Last Updated December 31, 2019


Data Analysis Inc. ("DAI", “Company”, "we", or "us") is committed to respecting and protecting the privacy of the personal information it processes on behalf of itself and/or its corporate affiliates (collectively, “Affiliates”). This Privacy Policy, including any future modifications and/or addenda (collectively, the "Privacy Policy"), applies to all information (including personal information) we may collect through your use (whether as a guest or a registered user) of (the "Site"), the SuccessFactors human resources platform that is used to manage job candidates’ applications and our recruitment process (the “Platform”), any information you provide to us voluntarily, and any other sites, applications, software, features, events, surveys or studies, or content offered by the Company or its Affiliates from time to time that links or otherwise refers to this Privacy Policy (collectively, including the Site and the Platform, the "Services"). For purposes of this Privacy Policy, “personal information” means information that relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. 

Except with respect to the processing of the personal information of employees of the Company or its Affiliates, this Privacy Policy is effective with respect to all information that we have collected from you or will collect from you in the future (including any personal information you submit to us as part of the employment application process) - employees will be provided with a separate written privacy policy that details the scope of any processing operations that impact their personal information (the “Employee Privacy Policy”). Please read this Privacy Policy carefully before you start to use the Services. BY ACCESSING AND/OR USING THE SERVICES, YOU EXPRESSLY CONSENT AND AGREE TO BE BOUND AND ABIDE BY THIS PRIVACY POLICY AND THE TERMS OF USE AVAILABLE AT HERE (THE "TERMS OF USE") INCORPORATED HEREIN BY REFERENCE AND TO COMPLY WITH ALL APPLICABLE LAWS, RULES, AND REGULATIONS (COLLECTIVELY, "APPLICABLE LAWS")

Further, you also certify that all information that you provide to us will be accurate and up-to-date and you understand that providing false information during any of the steps of the employment application process may lead to your rejection or termination. If you are hired, any external profile will be converted into an internal profile upon joining the Company or one of its Affiliates - from that time forward, any processing of your personal information will be governed by the Employee Privacy Policy in effect for the company that employs you. If you do not want to agree to this Privacy Policy and the Terms of Use, you must not access or use the Services.

Note: If you are affected by a visual impairment that prevents you from reading the content of this Privacy Policy and/or any addenda, you may call the Company at (833) 401-0196 for further assistance.

The Company’s primary line of business is providing shared services (human resources, legal, accounting, etc.) on behalf of its Affiliates – the Company does not have any outside clients. Accordingly, most personal information that we process has been voluntarily provided to us by you (by filling out a form on our Site, the Platform, or otherwise communicating with us), our employees, service providers, or Affiliates. With respect to the Platform, the Platform is used by the Company and its Affiliates to manage job candidates’ applications and the overall recruitment process – this includes the following companies: 

Data Analysis, Inc., a California corporation;
O’Neil Capital Management Inc. (“OCM”), a California corporation;
O’Neil Digital Solutions, LLC (“ODS”), a Delaware limited liability company;
O’Neil Global Advisors, Inc. (“OGA”), a Delaware corporation;
O’Neil Securities, Incorporated (“ONS”), a California corporation;
William O'Neil & Co., Incorporated (“WON”), a Delaware corporation; and
William O’Neil India Pvt. Ltd. (“WON India”), an Indian private limited company.

In general, the Company collects the following categories of personal information and has collected such categories of information over the twelve (12) month period preceding the date this Privacy Policy was last updated:  

  • Identifiers: Examples might include your name, email address, phone number, IP address, device identifier, or account name; 
  • Personal Information: Examples might include your financial information or business information; 
  • Classification Characteristics: Examples might include your age or sex;
  • Internet Activity: Examples might include your browsing history, your search history, and information on your interaction with the Site, the Platform, and/or other Services; 
  • Geolocation Data: Examples might include your physical location or movements;
  • Professional or Employment-Related Information: Examples might include your current/past employers, job positions, salary, etc.
  • Inferences: The Company may make inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitudes.

When you access the Services, or otherwise communicate with us, upload information, submit a request, attend an event (in-person or otherwise), or otherwise communicate with us, directly or through a third party (e.g., SAP), we may collect and store any personal information you may provide. This could also include any information you provide to one of our Affiliates that is transferred to the Company so the Company can perform services on behalf of its Affiliates. This information may include, without limitation, your: name; phone number; birthdate; age; gender; physical address; e-mail address; e-mail communications; phone communications; messaging platform communications; data entered into forms or surveys; dates and times of access; usernames; passwords; web cookies; government identification numbers; licenses/certifications; salary/salary history; job positions; educational information; employment history; any other information on your résumé or other information that you disclose to us; and/or any information you provide to us about other people. By submitting such information, you agree that this information may be shared with third parties for the purposes detailed herein.

