Last updated: July 1, 2023
1. What Personal Information We Collect. Company may collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you or your household (referred to herein as “personal information”). The categories of personal information we may collect or have collected about you within the past 12 months include without limitation:
Identifiers – This includes, without limitation, your real name, alias, account name, online identifier, email address, postal address, phone number, social media profile, social media address, or other similar identifiers. Our web servers may automatically collect unique identifiers that can be used to recognize you or your device, mobile carrier or access provider, including without limitation your domain name, Internet Protocol address, beacons, pixel tags or other device and mobile identifiers or similar technology.
Personal Information Categories Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)) – This includes, without limitation, your name, address, telephone number, education, employment, and employment history. Some personal information included in this category may overlap with other categories.
Characteristics of Protected Classifications Under California or U.S. Law – We do not request or require you to provide protected classification characteristics to us. However, resume/CVs and other application materials, which we collect from talent candidates, may inadvertently include protected classification characteristics. Please carefully review all materials you provide us, and do not provide us with such sensitive information, including but not limited to your: (i) racial or ethnic origin; (ii) political, philosophical or religious beliefs, including membership in a political party or trade union; (iii) physical or mental health, biometric details, or genetic makeup; (iv) sexual orientation or preferences; or (v) age (over the age of 40). Some of our clients may request for a veteran or military status of talent candidates in accordance with applicable law, and talent candidates may choose whether or not to submit such information to us.
Commercial Information – With respect to our clients or prospective clients, this includes, without limitation, records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, such as details about payments to and from you, details regarding the Services that you have purchased, and details about your company or organization (such as contact information and website URL).
Payment Data – With respect to our clients or prospective clients, this includes, without limitation, your credit card information, billing address or any financial information you provide in connection to your use of our Services.
Internet or Other Electronic Network Activity Information – This includes, without limitation, your browsing history, search history, and any other information regarding your interaction with our Services and advertisements.
Geolocation Data – This includes, without limitation, information that can help identify your physical location like your GPS coordinates, the approximate location of your electronic devices, and time zone setting.
Audio and Visual Information – This includes, without limitation, voice and video recordings (e.g., when you leave voicemails on our voice mail boxes).
Professional or Employment Information – With respects to talent candidates, this includes, without limitation, your current and past employment and titles, your current corporate duties, work address and contact information, education information, job searches, job applications, base salary, salary requirements and expectations, and any information provided in a resume/CV or job seeker profile. With respects to our clients or prospective clients, this includes without limitation your title and position, candidate searches and requirements, and other professional or employment-related information about you that you would like shared with talent candidates.
Inferences Drawn About Your Preferences – This includes, without limitation, your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes, decisions, and actions as it relates to your preferences or behavior relating to your use of our Services.
Other Categories of Personal Data that Relates to or is Reasonably Capable of Being Associated with You– This includes, without limitation, the messages you send us via our Services and any user-generated content you provide us. We may also collect your general availabilities and calendared events in order to organize calls, meetings, video conferences or interviews.
Data About Others – Including without limitation personal information of individuals for whom you provide to us, such as other individuals’ name and email address. If you do not have such individual’s permission to share their information, please do not share such information with us.
2. How We Collect Your Personal Information. Company collects your personal information from a variety of sources, including without limitation from you directly, referrals, clients, talent candidates, social media platforms and networks, and our third party service providers, vendors and affiliates. Some ways we collect personal information about you include, without limitation:When you create an account to use our Services.When you speak with our staff in an effort to be our client or talent candidate.When talent candidates respond to our outreach messages and submit resumes/CVs or other job requirements to be considered for a job opportunity.When you use our Services (i.e., through our browser cookies, web beacons, third party software development kits, and other similar technology).When you complete a survey or send us messages or other content regarding feedback and inquiries relating to our Services, job searches, candidate searches, job opportunities, marketing material, and other advertisements.When you disclose personal information to our customer service providers and staff.Through our events (e.g., we may ask for your name to confirm you are on our RSVP List, and we may take photos and record videos at our events for marketing and promotional purposes).Through publicly available sources such as LinkedIn, job boards, social media, and any other information from third party websites found from an internet search of your name or during our research for talent candidates and prospective clients.Your interaction with other third parties (e.g., our service providers), with whom you provided your consent for them to share your personal information with us.Through purchased email lists from third-parties for advertising and marketing purposes or for fraud detection and prevention.When you link your social media account to your account and profile on our Services. You may have the option to import certain information from your social media accounts and add it to your profile automatically.During our onboarding process as a client or talent candidate, when you submit questions or comments, request information, or respond to our inquiries.
