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Privacy Notice

Your privacy is important to us. This privacy statement explains the personal data TalentQuest collects, how we process it, and for what purposes.

1. Our Commitment to Privacy

Your privacy is important to us. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. This Privacy Notice (“Notice”) applies to TalentQuest, LLC and its subsidiaries (“TalentQuest” or “we,” “our,” or “us”). In this Notice, the words “you” and “your” refer to you, the user of our Services. Employees of TalentQuest should refer to the Employee Privacy Notice. This Notice describes our privacy practices for information that we collect from your interactions with us, including, but not limited to:

  • Use of this website and any other websites owned or controlled by us which reference or link to this Notice (the “Websites”);
  • Use of the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
  • Use or consideration of our products, including but not limited to, our Talent Insights™, Behavioral Assessments, Goals, Performance, Compensation, 360 Surveys, Learning, Succession, Connect, and Analytics (the “Products”);
  • Interacting with our customer service department, connecting with us on social media, posting to our social media pages, and tagging us in your social media posts (collectively, the “Communications”); and
  • Responding to or viewing our advertisements or participating in our surveys, contests, or promotions (the “Participation Opportunities”).

The Websites, the Apps, the Products, the Communications, and the Participation Opportunities are collectively referred to as the “Services.”  This Notice also applies to Personal Information that we receive from business partners or third parties (such as your employer or potential employer). You can find more information about our collection of Personal Information below. Our Services are used by our clients seeking to improve their Talent Management and Development practices (“Employers”), Employees of our clients (“Users”), people visiting the Websites (“Website Visitors”) and people applying for employment with us (“Job Applicants”). By using the Services, you agree to our Terms of Use.

This Notice does not apply to third-party websites accessible through our Websites. This Notice does not apply to any such user generated content and we are not responsible for circumvention of any privacy settings or security measures contained on the Websites with respect thereto. You understand and acknowledge that, even after removal, copies of such user content may remain viewable in cached and archived pages or if other users have copied or stored your user content.

2. Personal Information We Collect

“Personal Information” means any data that identifies you as an individual or relates to an identifiable individual. We obtain Personal Information relating to you at various points in interacting with our Services and from various sources described below.

Information That You Provide To Us

Website Visitors
  • Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers.
 Employers
  • Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers
  • Commercial information such as credit or debit card information, bank account information, and billing information, as well as Apps or Services purchased and/or used.
  • Inferences regarding your marketing and communications preferences, interests, and other characteristics.
  • Audiovisual information such as customer care call or video conference recordings.
 Users
  • Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers
  • Demographic information such as your age, gender, citizenship status, disability status and marital status.
  • Audiovisual information such as customer care call or video conference recordings.
  • Social media information consistent with your account settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, and friend list.
 Job Applicants
  • Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers
  • Demographic information such as your age, gender, citizenship status, disability status and marital status.
  • Employment information such as employment history, current and former employer names and addresses, profession or title/role, employer/employee identification information, expense information, tax and withholding information, and emergency contact information.

Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Services. Usage Information may include:

  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Websites that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
  • Your Device characteristics;
  • Certain other Device data, including the time of day you visit our Websites or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and
  • Statistical information about how both unregistered and registered users, collectively, use the Websites and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

Information Collected from Third Parties

The Websites may include functionality that allows certain kinds of interactions between the Websites and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of our Websites from third parties. These third parties also use cookies and other tracking technologies to capture information about your interactions with us. We do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the Notices of these third parties to understand their privacy practices.

3. Where We Collect Information

  • Registration on our Services – In order to use some of our Services, you must first create a username and password.
  • From Employers (or potential Employers) – We collect contact information (such as full name, address, phone number, and email address). We may use this information to contact you about our Services.
  • Pay for Services – We collect Personal Information from you in order to fulfill your order and your request for Services.
  • Inquire about Our Services or Request Information or Materials from Us – We collect Personal Information from you to respond to your request for a quote or inquiry about our Services.
  • Contact Customer Care Centers – We collect Personal Information from you when you contact us, including when you communicate with us by email, fax or via online chat services or contact customer service. These verbal communications may be recorded for purposes of quality assurance and training.
  • Social Media – We collect Personal Information from you when you choose to participate in our social media activities or offerings. We may also allow you to enter into contests to provide photos which you may share with your connections on social media for votes, shared offers or other promotions.
  • Application for Employment – We collect Personal Information from you when you choose to apply online for employment with us to assess your suitability for employment.

