Last updated January 1, 2020
Information we collect
In order to make your visits to the Website and your use of the Services as worthwhile as possible, we may ask you for certain personal information and we may collect certain information from your computer when you visit us.
Information that you provide to us
We collect personal information from users of the Website and persons who register to use the Services on the Website and/or submit information or materials on the Website, including, for example, when users apply for employment positions on the Website, submit resumes or other information or materials on or through the Website or the Services, send us an e-mail, or in any other way submit personal information to us via the Website.
The personal information we may collect from you includes:
- Contact information you provide to us (such as name, postal address, e-mail address and telephone and/or mobile phone numbers);
- Information contained in your resume and cover letter if you choose to submit it to us via the Website; and
- Other information you may provide to us through the “Contact Us” or similar features.
Information we collect or generate about you
Cookies and Related Technologies
When you use the Website and/or the Services, we may collect certain information by automated or electronic means, using cookies.
Use of Information
When using your personal information, we make sure that the usage complies with applicable law. These uses include:
- the use of your personal information as described herein for our legitimate business interests;
- the use of your personal information in order to comply with applicable law and regulations;
- the use of your personal information in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
- the use of your personal information to the extent we have obtained your consent.
More specifically, we may use your personal information for the following legitimate business interests:
- to operate, maintain or improve the Website, the Services or our business;
- to contact you or respond to your requests or inquiries;
- to consider you for employment or business opportunities;
- to support auditing, legal or compliance functions;
- to provide our products and services;
- to create and manage online accounts;
- to send promotional materials, alerts and other communications, which may be through the Website or outside of the Website, such as via e-mail or through third party websites and/or apps;
- to optimize the Website and/or Services and understand usage patterns and user behavior;
- to communicate about, and administer participation in, special events; promotions, programs, offers, surveys, contests and market research; and/or
- to maintain our internal records.
How We Share Information
We may share your information within our organization, with our third party business partners, business associates, or subcontractors, and/or with other third parties for the purposes set out below:
- Within our organization and to our third party service providers: We may disclose your personal information to third parties, including our affiliates, subcontractors, agents and any person who provides professional, legal, tax or accounting advice or other services to us. All such third parties are required to maintain the security of such information to the extent they receive it.
- Potential buyers, transferees, merger partners or sellers: We may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers in connection with any actual or potential transfer or merger, sale, acquisition, assignment, transfer, or other disposition of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
- Legal reasons: We may disclose your personal information or any portions thereof: (a) as required by, or to comply with, applicable law, regulation, court process or other statutory requirement or to enforce our legal rights or agreements with you or others; (b) to respond to requests from any regulatory, supervisory or governmental authorities; or (c) where we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website or Services, or anyone else that could be harmed by such activities.
International Transfer of Information
Where your information is transferred outside of your jurisdiction, care is taken to ensure that the transfer is subject to appropriate safety measures (which may be contractual in nature) in accordance with applicable data protection laws.
In particular, where we transfer your personal information from within the EU to another country outside the European Economic Area (the EEA), we will ensure that it is transferred in a manner consistent with legal requirements in one of the following ways:
- the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to otherwise transfer your personal information outside the EEA.
You can obtain more details about these safety measures by contacting us at [email protected]
Right to Opt In and Opt Out
You may have the right to "opt in" and "opt out" of certain of our uses of your personal information. For example, at the time you are requested to provide personal information (for example, when you fill out an online application), you may have the opportunity to elect not to have your personal information shared with other entities for marketing purposes. You can also make such requests by sending an e-mail to [email protected].
We take the protection of your personal information seriously, and have security measures, controls and policies in place. We will hold your personal information on our systems for the longest of the following periods: (a) as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us; (b) the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations; (c) any retention period that is required by law; or (d) the end of the period in which litigation or investigations might arise in respect of your use of our Website and/or the Services that we provide to you.
We utilize security measures appropriate to the provision of the Website and/or Services, such as reasonable administrative, technical, personnel, and physical measures designed to: (a) safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) ensure the integrity of personal information. However, while we will endeavor to protect the security and integrity of your personal information, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information will be absolutely safe from intrusion by others, such as hackers, during transmission through the Internet or while stored on our systems or otherwise in our care.
If you contact us by e-mail or the "Contact Us" or similar feature on the Website and/or the Services, you should be aware that your transmission mechanism might not be secure. A third party could view information you send by these methods in transit. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission by you.
Privacy Policies of Third Party Websites
We do not collect or maintain information from anyone known to be under the age of 13, and no part of the Website or Services is designed to attract anyone under the age of 13. You must be over the age of 18 in order to sign up for the Services.