3. How We Use Your Personal Information. Company collects and uses your personal information for various business and commercial purposes, including without limitation:Matching candidates with employers.Sending outreach messages to talent candidates.Sending you alerts regarding our Services, job opportunities, and candidate matches that you have expressed an interest in or we think may interest you.Sending personalized emails and messages regarding your use or proposed use of our Services.Processing your job applications or recruitment/hiring requests.Operating, managing, and improving our Services, marketing material, outreach strategies, and promotions.Performing Services requested by you, such as responding to your comments and employment requests, processing or fulfilling job matches, verifying your information, servicing or maintaining your accounts, scheduling interviews, and sending related communications.Undertaking activities to verify or maintain the quality, safety, security and integrity of our systems, operations, equipment, devices, events and Services.Detecting security incidents, protecting you against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.Sending you technical notices, updates, security alerts, information about our policy changes, and other administrative messages.Preventing and addressing fraud, unlawful access, and breach of our policies and terms.Complying with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise disclosing information to protect the rights, property or safety of our clients, talent candidates, employees, affiliates, service providers and or the public.Investigating claims and pursuing legal matters such as defending against claims and/or establishing or exercising any legal rights that Company may have.Analyzing trends and usage, such as the efficiency of deliveries and operations, and troubleshooting problems with our Services, Wi-Fi systems, or other technology driven models and systems.Debugging to identify and repair errors that impair existing intended functionality of our Services, Wi-Fi systems, or other technology driven models and systems.Facilitating our accounting, auditing, and reporting requirements for internal purposes or in connection with a merger, acquisition or other business transaction.Auditing relating to your interactions with our Services.Posting and advertising job opportunities for talent candidates.Conducting surveys to better understand how we can help current and prospective clients and talent candidates.Undertaking internal research for technological development and demonstration.Correlating information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts.Processing or engaging in a sale of all or part of our business, or if we go through a reorganization or merger.Fulfilling any other business or commercial purposes at your direction, with your consent, or as reasonably anticipated within the context of your ongoing business relationship with Company.
Affiliates – We share information with our related entities including without limitation our parent, subsidiaries, and affiliates, or to their employees, agents, contractors, representatives, legal counsel and/or accountants, for: operational, management and administrative purposes; internal audit, legal, regulatory, security, insurance, financial, processing and other similar purposes; marketing, research and development purposes; or as otherwise permitted or required by law.
Professional Advisors – We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional service that they render to us.
Advertising Partners – We may purchase from third parties your personal information and may share your personal information to third parties as we contemplate making such purchases.
Third Parties in Connection with a Merger, Acquisition or Other Business Transaction – We may share information if Company is involved in a merger, acquisition, sale of all or a portion of its assets, financings, joint ventures, reorganizations, dissolution, liquidations, or other event where we sell or transfer all or a portion of our business assets or equity. We will not provide you with notice before disclosure in such cases.
Third Parties for Security and Compelling Disclosure Purposes – Company must disclose information about you in response to lawful requests by public authorities, including but not limited to meet national security or law enforcement requirements. We may share information about you in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.
Clients and Prospective Clients – We may share personal information of talent candidates to our clients and prospective clients, such as when a client or prospective client requests for a talent candidate’s professional and employment-related information for purposes of evaluating his/her credentials, skills and experience for a certain job opportunity.
Talent Candidates. We may share personal information of our clients or prospective clients to talent candidates such as when a talent candidate must know information about whom to contact when going on an interview.