4. How We Use Your Information

TalentQuest may use Personal Information provided to us as follows:

  • To offer and provide our Services and to support our core business functions.
  • To service or fulfill orders, including to communicate with you about our Services, send an order confirmation, register and service your account, and respond to customer service requests related to the Services we provide.
  • To personalize your experience by displaying content based upon your interests.
  • To maintain our customer relationship and provide you with information about or changes to our Websites, our Terms of Use, and/or this Notice.
  • For internal business processes, authentication, loss and fraud prevention, public safety, and legal functions.
  • For direct marketing purposes, including to invite you to participate in contests, giveaways, and promotions; to send you information about our products or service information; and to send you information about new or updated products, or news and information that you have otherwise requested through our newsletter subscription.
  • To conduct research, analysis, and advertising.
  • To invite you to participate in user surveys or to ask for your feedback on the Websites or our products.
  • For internal statistical, marketing, or operational purposes, such as to measure and understand demographic, user, user interest, purchasing, and other trends among our users.
  • To protect the security and integrity of our Websites and business.
  • To investigate, prevent, defend against, or take other action regarding violations of this Notice or our Terms of Use, illegal activities, suspected fraud, or situations involving potential threats to the legal rights of us or others.
  • To comply with applicable laws and regulations.

TalentQuest may collect information about the use of the Websites, such as the types of Services used and how many Website Visitors we receive daily. This information is collected in aggregate form, without identifying any Website Visitor individually. TalentQuest may use this aggregate, non-identifying statistical data for statistical analysis, research, marketing, or similar promotional purposes. In addition, TalentQuest analyzes aggregate data as part of ongoing efforts to validate and enhance our product.

5. Communications From Us

  • Services-related Announcements – We will send you Services-related announcements on occasions when it is necessary to do so. For instance, if you are a participant in a performance appraisal or a 360-feedback survey, we will send you a notification email. In some instances, we may also send you other notification/reminder emails related to the performance management process. Generally, you may not opt-out of these communications, which are not promotional in nature. You may opt out of the 360-feedback process and the emails related to that 360-feedback process by following the opt-out procedure specified in such e-mail. Employers have the option to deactivate User accounts.
  • Customer Service – We will communicate with you in response to your inquiries, to provide the Services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your reasonable instructions.
  • Text Messaging – We may send Services-related text/SMS messages to you if you or your Employer have provided consent. Your Employer can only opt you in to these text messages if you have previously given the Employer consent. Text messaging rates may apply. You can opt out of receiving text messages from us at any time by replying STOP in the messages.

6. How We Disclose Your Personal Information

TalentQuest is not the sole owner of the information collected on TalentQuest. Personal Information of Users submitted to us related to our Services may be shared with an Employer in connection with its use of the TalentQuest Services.

We may disclose Personal Information provided to us as follows:

  • Aggregate Information – We may disclose aggregate data for validity, reliability, and normative research, though in such analyses data will not be identified by individual.
  • Personal Information -We may disclose User Personal Information that you provide to your Employer. We may also share User Personal Information with companies providing services to us or delivering Services on our behalf. This includes the provision of certain Services, like the vendors we partner with that perform behavioral and personality assessments. In such cases, we require these companies to institute safeguards for the protection of your information.
  • Acquisition – If our company or our assets are acquired by another company, the acquiring company will assume responsibility for the information collected by us through the Services and it will assume the rights and obligations regarding the information collected through the Websites, as described in this Notice.
  • Required by Law – We will disclose your Personal Information (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on an enforceable government request or as may be required under applicable law, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

7. Links to Other Sites

Our Websites may contain third-party links, include third-party integrations, or offer a co-branded or third-party branded service (collectively, “Other Links and Sites”). Through these Other Links and Sites, you may be providing information (including Personal Information and other information) directly to the third party (which may include certain Service Providers), us, or both. Because these Other Links and Sites may not be hosted or controlled by us, we are not responsible for the privacy practices of those Other Links and Sites or the content provided thereon.

This Notice does not apply to the information practices of those Other Links and Sites. We encourage you to review the privacy policies of each of those Other Links.

8. Choice/Opt-out

User participation in the Services offered (e.g., performance appraisals, goals management, 360 feedback, selection assessments, succession planning, learning management, connect, compensation management, and any future Services we may offer) is based on your relationship with your Employer. If you are a User you should discuss with your Employer if you decide not to participate in our Services.

For marketing messages, you may unsubscribe from our newsletter by clicking on the unsubscribe button found in the emails at any time or contacting us using the information in the Contact Us section below.

9. Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on our Websites. When visiting our Websites, we maintain data on the Website Visitor’s activities on our servers within a session. This session is uniquely identifiable via a temporary session token. We store this session token in the session cookie.