Further, if you submit suggestions, ideas, enhancement requests, recommendations, or other feedback in connection with the Services (collectively, “Feedback”), the Company will have the unrestricted right to use or act upon such Feedback without compensation and such Feedback will not be considered confidential. By providing any of the foregoing information, you consent to such information being collected, used, disclosed, shared, and stored by us in accordance with this Privacy Policy.

The Services may use cookies and other means of collecting information; such information is used to enable you to submit your information to us and for analytical purposes. Cookies are messages placed on your computer or mobile device when you visit a website or page. For example, a cookie may be used to store your login and profile details so you do not have to re-enter them each time you login to the Platform. It is possible to disable the placement of cookies through your browser settings. However, as portions of the Services rely on cookies to enable certain functionality, if you choose to disable cookies, some of this functionality may not work properly.

We may also collect technical and usage information when you use the Services, including, without limitation, information obtained using various types of tracking software, such as cookies, beacons, pixels, and/or other tracking technologies which collect information about you when you use the Services. Information collected may include your browser type and version, IP address, operating system and platform, your internet service provider, when you open email that we send you or interact with an advertisement, and other information. 

We may collect and store information locally on your device using mechanisms such as browser web storage and application data caches. In addition, if you access the Service from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device. By visiting/using the Services, you consent to the tracking of your activities and your use of the Services through the technologies described in this Privacy Policy and similar technologies that may be used or developed in the future.

We may obtain additional personal information about you from our service providers (e.g., staffing/recruiting agencies), the internet, offline sources, or other public or commercial sources including, but not limited to, social media services you have provided your information to (e.g., your name, username, gender, birthday, profile picture, avatar, “likes”, etc.). This could include, for example, information you have provided to recruiters, job-posting services (e.g., LinkedIn), social media services, or other similar services. When you access the Services through a third-party service (e.g., Facebook, Twitter, etc.), you connect the Services to a third-party service, or share our content via a third-party service, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.  

We may also receive additional personal information about you from certain third parties (e.g., researchers, analysts, and/or marketers) that provide us with statistical, demographic, or other similar information. Further, we may also combine your online information with information we obtain from offline sources, including, without limitation, information that you may provide us with over the phone, via webchat, or via email. The Company is not responsible for the privacy practices of third parties; when you provide information about yourself on such services, it may be publicly viewable by other users of such services and we cannot prevent further access by others. If you wish to know how social media services or other third-party service providers handle your information, please review their respective terms of use, cookie policies, and/or privacy policies; such services/parties may permit you to modify your privacy settings. 

We may collect aggregated and/or anonymized information for various purposes. Once aggregated or anonymized, information is no longer considered to be “personal information” because it will no longer be able to identify you individually and/or any of your devices used to access the Services.



As the Company does not have clients outside of its Affiliates, the Company generally only uses personal information in order to: (a) evaluate a candidate’s suitability for current and/or future employment opportunities with the Company or our Affiliates; (b) to otherwise communicate with you; (c) to evaluate/engage service providers; (d) aggregate information; and (e) for purposes that are required by Applicable Laws. The Company will never use your personal information to send you marketing, advertising, or other similar messages.


The Company processes personal information in order to evaluate your qualifications for current and/or future employment/engagement with the Company or our Affiliates. Additionally, the Company will use personal information so that it can manage its recruiting, hiring, and procurement processes. Further, we may also verify references you give us and you hereby authorize us to contact any person/entity you have listed as a reference.

We use your personal information to communicate with you the Services, available job opportunities, your application, communications you have sent us, etc. We will generally communicate with you via email, web chat, and/or by telephone. By using the Services, or otherwise engaging with us, you agree that the Company and/or our representatives may email, call, or text you, including communicating with you about your interactions with the Company or the Services. Please note that if you telephone us, or if we call you, the call may be recorded for quality, training, and/or management purposes; online interactions (including through chat or email) may be recorded for similar purposes.

BY PROVIDING YOUR HOME TELEPHONE NUMBER OR MOBILE NUMBER, YOU ACKNOWLEDGE AND AGREE THAT THE COMPANY MAY MAKE CALLS AND TEXTS TO SUCH NUMBER VIA USE OF AN AUTOMATIC TELEPHONE DIALING SYSTEM (“ATDS”) OR ANOTHER SIMILAR ANNOUNCING DEVICE. However, it should be noted that consent to receive phone calls via an ATDS is not a required condition for employment or to otherwise do business with the Company or any of its Affiliates. 