Third Parties that You Direct Us to Share With – We share information at your request or direction, such as when we contact individuals that you referred to us. We may also share your information with other third parties as required by applicable law or to those you have consented or directed us to share your information with. For example, if you are a talent candidate, we will share your contact information, resume/CV and job application to our clients in connection with our Services.
Security and Storage. We believe our Services incorporate reasonable safeguards to protect the security, integrity, completeness, accuracy, and privacy of the personal information we have collected. We have put in place reasonable precautions to protect information from loss, misuse, and alteration. However, despite our efforts, please be aware that no security measures are perfect or impenetrable and we cannot guarantee that the information you transmit or provide to us will be completely secure.We will retain your personal information for as long as needed to provide you with our Services (e.g., as long as you have an online account with us) or as needed to fulfill our own obligations, such as preventing fraud, meeting regulatory requirements, resolving disputes, improving our Services or maintaining security, and in each case, as consistent with applicable law. We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.
Children. Our Services are intended for general audiences and is not directed to children under 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information without parental consent, please contact us at email@example.com. If we become aware that a child under 18 has provided us with personal information without parental consent, we will take reasonable steps to remove such information and terminate the child’s account (if applicable).
Your Choices You Have Over How Your Information is Used. In this section, we describe the rights and choices available to all users. California residents have additional rights as set forth below in the section entitled “California Residents: Your California Privacy Rights.”
Review and Update Your Account Information – If you registered for an account with us, you may review, update, or delete certain personal information regarding your account by logging into your account and editing your profile information or contacting us at firstname.lastname@example.org.
Opt Out of Marketing Communications –You may opt out of our outreach and marketing-related emails and direct mail by following the opt-out or unsubscribe instructions located at the bottom of such messages. You may continue to receive service-related and other non-marketing emails and direct mail (e.g., confirmation emails regarding receipt of your resume/CV). If you are a talent candidate and we forwarded your information to our clients in hopes to make a match, our clients may keep your information and may use it in case another job opportunity presents itself. You will need to contact such potential employer to request they delete such information from their database if you do not want to be considered by them for future job opportunities.
Cookies – Most browsers and devices let you remove and/or stop accepting cookies from the websites and mobile applications that you visit. To do this, follow the instructions in your browser’s or device’s settings. Note that disabling cookies and/or other tracking tools may prevent Company or its service providers from providing you certain features of our Services.
Advertising Choices –Your device settings may provide functionality to limit use of advertising ID associated with your device for interest-based advertising purposes. Additionally, you can manage third party advertising preferences for some of the third parties we work with that serve advertising across the internet by using the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices. We do not guarantee that all of the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do.
Privacy Settings and Location Data – Users of our websites and mobile applications can disable our access to their device’s precise geolocation in their electronic device settings.
Choosing Not to Share Your Personal Information – If you do not provide information that we need to render our Services, we may not be able to provide you with such Services or provide you access to certain features of our Services. For example, if talent candidates do not provide us with their professional and employment information, we are unable to assess whether a job match exists with our clients and provide such talent candidate with an opportunity to be hired.
Third Party Platforms or Social Media Networks – We encourage you to review your privacy options and settings of third-party platforms, including without limitation social media platforms and networks, that you use in connection with our Services. We recommend you understand what choices you have about sharing information from those platforms and networks with us.
California Residents: Your California Privacy Rights. California residents have specific rights regarding their personal information as described below. These rights are subject to certain exceptions. When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time.
Right to Know About Personal Information Collected or Disclosed– You have the right under the California Consumer Privacy Act (“CCPA”) to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:The categories of personal information we have collected about you in the last 12 months.The categories of sources for the personal information we have collected about you in the last 12 months.Our business or commercial purpose for collecting that personal information.The categories of third parties with whom we share that personal information.The specific pieces of personal information we collected about you.If we disclosed your personal information to a third party for a business purpose, a list of the type of personal information that each category of recipient received.
Right to Request Deletion of Personal Information – You have the right under the CCPA to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will delete all information that we are not allowed to maintain under applicable law.