Accessing, Reviewing, Updating and Modifying Personal Information
You have the right to access, review, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access to, updates to and corrections of inaccuracies in your personal information by e-mailing to us as set forth under “Contact Us” below. We may request certain personal information for the purposes of verifying the identity of the individual seeking to access or update their personal information records.
Processing of Personal Information in the European Union
- Right of subject access: The right to make a written request for details of personal information about you held by us and a copy of that personal data;
- Right to rectification: The right to have inaccurate or incomplete information about you rectified;
- Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled or required to retain it;
- Right to object to, or request that we restrict, our processing: Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
- Right to data portability: In some circumstances, the right to ask for personal information you have made available to us to be transferred to you or a third party in machine-readable formats where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to us; and
- Right to withdraw: Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation.
These rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
To exercise any of these rights, or if you have any other questions about our use of your information, please contact [email protected]
You have a right to complain to the data protection regulator in the EU Member State where you live or work or where you think a breach of your personal information has taken place.
Processing Of Personal Data of the Citizens of the Russian Federation
If you are our employee (or consultant) and a citizen of the Russian Federation (“RF”), please be informed that we process your personal information in full accordance with the RF applicable data protection laws, including Federal Law No. 152-FZ "On Processing Personal Data", dated 27.07.2006 (as amended). We procure that while collecting your personal information through the Website, we confirm that the recording, systematizing, accumulating, storage, adjustment (updating, amending), extracting of personal information of the RF citizens is being performed with the use of databases located in the RF as required by Federal Law No. 242-FZ "On Amending Certain Laws of the Russian Federation with regard to the Procedure for Personal Data Processing in Information-Telecommunications Networks", dated 21.07.2014. We further ensure that the cross-border transfer of personal information of the RF citizens is made in accordance with the RF applicable data protection laws. When you register for use of or use in any capability, a software or service that may be made available through the Website, you agree with our processing of your personal information and transmission (including cross-border transfer) to other jurisdictions, including those that do not provide adequate protection of personal information as provided by the RF applicable laws.
Обработка Персональных Данных Граждан Российской Федерации
Если Вы являетесь нашим работником (или консультантом) и гражданином Российской Федерации («РФ»), пожалуйста, примите во внимание, что обработка Ваших Персональных Данных осуществляется нами в строгом соответствии с применимыми законами РФ в сфере защиты персональных данных, в том числе, Федеральным законом № 152-ФЗ «О персональных данных» от 27.07.2006 (с изменениями и дополнениями). Мы обеспечиваем, что при сборе Персональных Данных запись, систематизация, накопление, хранение, уточнение (обновление, изменение), извлечение персональных данных граждан РФ осуществляется с использованием баз данных, находящихся на территории РФ, в соответствие с требованиями Федерального закона от 21.07.2014 N 242-ФЗ "О внесении изменений в отдельные законодательные акты Российской Федерации в части уточнения порядка обработки персональных данных в информационно-телекоммуникационных сетях". Мы гарантируем, что трансграничная передача Персональных Данных граждан РФ также осуществляется в соответствие с применимыми законами РФ в сфере защиты персональных данных. Когда Вы регистрируетесь на Веб-сайте или используете возможности, сервисы, программное обеспечение, которое может быть доступно через Веб-сайт, тем самым Вы соглашаетесь с тем, что мы обрабатываем Ваши Персональные Данные и осуществляем их передачу (включая трансграничную передачу) их в другие страны, в том числе, страны, не обеспечивающие адекватную защиту Персональных Данных, как предусмотрено законодательством РФ.
Notice to California Residents
Examples of personal information we may collect
A real name, alias, postal address, email address, Social Security number, driver's license number, passport number, or other similar identifiers. Also may include references’ contact information (which the Consumer must obtain consent for before providing to us).
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, as provided in an email, resume, cover letter or background check application.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Information about Consumer’s visa status and authorization to work in the relevant jurisdiction, demographic information including age and gender, and where applicable and in accordance with applicable law, ethnicity, disability or veteran status. With Consumer’s permission or as permitted by applicable law, information obtained through background checks.
D. Commercial information.
E. Biometric information.
F. Internet or other similar network activity.
Information on a Consumer's interaction with the Website or Services.
G. Geolocation data.
H. Sensory data.
Audio, electronic, visual, and similar information, such as images and audio, including CCTV footage.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, or student disciplinary records, as related to the application or recruitment process.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, attitudes, intelligence, skills, abilities, interests and aptitudes as related to the application or recruitment process.