The Company may aggregate and/or anonymize any information collected for various purposes. Once aggregated or anonymized, the information will no longer be considered “personal information” because it will no longer be able to identify you and/or any of your specific devices used to access the Services. The Company may use such information for any purpose (e.g., research and development purposes), including sharing such information with third parties. 

Your information will also be used to fulfill any other purpose for which you provide the information or otherwise provide your consent for the Company and/or other third parties to use such information.



As stated above, the Company’s primary line of business is performing administrative services on behalf of its Affiliates. The Company may be required to process your personal information to fulfill its contractual obligations to its Affiliates and/or to ensure that its Affiliates are able to meet their contractual or legal obligations (e.g., screening requirements imposed by a client of an Affiliate).

As the Company is part of a larger group of companies, it may be necessary for the Company to transmit your personal information to its Affiliates. Processing may be necessary so that data can be shared amongst our affiliates so that each entity can carry out their legal, regulatory, and/or contractual responsibilities and/or coordinate/implement business plans, logistics, and/or operations. This is especially true because the Company performs critical services on its Affiliates’ behalf, including services related to: accounting, human resources, legal, etc.

Processing your personal information may be necessary to facilitate the day-to-day operation of our business, to allow our service providers and other third-parties assist in providing and managing the Services, and to allow for business planning for strategic growth. This may include: managing our relationship with you, our employees, users, clients, vendors, and/or others; sharing intelligence with internal stakeholders; implementing training procedures; planning and allocating resources and budgets; performing data modelling; facilitating internal reporting; analyzing growth strategies; aggregating analytics; and/or processing personal information to create anonymized data (e.g., for product improvement, analytics, etc.).

Processing your personal information may be necessary to enable the Company’s business operations to run more efficiently, e.g., establishing how to allocate resources. 

Processing your personal information will likely be necessary for us to deliver and/or improve the Services. This includes processing your personal information to determine whether our offerings are working as intended, monitoring usage and conduct, and identifying and troubleshooting issues.

The Company may need to process your personal information in order to identify recurring problems and/or analyze the patterns of behavior of users in order to monitor the performance of, and users’ behavior on, the Services.

Processing your personal information may be necessary for direct communication purposes to occasionally communicate with you for non-marketing/advertising purposes.

The Company may need to process personal information in the context of communicating with other businesses, e.g., processing the information of a business contact.

It may be necessary for the Company to process your personal information for the purposes of conducting due diligence. This could include, for example, monitoring official watch-lists, sanction lists and “do-not-do-business-with” lists published by governments and other official bodies globally. This could also include keyword searches of industry and reputable publications to determine if companies and individuals have been involved in or convicted of relevant offenses, such as fraud, bribery, and/or corruption.

Processing your personal information may be necessary for the Company to help detect and prevent fraud.

Processing your personal information may be necessary to verify the accuracy of your data and to create a better understanding of our past, present, and/or prospective users, visitors, and/or applicants (including preferences related to receiving communications). 

Processing your personal information may be necessary for the purposes of ensuring our network and information security, e.g., monitoring users’ access to our network for the purpose of preventing cyber-attacks, inappropriate use of data, corporate espionage, hacking, system breaches, etc. This could include preventing unauthorized access to electronic communications networks and malicious code distribution and stopping “denial of service” attacks and damage to computer and electronic communication systems. 

The Company may process your personal information because it is necessary to allow for the backup and protection of your information (e.g., utilizing cloud-based services to archive/protect data) in order to ensure that such information is not improperly lost or modified. Such processing may also be necessary to archive/protect data in accordance with legal, regulatory, organizational, and/or contractual obligations.

In processing your personal information, the Company may process your data utilizing algorithms that help to streamline organizational processes, e.g., putting in place an algorithm that helps to route candidates contacts to the most appropriate Company contact/department.

The Company is subject to binding legal or regulatory obligations and may need to process your personal information in order to comply with such laws or regulations. Examples could include: complying with reporting obligations; complying with screening obligations; responding to law enforcement requests; and/or responding to judicial/regulatory agency requests.

Several of the Company’s Affiliates are part of industry self-regulatory organizations. Such organizations were formed in order to address various concerns, including: developing industry standards and best practices to protect the industry; sharing intelligence or concerns about individuals (e.g., industry-specific watch lists); sharing intelligence or concerns that may have a negative or detrimental impact on the industry; and/or ensuring that participants in the industry are following agreed-upon standards. The Company may be required to process personal information so that we may stay in compliance with these self-regulatory requirements.

The Company may need to use personal information to report possible criminal acts or threats to public security/safety that we identify as part of our processing activities to a competent authority.

