Last Updated: July 12, 2022
Personal data is any information relating to an identified or identifiable natural person. It includes things like email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. These are just examples and there are many other types of information that would be considered personal data.
Because we operate globally, we apply local rules regarding the use and sale of personal data, as well as the choice to receive communications from us and our affiliate companies. This Policy generally describes our collection and use practices, but please review the specific notice below for your geographic area, which provides more specific information regarding our practices and your rights:
We hope you take some time to read through this Policy carefully, because it is important. If there are any terms in this Policy that you do not agree with, please immediately discontinue use of the Platform and our services. If you have any questions or concerns about our collection or use of your information, please contact us at [email protected]
1.Personal data you disclose to us
We collect personal data that you voluntarily provide to us when registering to use the Platform, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Platform or otherwise contacting us.
The personal data that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use. The personal data we collect may include the following:
Name and Contact Data. We collect your first and last name, email address, mailing address, phone number, and other similar contact data.
Credentials. We collect usernames, passwords, password hints, and similar security information used for authentication and account access.
Employment, Resume, CV and other Job Related Data. We collect the employment, resume, CV and other job related data that you submit to us or provide us access to in connection with the Platform.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our third-party payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section “How do we handle your social logins”
All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data.
2.Data automatically collected
We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. This information is primarily used to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes.
3.Data collected from other sources
We and our affiliates generally share personal data with each other so that we can provide our services to you. We also may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties.
Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links). When you choose to, for example, obtain feedback on a resume through one of our third-party marketing partner sites, your contact information and resume will be sent to us.
Our Platform is not directed to minors and we do not intend to collect personal data from children under the age of 18. Therefore, we recommend that parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal data without parental consent. If you believe that we inadvertently have collected personal data about your child, please contact us at [email protected] and we will promptly delete or anonymise this information.
We use personal data collected through our Platform for a variety of business purposes described below. We process your personal data for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We use the information we collect or receive:
To facilitate account creation and logon process. We use information you provide to create an account with us. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below “How do we handle your social logins ” for further information.
To send administrative information to you. We may use your personal data to send you information about products or services you have purchased and/or information about changes to our terms, conditions, and policies.
To fulfill and manage your orders for services. We may use your information to fulfill and manage your orders for services, subscriptions, and payments, and to address any issues with services provided through the Platform.
To post testimonials. We post testimonials on the Platform that may contain personal data. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences. These communications may include information about new products, services, or features. You can opt-out of our marketing emails at any time (see the section “what are your privacy rights” below).
To deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
To request feedback. We may use your information to request feedback and to contact you about your use of our Platform so that we can improve our products and services and develop additional products and services to better serve our users.
To develop our products and services.
We may use your information to further develop our existing products and services or to develop new products and services.
To protect the Platform, us, and others. We may use your information as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.
To enforce our terms, conditions and policies.
We may use your information to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.
To respond to legal requests and comply with applicable law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your information and potentially provide your information in response to the request. We may also need to use your information as needed to comply with applicable laws and regulations.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience.
Yes, your personal will be shared between Talent, Inc. and its affiliates and subsidiaries. In addition, we may share your personal data with the following categories of third-party service providers and marketing partners for one or more of the purposes described above.
*Advertising, direct marketing, and lead generation providers *Chat service providers *Content optimization service providers *Invoice and billing service providers *Social media companies to which you enable access *Social media site advertising *Software service providers that parse and match resumes with job postings *Targeted advertising platforms *Website and application analytics providers *Website hosting providers *Website testing and optimization service providers
In addition, where we believe it necessary or appropriate to do so, we may share your information with: law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive. In those circumstances we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible.
Finally, we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.
We will use the information we receive for the purposes that are described in this Policy. For more information about your rights with respect to this information, please see the section “What are your privacy rights?” below.
We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal data, transmission of personal data to and from the Platform is at your own risk. You should only access the Platform within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at [email protected]
The rights described in this section apply to all users. As noted above, if you reside in a particular state or country, you may have additional rights as required by applicable law. Please see our specific notices for those regions for more information about your specific rights:
Opt Out of Email Marketing
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. Even if you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.
We may update this Policy from time to time. The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible. We encourage you to review the posted Policy frequently to stay informed about how your information is being used.
If you have questions or comments about this Policy, you may contact our Data Protection Officer (DPO) by email at [email protected]
We offer our Platform and services within the European Union and therefore the General Data Protection Regulation (“GDPR”) applies. This notice applies to you if you are resident in the European Economic Area (“EEA”: the countries of the European Union as well as Norway, Liechtenstein and Iceland) (“GDPR notice”).