How to Exercise the Above Rights. To exercise your rights described above, please submit a verifiable consumer request to us by filling out our request form, emailing us at email@example.com or calling us at (646) 495-3025 You may make a verifiable consumer request no more than two times within a 12-month period. If you submit a verifiable request by email or phone, the verifiable request must:Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Such verification process will involve you confirming details of the personal information we have collected about you, and will increase in scope in the event the nature of your request relates to the disclosure of sensitive personal information or the deletion of any personal information;Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it; andInclude a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know/Delete request has been made.”
Right to Appoint an Authorized Agent – You are also permitted to designate an authorized agent to submit the above requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above method before processing the authorized agent’s request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights – You may exercise your rights under the CCPA without discrimination. However, if you choose not to provide us with certain information, you may not be eligible to utilize most of our Services. For example, we are unable to make a match between a talent candidate and our clients if a talent candidate does not provide us with his/her resume/CV. We will tell you what information you must provide to receive our Services by designating it as required at the time of collection or through other means that we deem appropriate.
Right to Opt Out of Sale of Personal Data – Although we do not sell your personal information that is collected through our Services to third parties for any monetary consideration, under the CCPA, “sale” is broadly defined to mean the sharing of personal information with third parties who are not acting as our service providers or who are otherwise not restricted from using data only on our behalf or pursuant to an applicable CCPA exception. Under the CCPA, “sale” may include us sharing information with our affiliates or allowing third parties who are not “service providers” under the CCPA to “collect” or “receive” certain information, such as your name, email, social media profiles and employment history for our business and legal purposes. If you would like to opt out of our use of your personal information for such purposes that are considered a “sale” under the CCPA, you may do so by following instructions set forth on the webpage entitled: Do Not Sell My Info. You acknowledge that any election to opt out of a sale of personal information in connection with our Service will only cover the personal information obtained through your use of our Service and does not cover the personal information that may be collected outside of our Site from our affiliates or third parties.
Direct Marketing and Do Not Track Signals – Under California’s “Shine the Light” law, California residents may request and obtain a notice once a year about the personal information we shared with other businesses for their own direct marketing purposes. Such a notice will include a list of the categories of personal information that were shared (if any) and the names and addresses of all third parties with which the personal information was shared (if any). The notice will cover the preceding calendar year. To obtain such a notice, please contact us as described below. In addition, under this law you are entitled to be advised how we handle “Do Not Track” browser signals. Company does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, most web browsers (like Safari) allow you to set the DNT signal on your browser so third parties (particularly advertisers) know you do not want to be tracked.
Consumer Rights Information. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints regarding our Site with the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 1625 North Market Blvd., Sacramento, California 95834, by telephone at (916) 445-1254 or (800) 952-5210, or by email to firstname.lastname@example.org.
Nevada Residents: Your Nevada Privacy Rights. Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them. Company does not sell your personal information to third parties as defined in Nevada law, and will not do so without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us via the methods set forth below in the section entitled “How to Contact Us” below.
Geographic Restrictions. We may limit the availability of our websites to any person or geographic area at any time. If you access our websites from outside the United States, you do so at your own risk.OUR WEBSITES ARE INTENDED FOR UNITED STATES RESIDENTS ONLY. IF YOU ARE A USER ACCESSING OUR WEBSITES FROM ANY OTHER COUNTRY WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE AND DISCLOSURE THAT DIFFER FROM THE LAWS OF THE UNITED STATES, PLEASE BE ADVISED THAT THROUGH YOUR CONTINUED USE OF OUR WEBSITES, YOU ARE TRANSMITTING YOUR PERSONAL DATA TO THE UNITED STATES AND YOU CONSENT TO THAT TRANSMISSION. ADDITIONALLY, YOU UNDERSTAND THAT YOUR PERSONAL INFORMATION MAY BE TRANSMITTED TO AND PROCESSED IN COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING PERSONAL INFORMATION MAY BE LESS STRINGENT THAN IN YOUR COUNTRY.