We use both session ID cookies and/or persistent cookies. We use session cookies to make it easier for you to navigate our Websites. A session ID cookie expires when you close your browser, and does not contain any Personal Information. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. (For more information on cookies, click here)

We set a persistent cookie to store your login id, so you don’t have to enter it more than once.

If you reject cookies, you may still use our Websites, but your ability to use some areas of our Websites may be limited.

These cookies are essential to provide you with Services available through our Websites and to enable you to use some of their features. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those Services.

These cookies allow our Websites to remember choices you make when you use our Websites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Websites.

These cookies collect information about traffic to our Websites and about how individuals use our Websites. The information gathered may include the types of information described above in the section titled “Information automatically collected.” We use this information to help operate our Websites more efficiently, to gather broad demographic information, monitor the level of activity on our Websites, and improve the Websites. We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Websites by downloading and installing the browser plugin available here.

These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our Websites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. Social networks use their own cookies.

These cookies track your browsing habits to enable us and third-party advertising networks to deliver ads that may be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests or browsing behavior. Based on the cookies that the third-party advertising network sets on our Websites and other sites, advertisers can display advertisements that may be relevant to your interests on our Websites and while you are on third party websites. You can choose to disable cookies, as described below, or to opt out of the use of your browsing behavior for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Statement.

Under certain US state laws, collection of data through third-party cookies for targeted advertising and similar purposes may be considered a “sale.” To opt-out of automated sales of Personal Information, please click here.

10. Do Not Track

Some Internet browsers have begun to offer what often is referred to as “do not track” mechanisms for browser users to automatically signal privacy preferences to websites that they visit. Internet browsers have only begun to include these features relatively recently and there is not yet a consensus about what steps a website should take when it receives a do-not-track signal from a site visitor’s browser or what information collection or use restrictions should be applied when a do-not-track signal is received. As a result, our Websites do not currently respond to do-not-track-signals.

We do not authorize third parties, such as advertising networks, to collect personally identifiable information about an individual’s online activities over time and across different websites when the individual uses our Services.

11. Access To Personal Information

If you are a User and your Personal Information changes, you may update it by making the change on your personal profile page or by emailing your Employer administrator. You may access your profile page by clicking the profile link on the TalentQuest Home Page.

Access to Personal Information stored by TalentQuest (such as assessments or 360 feedback reports) is provided at the discretion of your Employer.

12. Security

The security of your Personal Information is important to us. When you enter information, we encrypt that information using secure socket layer technology (SSL). (To learn more about SSL, follow this link)

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

If you have any questions about security on our Websites, you can send an email to us at privacyofficer@talentquest.com.

13. Children’s Privacy

Our Websites are not directed at children under 18 years of age, and we do not knowingly collect or receive Personal Information from them. In limited cases, Employers might use our Services to collect and process Personal Information of children between the ages of 13 and 16, but only with the consent of a parent or guardian. If you are a parent or guardian and believe we may have inadvertently collected Personal Information from your child, please notify us immediately by sending an email to privacyofficer@talentquest.com.

14. International Data Transfers

We operate internationally, and as a result, may transfer Personal Information across international borders, including from the EEA and Canada to the United States for processing and storage and to India for processing depending on the Services you access. Information collected through these Websites may be delivered to servers located in the United States and Canada. By using our Websites, you consent to the transfer of this Personal Information, and to our use of such Personal Information as outlined in this Notice.

We participate in the EU-U.S. Data Privacy Framework (“DPF”) and comply with the DPF Principles. As with other participants in the DPF, we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

When we transfer Personal Information to a third party acting as an agent, we ensure that that we (i) transfer such information only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Information transferred in a manner consistent with our obligations under the Principles; (iv) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the U.S. Department of Commerce upon request.

If you are located in the European Economic Area, please visit our EU-U.S. Data Privacy Framework Notice to learn about your rights with respect to Personal Information.

For more information about the EU-U.S. Data Privacy Framework, visit https://www.dataprivacyframework.gov.

15. Retention of Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

16. Your California Privacy Rights

This section of our Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information we have collected about you;
  • The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
  • The categories of Personal Information about you that we disclosed for a business purpose.
  • The categories of sensitive Personal Information to be collected and the purposes for which the categories of sensitive Personal Information are collected or used and whether such information is sold or shared.

Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Right to Correct Personal Information

You have the right to request that we correct any inaccurate information that we maintain about you.