Therefore, if you are located in the EEA, the general considerations in the Policy and the considerations specifically set out in this GDPR notice will apply. If there is a conflict between the Policy and the GDPR notice and this GDPR notice applies to you, then the GDPR notice will prevail.
If you have any questions or concerns about our collection or use of your information, please contact us at [email protected]
Processors And International Data Transfers
Insofar as third parties process your personal data on our behalf, they do so as processors as defined in the GDPR. In these cases, we are the data controller, as we determine the purposes and means of data processing. We will only engage processors who adequately implement appropriate technical and organisational measures and who guarantee the protection of your rights. In order to ensure this, we enter into data processing agreements with our processors. This is compulsory under the GDPR. The data processing agreement regulates, among other things, data security, confidentiality and your rights.
If your personal data are transferred to ‘third countries’ – i.e., countries outside the EEA – we will only do so if the third country offers an adequate level of protection. In some countries outside the EEA – please, check here – your personal data are sufficiently protected in accordance with European data protection laws and regulations. If this is not the case, we provide appropriate safeguards to ensure adequate data protection. For example, by using the most recent standard contractual clauses as approved by the European Commission and by implementing additional safeguards. If no appropriate safeguards are in place, we will only transfer your personal data if a legal exception applies. An example of a legal exception is explicit consent.
When And How Do We Request Consent?
1. Collecting and sharing your personal data As set out in the Policy, we may collect your personal data from other sources and we may share your personal data with affiliated companies, group companies and subsidiaries, third-party services providers and marketing partners. In these cases and to the extent that the receiving party is not a processor on our behalf, we will only collect or share your personal data if we have obtained your consent. This consent is obtained for example via a consent banner or a cookie banner depending on the receiving party.
2. Marketing purposes
We will not use your electronic contact details for marketing purposes, unless you are our customer or meet another exception under the applicable telecommunications laws. As mentioned in the Policy, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send (this is also called ‘OPT OUT’). If you are not our existing customer, we will ask for your consent to send direct marketing messages (this is also called ‘OPT IN’).
For the underlying processing of your personal data for marketing purposes, we may process your personal data on the basis of our legitimate interest, except when your interests or your fundamental rights and freedoms outweigh our interests. This legal basis is referred to below as ‘legitimate interest’.
3. Special categories of personal data
Our Platform does not intend to collect special categories of personal data, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. However, we cannot fully guarantee that we will not collect such data if you provide it to us (for example, in your resume). We will not use it for purposes other than creating your resume.
Additional Privacy Rights If you are a resident of the EEA, you may invoke a number of privacy rights additional to those mentioned in the Policy, which are the right to review or change the information in your account to make sure it is accurate and up-to-date. The additional rights include:
Right to Erasure. You generally have a right to erasure; however, we may not always erase your personal data because sometimes the processing is still necessary: for example, for complying with statutory obligations or for lodging, exercising or substantiating legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for other legitimate interests. Regarding the deactivation of your account we refer to the information mentioned in the Policy.
Right to Restriction of Processing. Under certain circumstances, you may have us restrict the processing of your personal data. For example, if the accuracy of your personal data are contested.
Notification of Rectification, Deletion or Restriction. Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about rectification, deletion or restriction of processing.
Right to Data Portability. Under certain circumstances, you may request us to transfer your personal data to another party.
Right of Objection. Furthermore, under certain circumstances you may object to the processing of your personal data by us (or third parties engaged by us). For example, you may object to the use of your personal data for marketing purposes.
Right to Withdraw Consent. If we have requested your consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.
Right of Complaint. If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at [insert email]. We will always try to find a solution together. Should this not be possible, you can lodge a complaint with the Dutch Data Protection Authority, or any other competent authority in the European Union, or to take legal action.
How to exercise these rights and what we may need from you?
You can submit your request(s) for exercising these rights to us at [insert email], please provide your name, telephone number, and type of request. To protect your privacy and security, we will take reasonable steps to verify your identity before responding to your request(s). Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal data. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity. This is a security measure to ensure that personal data are not disclosed to someone who has no right to receive it.
We will respond to your request as soon as possible, and no later than one month from receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the law. If a longer period of up to two months is needed, we will inform you within one month of receipt of the request. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive, in particular because of a repetitive character.
Representative In The EEA
If you have questions or comments about this GDPR notice, you may contact our Data Protection Officer (DPO) by email at [email protected] and our representative in the EEA, which is established in the Netherlands: Resume.io // Imkey B.V. [email protected]
This Notice provides more information about specific disclosures and rights we provide to residents of the U.S. in accordance with U.S. law.