Your information will also be used to fulfill any other purpose for which you provide the information or otherwise provide your consent for the Company and/or other third parties to use such information – assuming such use is consistent with applicable laws and regulations.

The Company shares personal information as stated in this Privacy Policy and in accordance with Applicable Laws. We do not share your personal information with others except as indicated in this Privacy Policy, as required/allowed by Applicable Laws, or when we inform you and give you an opportunity to “opt-out” of having your personal information shared. For applicants and service providers, we will only share your information in order to evaluate your suitability for current and/or future employment/engagement opportunities with us and where sharing is required by applicable laws or regulations. When we share your personal information with service providers, we will require them to protect your information. We will never share your information with third parties for marketing, advertising, or other similar purposes. Below, are categories of third-parties that we may share your information with:

We may share your personal information with service providers who perform services on the Company’s behalf. Your information is generally shared with service providers so that the Company can fulfill, streamline, and enhance the Services. Service providers could include parties that perform research services, recruitment services, background screening services, and/or other operational support.

As stated above, the Company’s primary line of business is providing administrative services for its Affiliates. Accordingly, most personal information that we process has been provided to us by our employees, Affiliates, and/or service providers. Additionally, as the Company is part of a larger group of companies, it may be necessary for the Company to transmit your personal information within the organizational group.

We may share your personal information with competent governmental authorities when required by law and/or as necessary to protect the Company, its personnel, other users, and/or the Services.

When you contact us via phone, text, email, chat, or otherwise contact us, we may include the contact information you provide to us (e.g., your address, phone number, or email address) in a profile. If your personal information changes, you may be able to correct, update, or remove your personal information provided to us by sending an email to us at:



The security of personal information is very important to us. Personal information is protected by the Company in accordance with generally accepted industry standards and applicable data privacy laws, including both online and offline security measures and safeguards. The Company uses a combination of administrative, technical, personnel, and physical measures to safeguard personal information in its possession against loss, theft, and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information. 

IF YOU HAVE REASON TO BELIEVE THAT YOUR INTERACTION WITH US IS NO LONGER SECURE (FOR EXAMPLE, IF YOU FEEL THAT THE SECURITY OF ANY ACCOUNT YOU MIGHT HAVE WITH US HAS BEEN COMPROMISED), PLEASE IMMEDIATELY NOTIFY US OF THE PROBLEM.  However, please remember that no method of electronic storage or transmission over the internet is one-hundred percent secure and, therefore, while we strive to use commercially reasonable means to protect your personal information, and will comply with applicable data privacy laws, we cannot guarantee the absolute security of such information.

Phishing is a term used to describe a type of internet scam in which inauthentic communications that appear to be coming from a legitimate source are sent in an attempt to trick you into providing confidential information. These communications usually invoke a sense of urgency and often imply that your account is about to be closed unless immediate action is taken. As an example, phishing emails will often ask you to click on a link that leads you to a webpage that simulates that of the legitimate source, but it is really a page specially designed to get you to input your confidential information such as your account number, password, social security number, or credit card number. The thieves then use that information to commit fraud and identity theft.

The Office of the Comptroller of Currency has set up a website providing information warning consumers about the dangers of these scams and how to protect yourself. To learn more about phishing, please click on the following link: If you ever question the legitimacy of an email or other communication from the Company, please contact us at  If you believe you have been the victim of a scam, you can file a complaint with the Federal Trade Commission at:

At this time, the Services do not recognize or respond to browser’s “Do Not Track” signals.

We will retain your information for the period necessary to fulfill the purposes for their collection as outlined in this Privacy Policy, unless a longer retention period is either mandated by the Company’s contractual requirements, internal policies, or otherwise required or allowed by Applicable Laws.  We may retain backup information related to any account/interaction on our servers for for fraud detection or to comply with Applicable Laws or our internal security policies. It is not always possible to completely remove or delete all of personal information due to technical constraints, contractual, financial, or legal requirements. Where it is not possible to remove or delete all information, the Company shall continue to safeguard your information as detailed herein.

The Services are for a general audience and are not targeted to children.  The Company, its Affiliates, and service providers do not knowingly collect, solicit, or share personal information from children under the age of sixteen (16). If such a situation is discovered, we will delete that information immediately. If you believe the Company has any information from a child under the age of sixteen (16), please contact us via email at  

For users that are residents of the State of California, please click here to review the Company’s California Privacy Addendum (the “California Addendum”). The California Addendum details your rights under the California Consumer Privacy Act (“CCPA”), additional disclosures as required under the CCPA, and provides you with an explanation of how you may exercise your rights (including the Right to Opt-Out of the Sale of Personal Information). The California Addendum also details your rights under California’s "Shine the Light" law.

