This Notice was last revised on March 31, 2019. Please check this Notice frequently for any changes or modifications. If there are changes which are material in nature, they will be posted in this Notice in a timely manner.
IMPORTANT: CONSENT AND COMPLIANCE WITH THIS NOTICE IS A CONDITION OF YOUR USE OF OUR SITE(S) OR ANY PORTION(S) THEREOF, OR ANY SERVICES WE PROVIDE, FROM WHEREVER YOU ARE AND USING WHATEVER DEVICE OR MEANS YOU ARE USING.
PLEASE READ THIS NOTICE CAREFULLY AND PRINT IT FOR YOUR RECORD.
Cookies, Activity Log data in Analytics
By using our website or any technology services provided to you directly or through a third-party vendor (collectively referred to as “Technology”), you acknowledge that you are at least 13 years of age. You agree not to use our Technology in any unlawful manner. Without limitation, you agree not to:
1. Collect any information (including, but not limited to, contact information) from our Technology by electronic or other means, or using automated scripts, or through any other means through interacting with the Site or our Services;
2. Damage, disable, overburden or impair our Technology;
3. Allow any third party to copy, modify, create derivative work from, or attempt to do such with respect to any legal right in or element of the Technology;
4. Reselling or making commercial use of contents outside the permitted use; or
5. Solicit for information to be used for commercial or unlawful purposes.
Privacy and Data Security
By using our Technology, you agree not to upload, post, transmit, share, store or otherwise make available
1. any content that we deem to be harmful, threatening, unlawful, defamatory, infringing, abusive, inflammatory, harassing, vulgar, obscene, fraudulent, invasive of privacy or publicity rights, hateful, or discriminatory in any way, or is otherwise considered objectionable, or
2. anything that would constitute as encouraging or providing instruction for criminal activities that would otherwise create liability or violate any local, state, federal, or international law (including but not limited to Section 219 of the Immigration and Nationality Act);
3. any unsolicited or unauthorized advertising, solicitation, promotion, “junk mail,” “spam,” “pyramid schemes,” or any similar solicitation, or
4. any material that contains software virus, malware, or any other dangerous or harmful computer code, file, or program, or
5. any private or protected information such as address, phone number, email address, Social Security number, and/or credit card number;
6. misrepresent yourself, your age, affiliation with any Person or entity, impersonate any Person or entity, or use or attempt to use another Person’s account, or creating a false identity for any reason.
Pursuant to 47 U.S.C. Section 230 (d), as amended, we hereby notify you that parental control protections (such as computer hardware, software or filtering services) are commercially available that may assist you in limiting access to material that is harmful to minors.
We make no representation that products or services available through the Technology are appropriate or available for use in locations other than the United States of America. Those who choose to access the Technology from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent local laws are applicable.
You agree to comply with all applicable laws regarding the transmission of technical data exported from the United States and/or the country in which you reside.
WE RESERVE THE RIGHT TO LIMIT THE AVAILABILITY OF THE TECHNOLOGY DESCRIBED HEREIN TO ANY PERSON, GEOGRAPHIC AREA OR JURISDICTION, AT ANY TIME AND IN OUR SOLE DISCRETION.
Adopted March 31, 2019
PLEASE READ THIS CAREFULLY. THIS DOCUMENT IS LEGALLY BINDING AND IMPACTS YOUR RIGHTS.
The Kind of PII Collected
In the course of the Company’s operations, types of PII may be collected include, but are not limited to:
1. Personal characteristics such as gender and place of birth;
2. Contact information such as name, address, phone/mobile number, email address;
3. Prior professional and academic data such as résumé, CV, education and work history;
4. Current professional data;
5. Various personality or performance reports;
6. Other information gathered from voluntary participation in programs and/or services.
How PII Is Used
The Company may use collected PII for legitimate business purposes, including, but not limited to reporting and investigative consulting services provided by the Company, including processing of the PII by a third-party vendor for legitimate business purposes.
How Is PII Shared
It is presumed that consent is given to the Company for legitimate programs/services rendered at the time of any voluntary disclosure of PII.
The Company will only share PII with those who have a legitimate business interest to know. Under certain circumstances, the Company may be compelled to disclose PII for law enforcement purposes (see below).
The Company may share information with any third-party vendors (“Third Parties”) who perform the Company’s business operations on our behalf. The Company requires that Third Parties provide equivalent levels of protection as applied by the Company when handling PII. When necessary, the Company will contractually require data processors solely in accordance with our instructions and to use appropriate administrative, technical, and physical security methods to protect such data. Third Parties may not otherwise use or disclose the information, except as authorized by the Company, and/or to comply with legal requirements.
Consistent with the Company’s legitimate business interest, informed consent, the Company’s legal obligations, and/or to comply with the Company’s contractual obligations, the Company will inform affected client/customers about PII that has been collected and how it will be used.
We may also disclose PII to respond to required legal processes; to enforce or protect the rights and policies of the Company; or to assist in the investigation of suspected or actual illegal activity. We may also share PII in the context of a business transaction involving part or all of the Company’s business operations, such as a merger or acquisition. Following such a business transaction, you may contact the entity to which we transferred your PII with any inquiries concerning the use of that information.
Subject of an investigative inquiry may have the right to contact the Company and/or its Client and request to access the PII obtained about the subject; or may request that inaccurate, outdated or no longer necessary information be corrected, erased or restricted. The Company will make good faith effort to comply where required by applicable law(s). Where the processing of PII is based on consent, the subject of investigation may have the right to withdraw such consent.
Certain types of data are more sensitive than others. Certain information may be labelled as “Sensitive Personal Information” or “SPI” to comply with a specific country/region’s laws. The Company defines SPI as any information relating to an identifiable person that includes or implies race, ethnicity, political views, religion, health, sexual orientation, genetic or biometric data, and information about criminal convictions and offenses. The only permitted use of SPI is Company-related as required for business purposes (i.e., providing a Client with the Information and compiling end products under the Company’s Agreement with the Client). Given the above, the Company will only process SPI at the Client’s request documented in writing.
Any offering and use of PII shall observe and comply with all applicable laws, privacy legislation and any other legal requirements. Client is also responsible to provide accurate and truthful information; the Company is not obligated to update or correct any mistakes unless the Client specifically request such action be taken with good cause stated in writing and additional consideration are agreed by Company.
Records and Safeguards
The Company keeps PII for as long as necessary to fulfill business-related purposes, unless a longer retention period is required or permitted by applicable law. In some cases, we may need to retain PII for a period after the termination of Client’s relationship with the Company in order to comply with legal or contractual obligations.
The Company has implemented appropriate basic physical, administrative and technical measures, such as access controls, designed to protect PII against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, access or use, and all other unlawful forms of processing. For more information, please seen our Security Policy below.
Where applicable, the Company has implemented the following in an effort to comply with the most recent European Union data privacy regulations:
1. pseudonymization and encryption of PII;
2. ongoing scanning and monitoring of confidentiality, integrity, availability and resilience of cloud and in-office processing systems and services;
3. backups of PII in the event of a physical or technical incident; and
4. regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
The Company reserves the right to modify this Policy as needed, for example, to comply with changes in laws, regulations, Company practices and procedures, or to respond to new threats or new requirements imposed by data protection authorities. Where such changes materially affect our processing of PII, we will notify our clients accordingly.
Breach and Notification(s)
Where there is a breach of any PII, the Company will make its best effort to notify the affected party/parties, any business associates, regulatory agencies, or any other required entity without undue delay in order to carry out data protection impact assessments as well as any necessary mitigating measures.