Categories of Information Collected
In the 12 months preceding the Last Updated date of this Policy, we have collected or received the following categories of personal information (the “Category” information corresponds to the categories in the California Consumer Privacy Act).
|Category||Types of information collected||Purpose of collection|
|A. Identifiers||Name, mailing address, Internet Protocol (IP) address, email address.||Account registration, fulfilling customer orders for our services, marketing our services, customer service|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, address, telephone number, education, employment, employment history, credit card number, debit card number. (Some personal information included in this category may overlap with other categories.)||Account registration, Fulfilling customer orders for our services, Marketing our services, Customer service|
|C. Characteristics of protected classifications under California or federal law.||Age (40 years or older), race, color, national origin, citizenship, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.||Fulfilling customer orders for our services, Analytics and improvement of our services, Customer service|
|D. Commercial information.||Records of products or services purchased.||Account registration, Fulfilling customer orders for our services, Marketing our services, Customer service|
|E. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Web site optimization, marketing our services|
|F. Geolocation data||Physical location or movements.||Web site personalization, Marketing our services|
|G. Sensory data.||Audio, visual, and electronic information..||Fulfilling customer orders for our services|
|H. Professional or employment-related information.||Current or past job history or performance evaluations.||Fulfilling customer orders for our services, marketing our services, Customer service, Analytics and improvement of our services|
|I. Education information that is not publicly available||Education records such as education history and degrees achieved..||Fulfilling customer orders for our services, marketing our services, Customer service, Analytics and improvement of our services|
|J. Inferences drawn from other personal information.||Profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Marketing our services, Analytics and improvement of our services|
Categories of Information Disclosed
In the 12 months preceding the Last Updated date of this Notice, we have disclosed the following categories of personal information for a business purpose as described above:
Categories of Information “Sold”
We do not sell your personal data for a monetary fee; however, some U.S. privacy laws define a “sale” very broadly such that it may include our sharing of your personal data with certain third parties if we receive anything of value in return. In that regard, we share your personal data with certain third-party marketing partners and in exchange we receive the ability to market or offer our products and services through their websites and applications. This may be considered a “sale” under some laws.
The personal data that may be shared or sold in this context is: your name; email address; other contact information; and information obtained through cookies about, for example, your location, the website that directed you to our Platform, how you navigate our sites, and what purchases you make.
Other than these third-party marketing partners, there are no other third parties to which we will sell your personal data.
Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will update this Policy if that changes in the future.
Additional Privacy Rights
Right to Information.
Subject to certain limits, you may ask us to provide the following information for the 12-month period preceding your request: (1) The categories of personal information we collected about you; (2) The categories of sources from which the personal information was collected; (3) The business or commercial purpose for collecting the personal information; (4) The categories of third parties with whom we shared the personal information; (5) If we disclosed personal information for a business purpose, a list of the disclosures including the personal information categories that each category of recipient received; and (6) The specific pieces of personal information we collected about you. We do not provide these information rights for personal information that we obtain through a business-to-business (B2B) relationship.
Right to Delete
You also have the right to ask us to delete any personal information that we have collected about you, subject to certain limitations. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law.
Right to Opt Out of Sale.
You have the right to opt out of the sale of your personal information. You may exercise this right by clicking on the “Do Not Sell My Personal Information – U.S.” link located at the bottom of our homepage or by submitting a request as described in the “Submission of Requests” section below.
**Right to Nondiscrimination. **
We will not discriminate against you if you exercise your privacy rights under any applicable privacy law, including by:
We are permitted under applicable law to offer you certain financial incentives that can result in different prices, rates, or quality levels, which are related to your personal information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Submission of Requests.
You may submit a request regarding your personal information by:
Calling us at 1-888-884-1491.
Emailing us at [email protected] – please provide your name, telephone number, and type of request (that is, a request for categories of information, a request for specific pieces of information, a request to delete, or a request to opt out the sale of your information).
What We May Need from You.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to someone who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Verifying Your Identity: To protect your privacy and security, we will take reasonable steps to verify your identity before providing your personal information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal information. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity, so that we can help protect your information.
Requests from Authorized Agents: You may designate an authorized agent to make a request for you. If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.
Responses to Requests.
We will confirm receipt of your request within 10 business days of receipt and generally will respond to your request within 45 days of receipt. If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.
No Fee Usually Required.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
© 2022 Talent, Inc.