For users that are residents of the State of Nevada, the Company does not constitute a web “operator” for purposes of Nevada Senate Bill 220 (“SB-220”). 

The Company is a California corporation with its headquarters located at 12655 Beatrice St., Los Angeles, California 90066, United States. Our Services are targeted at residents of the United States and our Services are governed by, and operated in accordance with, the laws of the United States. The United States is where the Services, including our servers and central database, are hosted, located, and operated. If you are accessing the Services from outside the United States, you will be voluntarily transmitting your personal information to the United States where your information will be stored and processed by the Company and/or its service providers.

There are obvious risks that apply when data are transferred from one jurisdiction to another (e.g., an unauthorized interception of the data, misuse, etc.) and the data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country of residence. Additionally, in certain circumstances, law enforcement or regulatory agencies, courts, or security authorities in the United States may be entitled to access your personal information. BY USING THE SERVICES OR OTHERWISE COMMUNICATING WITH US, YOU ACKNOWLEDGE AND AGREE THAT YOUR PERSONAL INFORMATION WILL BE TRANSFERRED TO, AND PROCESSED IN, THE UNITED STATES AT OUR FACILITIES AND BY THOSE THIRD PARTIES WITH WHOM WE SHARE IT AS DESCRIBED IN THIS PRIVACY POLICY. Please be assured that we take commercially reasonable steps to ensure that your privacy is protected. 

For users that are residents of the European Union (“EU”) or the United Kingdom (“UK”), while the Company is an American company subject to American law, please click here to review the Company’s EU Data Privacy Addendum (the “EU Addendum”). The EU Addendum provides you with an explanation of how the Company will attempt to give effect to rights provided under the EU’s General Data Protection Regulation (“GDPR”) and provides you with additional disclosures. 

This Privacy Policy is subject to change at any time. All changes will be posted on the Site.  If the changes are significant, we will notify you by email (at the last email we have on file for you) or by prominently posting a notice on our Site (e.g., through a pop-up on our homepage). Changes will become effective as of the earlier of the date we post the revised privacy policy, send an email detailing any changes, or post such a notice. While we will do our best to inform you of any changes, we encourage you to review our Privacy Policy periodically to ensure that you remain informed of changes that may have occurred, including changes that relate to what information we collect, how we use it, and how we share it. BY CONTINUING TO USE THE SERVICES AFTER A CHANGE HAS TAKEN PLACE, YOU ARE AGREEING THAT YOU HAVE READ AND HAVE AGREED TO THE MOST CURRENT VERSION OF THIS PRIVACY POLICY AND EXPRESSLY CONSENT TO THE USE OF YOUR PERSONAL INFORMATION AS DETAILED HEREIN/THEREIN.


Though we make every effort to preserve user privacy, we may need to disclose your personal information to others. We may share your information to provide information to our representatives, service providers, advisors, corporate affiliates, clients, and business partners, and in the event of a sale, merger, public offering, bankruptcy or other change in control of the Company and/or its affiliates, your information may be shared with the person or business obtaining ownership and control. Your information may be used to protect the rights, including legal rights, and safety of ourselves and others.  We may also use your information to enforce our rights arising from any contracts entered into between you and us, including, for billing and collection.  Furthermore, disclosure of personal information may be required by law where we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or legal process.  In such cases, we may raise or waive any legal objection or right available to us.

Other websites and services to which we link, through which you access the Services, or share information from the Services and which are not owned or controlled by us are not subject to the terms of this Privacy Policy.  WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF ANY OTHER WEB SITES OR SERVICES AND ANY VISIT YOU MAKE TO THOSE OTHER SERVICES IS AT YOUR OWN RISK.  Third parties that support the Services, including by providing advertising or other services, such as analytics, may use tracking technologies to collect information about your use of the Services or other third-party services.  We do not control these third-party technologies or services and their use is governed by the privacy policies of third parties using such technologies.  Such third party's use of any information you share is governed by the third party's privacy policy.

If any provision of this Privacy Policy (including any attachment) is held to be invalid, illegal, or unenforceable by a court or regulatory authority of competent jurisdiction, the rest of this Privacy Policy shall remain valid and enforceable to the fullest extent permitted under Applicable Laws. To the extent that the main body of this Privacy Policy conflicts with the terms of any addenda referenced herein, the addenda will control.

To ask questions or comment about this Privacy Policy and/or our privacy practices, please contact the Company via email at For users with disabilities that would prefer to speak via phone, you may reach us at (833) 401-0196.


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