This background
information may include your Social Security number, tax information, employment history, and
health information (such as your ability to perform certain physical tasks required of your work
shift). We may also collect photographs and any related information you provide to us. To
receive payments, we or our service providers will also collect your financial information (such
as your bank account routing numbers) to facilitate payments to you. We do not directly collect
or store any payment card information entered through our Services, but we may receive
information associated with your financial information (e.g., your billing details).
Timesheet Information. If you are a Worker, our Services will collect your clock in, clock out,
and break time to determine the length of your shift and facilitate payouts.
Location Information. If you are a Worker, we may collect precise location information, such as
to confirm your arrival and departure from job locations, to track your location while on a shift, or
otherwise with your consent when you use our Services.
Audio and Video from Worker Shifts. We may collect and store audio, video, or transcripts
from worker-submitted content related to your participation in activities such as home-based
tasks and scheduled shifts at Traba customer facilities.
Audio and Video Communications. We may collect and store audio, video, or transcripts
when you participate in calls (including AI calls that Traba makes to you), interviews, text
exchanges, or video conferences through our Services. This may include your voice, image,
and any related content. You will be informed if a conversation is recorded, and by continuing,
you consent to such recording.
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., leaving a review or
rating of a Business and/or Worker, or leaving messages for other Workers or Businesses).
Although we may provide controls to facilitate private or anonymous sharing or messaging, 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. Please exercise caution before
revealing any information that may identify you to other Businesses or Workers outside the
context of the Services.
Your Communications with Us. We may collect personal information, such as email address,
phone number, or mailing address when you request information about our Services, register for
our newsletter, request customer or technical support, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be
asked to provide certain information which may include personal information.
Sweepstakes or Contests. We may collect personal information you provide for any
sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share
information of sweepstakes and contest winners.
Conferences, Trade Shows, and Other Events. We may collect personal information from
individuals when we attend conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information
from individuals and third parties to assess and pursue potential business opportunities.
Job Applications for Traba. We may post job openings and opportunities for Traba on our
Services. If you reply to one of these postings by submitting your application, CV and/or cover
letter to us, we will collect and use your information to assess your qualifications.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
Automatic Data Collection. We may collect certain information automatically when you use
our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie
identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device
information, location information (including approximate location derived from IP address), and
Internet service provider. 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.
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. Cookies are small text files placed in device browsers that store preferences and
facilitate and enhance your experience.
Pixel Tags/Web Beacons. 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);
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 (including Google Play Services, Analytics for Firebase, and Firebase
Crashlytics). 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.
Facebook Analytics. For more information, please see Facebook’s Data Policy.
Expo. For more information, please see Expo’s Privacy Policy.
Social Media Platforms. Our Services may contain social media buttons such as Google,
LinkedIn or Instagram (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.
Biometric Information. If you consent to our collection of biometric information or if our
collection of biometric information is otherwise permitted, we may collect your biometric
information including, without limitation, your facial recognition information, your fingerprints,
your voiceprint, and your eye retinas and irises. We may use biometric information for identity
verification, authentication, security purposes, Worker tracking, and Worker timekeeping. Your
biometric information may be shared with our service providers. Where required by law, your
biometric information will be stored for no more than three years from your last interaction with
Traba.
C. 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. For example, as a Worker, you may be able to import information from other
platforms you provide services for. 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.
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.
A. Provide Our Services
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;
With consent, sharing personal information with third parties in exchange for monetary or other
valuable consideration;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.
B. 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, such as contextual customization of ads;
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; and
Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
5We may use personal information 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,
cross-device tracking, and “interest-based” or “personalized advertising.”
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.
D. 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 recommend Businesses or Workers to each other. We may also analyze
personal information that you provide to us using AI systems for our business purposes
including, without limitation, verification of documents and verification of required equipment or
gear. 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. 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).
HOW WE DISCLOSE YOUR INFORMATION
We 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.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
Third Parties with Your Consent. With your consent, we may share your personal information
with third parties (such as AI companies), including in exchange for monetary or other valuable
consideration.
This personal information may include, but is not limited to, videos that workers record and
audio / video footage from applicant interviews.
Any personal information shared with these third parties will be subject to the third party’s
privacy policy. We are not responsible for the processing of personal information by third parties.
Other Businesses/Workers You Share or Interact With. The Services may allow or require
you to interface, interact, share information with, and/or direct us to share information with other
Business and/or Workers.
Any personal information shared with another Business may also be subject to the Business’s
privacy policy. We are not responsible for the processing of personal information by other
Businesses or Workers.
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 IT support, hosting, payment processing, worker verification/
background check or tax assistance services, 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.
Affiliates. We may share your personal information with our company affiliates for our
administrative purposes, including activities such as IT management, for them to provide
services to you or support and supplement the Services we provide.
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.
B. 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.
C. 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.
YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are
determined by applicable law and are described below.
Opt-Out of the Sale of Personal Information. If you have consented to our sale of your
personal information to third parties, you can request to opt out of future sales of by emailing
support@traba.work.
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).
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.
No personal information or consent obtained from you will be shared with third parties
for their own purposes unrelated to Traba's services.
Mobile Devices. We may send you push notifications through our 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 Privacy 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 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.
Opting Out of Calls or Video Recording. If you do not wish to receive automated or AI-
assisted calls, texts, or video sessions from us, or if you do not consent to recording, please
notify us at support@traba.work. However, certain Services (such as voice-based interviews or
video consultations) may not be available without recording. If you request deletion of an
existing audio or video recording, we will remove it from active use unless retention is legally
required or necessary for legitimate business purposes.
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.
INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the
world, including, but not limited to, the United States or other countries, 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.
If we transfer personal information to countries outside the European Economic Area, we will put
in place appropriate safeguards to ensure that this transfer complies with the applicable laws
and regulations. For more information about these safeguards, please contact us as set forth
below.
RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy for as long as
you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide
our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate
business purposes, enforce our agreements, and comply with applicable laws.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
The California “Shine the Light” law permits users who are California residents to request and
obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed
their personal information (if any) for their direct marketing purposes in the prior calendar year,
as well as the type of personal information disclosed to those parties.
CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and
we do not knowingly collect personal information from children. 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 described in “Contact Us” below. If we become aware that a child has
provided us with personal information in violation of applicable law, we will delete any personal
information we have collected, unless we have a legal obligation to keep it, and terminate the
child’s account if applicable.
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 our users 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.
When you visit or log in to our website, cookies and similar technologies may be used by our
online data partners or vendors to associate these activities with other personal information they
or others have about you, including by association with your email or home address. We (or
service providers on our behalf) may then send communications and marketing to these email
or home addresses. You may opt out of receiving this advertising by visiting https://
app.retention.com/optout.
Supervisory Authority. 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.
Changes to our 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.
CONTACT US
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: Traba: support@traba.work