Right to Opt-Out

You have the right to opt out of the sale or sharing of Personal Information. The term “sale” as used under the CCPA may be different in scope than you imagine. For example, it may include the sharing of information in exchange for anything of value, which is not limited to the exchange of money. Additionally, certain conduct is not considered a sale, such as when Personal Information is shared with a service provider that is contractually prohibited from using the Personal Information for any purpose beyond the service specifically request.

We may disclose certain categories of information that we collect about you to third parties. This may include the use of third party analytical cookies or other technology that may be considered “sales” under the CCPA. Under the CCPA, if you are a resident of California, you have the right to opt out of such sales by clicking the “Do Not Sell My Personal Information” link in the footer of this page.

We are also required to process global privacy controls, which are opt-out preference signals initiated by the individual at the browser level. For more information about Global Privacy Controls, please visit here.

Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Residents can revoke this permission at any time. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you.

Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

  • Denying you goods or services;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of goods or services; or
  • Suggesting that you will receive a different price or rate for goods or service or a different level or quality of goods or services.

This includes the right of current and prospective employees not to be retaliated against for the exercise of their CCPA rights.

However, as permitted by the CCPA, we may offer you certain financial incentives. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may withdraw at any time.

Personal Information that We Collect

Here is a summary of how we have collected, Personal Information within the last 12 months.

Category of Personal Information Examples of this Category Sources of Personal Information Business Purpose for Collection
Identifiers Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. You

Automatically

Third Parties

To provide our Services

To provide information you requested

To improve our Services

To identify potential customers

To market our Services

To verify identity

To prevent fraud

To process payments

To comply with law

To offer employment, to provide insurance and benefits, for background checks

Personal information described in California Civ. Code § 1798.80(e) Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. You

Automatically

Third Parties

To provide our Services

To provide information you requested

To improve our Services

To identify potential customers

To market our Services

To verify identity

To prevent fraud

To process payments

To comply with law

To manage payroll and provide and administer employee benefits

Characteristics of protected classifications under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking. You

Third Parties

To provide our Services to customers

To improve our Services

To offer employment, to provide insurance and benefits, for background checks

To comply with law

Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. You

Automatically

To provide our Services

To market our Services

To improve our Services

To provide information you requested

To comply with law

Biometric information An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns that can be used to establish individual identity, including images of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information. N/A N/A
Internet or other electronic network activity information Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Automatically To provide our services

To market our services

To improve our services (e.g., usage pattern data)

To track employee actions for internal reports and information security purposes

Geolocation data Physical location and/or movements. You

Automatically

Third Parties

To market our services

To detect security incidents and protect our Websites

Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. N/A N/A
Professional or employment related information Current or past job history or performance evaluations You To provide our Services

 

To offer employment, to provide insurance and benefits, for background checks

Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. N/A N/A
Inferences drawn from other Personal Information Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. You

Automatically

Third Parties

To provide our services

To market our services

To improve our services

To detect security incidents and protect our Websites

Sensitive Personal Information Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data You To provide our Services

To provide information you requested

To improve our Services

To identify potential customers

To market our Services

To verify identity

To prevent fraud

To process payments

To comply with law

To manage payroll and provide and administer employee benefits

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Information related to how long we retain each category of Personal Information collected is included in the Retention of Personal Information section above.

Personal Information that We Disclose

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the last 12 months, we have disclosed the following categories of Personal Information for a business purpose:

Category of Personal Information Recipient Categories Business Purpose for Disclosure
Identifiers Service Providers Auditing related to ad impressions

Helping to ensure the security and integrity of Personal Information

Debugging to identify and repair errors

Short-term transient use

Performing services on behalf of the business

Providing advertising and marketing services (other than cross-context behavioral advertising)

Internal research for technological development and demonstration

Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Personal information described in California Civ. Code § 1798.80(e) Service Providers Helping to ensure the security and integrity of Personal Information

Debugging to identify and repair errors

Short-term transient use

Performing services on behalf of the business

Internal research for technological development and demonstration

Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Characteristics of protected classifications under California or federal law Service Providers Helping to ensure the security and integrity of Personal Information

Debugging to identify and repair errors

Short-term transient use

Performing services on behalf of the business

Internal research for technological development and demonstration

Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Commercial information Service Providers Auditing related to ad impressions

Helping to ensure the security and integrity of Personal Information

Debugging to identify and repair errors

Short-term transient use

Performing services on behalf of the business

Internal research for technological development and demonstration

Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Biometric information N/A N/A
Internet or other electronic network activity information Service Providers Helping to ensure the security and integrity of Personal Information

Debugging to identify and repair errors

Short-term transient use

Performing services on behalf of the business

Internal research for technological development and demonstration

Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Geolocation data N/A N/A
Sensory data N/A N/A
Professional or employment-related information N/A N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) N/A N/A
Inferences drawn from other Personal Information N/A N/A
Sensitive Personal Information Service Providers Helping to ensure the security and integrity of Personal Information

Debugging to identify and repair errors

Performing services on behalf of the business

Internal research for technological development and demonstration

Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

Personal Information that We Sell or Share

In the last 12 months, we have sold/shared Personal Information as follows:

Category of Personal Information Recipient Categories Purpose for Sale/Sharing
Identifiers Advertising, marketing, and analytics providers

Suppliers

Marketing
Personal information described in California Civ. Code § 1798.80(e) N/A N/A
Characteristics of protected classifications under California or federal law N/A N/A
Commercial information Advertising, marketing, and analytics providers

Suppliers

Biometric information N/A N/A
Internet or other electronic network activity information Advertising, marketing, and analytics providers Marketing and analytics
Geolocation data N/A N/A
Sensory data N/A N/A
Professional or employment-related information N/A N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) N/A N/A
Inferences drawn from other Personal Information Advertising, marketing, and analytics providers Marketing and analytics
Sensitive Personal Information N/A N/A

Exercising Your California Privacy Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Emailing us at privacyofficer@talentquest.com, or

Calling us at 1-888-995-5983

Visiting our Privacy rights request page

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child, to the limited extent we have information related to minors. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 calendar days if we are able to verify your identity or let you know if we need additional time. Requests for deletion will require a separate confirmation that you want your information deleted.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer 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.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us using the information in the Contact Us section below.

17. Your Rights Under Other US Laws

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

  • To confirm whether or not a controller is processing your personal data and to access such personal data;
  • To correct inaccuracies in your personal data;
  • To delete your personal data;
  • To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
  • To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
  • Not to discriminate against you because you have exercised any of these rights, including by:
    • denying you Services;
    • charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
    • providing you a different level or quality of Services; and/or
    • suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using this webform or contacting us using the information in the Contact Us section below.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

Right to Opt Out

You may have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please click the “Do Not Sell My Personal Information” link in the footer of the webpage where your information is being collected.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

18. EU Data Subjects

This section of our Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopted this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section.

Depending on who you are in relation to us, we are considered either the “data controller” or the “data processor” of the Personal Information we handle under this Notice. For instance, we are considered a data controller for Website Visitors and Job Applicants, and a data processor for Users and Employers.

We hope to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

  • The right to access, update or delete the information we have collected from you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us using the information in the Contact Us section below.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Information.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

  • Contract: To conclude or perform a contract with you; for example:
    • To manage and fulfill orders, facilitate delivery, and to provide other Services;
    • To manage our accounts and records;
    • To handle your inquiries and requests;
    • When you apply for employment through our Websites, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Websites.
  • Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
    • To respond to your customer service inquiries and requests for information;
    • To maintain, improve, and analyze our Websites and Services we offer;
    • To conduct marketing activities;
    • To detect, prevent, or investigate security breaches or fraud; and
    • To facilitate the functionality of our Websites;
  • Legal Compliance: To comply with our legal obligations; for example:
    • To maintain appropriate records for internal administrative purposes and as required by applicable law, and
    • To provide important product safety information and notice of product recalls
  • Consent: We will send you marketing communications by email about our Services or other promotions only with your consent or if you otherwise opt-in to receiving those If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent to these communications at any time as described below. However, you might still receive transactional or account-related messages from us.

Exercising Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the information below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:

EU Representative

We have nominated ePrivacy GmbH as our GDPR representative in the European Union and they can be contacted at:

ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

https://www.eprivacy.eu

19. Your Rights Under the UK GDPR

If you are based in the United Kingdom, the following provisions also apply:

If we share your personal data within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

If you are a resident of the UK and have any questions about this section or to make a request, please contact us at:

UK Representative Service for GDPR Ltd.
7 Savoy Court
London WC2R 0EX
United Kingdom

https://www.eprivacy.eu/en/legal

20. Individual With Disabilities

If you have a disability and need access to this Notice in a different format, please contact us at privacyofficer@talentquest.com.

21. Changes In This Notice

If we decide to change our Notice, we will post those changes to this Notice and any other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this Notice at any time, so please review it frequently. If we make material changes to this Notice, we will notify you here, by email, or by means of a notice on our home page.

22. Contact Us

Last Updated: November 7, 2023

If you have any questions or suggestions regarding our Notice, please contact us at:

Email: privacyofficer@talentquest.com
Phone: 404.266.9368

Mailing Address:
TalentQuest
2400 Riverstone Blvd. #4277
Canton, GA 30114

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