Last updated December 27, 2022
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 natural 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 Automatically Collect From You
We collect this information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. These technologies allow us to provide, protect, and improve our products and services, such as by personalizing content, understanding user behavior, and offering a safer experience. We also use these technologies to provide you with personalized advertisements, including on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.
Use of Information
- 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 personal information under the following circumstances:
- We may share your personal information within our organization, including to our affiliates.
- We may disclose your personal information to service providers, including our subcontractors, agents and any person who provides professional, legal, tax or accounting advice or other services to us in order to provide a better service and user experience. All such service providers are required to maintain the confidentiality of such personal information to the extent they receive it. We may share your personal information with our vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your personal information.
- 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.
- If we or any of our affiliates are involved in a potential or actual transaction of merger, division, liquidation, acquisition or sale of assets or business, your personal information may be disclosed in connection with the transaction.
- We may disclose your personal information with notice to you and your consent
- We may disclose your personal information where you direct us to disclose the information.
Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.
International Transfer of Information
Where your personal information is transferred outside of your jurisdiction, we will take measures to ensure that the transfer is subject to appropriate safety measures (which may be contractual in nature) in accordance with applicable data protection laws, such as through standard contractual clauses.
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 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 personal 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 personal information you send by these methods in transit. We will have no liability for disclosure of your personal 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 personal 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 personal 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 personal information, please contact [email protected]
You have a right to contact the data protection regulator in the EU Member State where you live or work if you think a breach of your personal information has taken place.
Processing of Personal Information of Citizens of Armenia
- Right to be informed: The right to know what personal information we process about you and to whom your personal data may be transferred;
- Right of access: The right to be aware of and verify the lawfulness of the processing of your data;
- Right to rectification and to be forgotten: The right to require we rectify, block, or destroy your personal data;
- Right to decline: The right to withdraw your valid consent to the processing of your data if you find out the processing of your data violates applicable law or your basic rights and freedoms;
- Right to appeal actions or inaction of processor: Where you consider the processing of your personal data is carried out in violation of the requirements of the applicable legislation or otherwise violates your rights and freedoms, you shall have the right to appeal our actions or inaction before an authorized state body.
To exercise any of these rights, or if you have any other questions about our use of your personal information, please contact [email protected].
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.
Processing of Personal Information in China
Notice to California Residents
The notice below is provided to California, U.S.A residents who are users of the Website or Services. Depending on the nature of your interaction with us, the following categories of personal information may be, or may have been within the last 12 months, collected:
|Category||Examples of personal information we may collect|
|A. Identifiers.||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 sex, sexual orientation, gender identity 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.||None.|
|E. Biometric information.||None.|
|F. Internet or other similar network activity.||Information on a Consumer’s interaction with the Website or Services.|
|G. Geolocation data.||IP address, country/region of residence.|
|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.|
|L. Communications.||Information you email, submit, or post. This may contain personal information about you such as personal identifiers and professional or employment history.
Information from various sources including, but not limited to, social networks and forums.
From job applicants or contractors we may collect personal information that is also considered “sensitive personal information” under the CCPA. That sensitive personal information may include:
- Social security, driver’s license, or passport numbers
- Information concerning your health
- Information about racial or ethnic origin, sex, sexual orientation, or union membership
- Biometric information
We use sensitive personal information for lawful purposes in compliance with the CCPA and do not use sensitive personal information collected in the context of employment or an application for employment to infer characteristics about employees.
We collect and use this personal information for the business and commercial purposes set out in the “Use of Information” section above. We disclose this personal information to the categories of persons set out in the “How We Share Information” section above.
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale ” as that term is defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value. We may collect or sell the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. The categories of third parties to whom we may sell your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising.
Subject to certain limitations, under the CCPA, if you are a Consumer, you have the right to know certain details about our data practices. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of persons to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
You also have the right to delete the personal information we have collected from you.
If you would like to make a request and exercise your rights described above, please reach out to [email protected]. If you have an account with us, we may require you to use the account to submit the request. We will confirm receipt of your request within 10 business days. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
In addition, you have the following rights:
- Effective January 1, 2023, right to correction: The right to have inaccurate or incomplete personal information about you rectified.
- Right to limit use and disclosure of sensitive personal information in some circumstances.
- Right to Opt-Out of the Sale of your personal information. You have the right to opt-out of the sale of your personal information by us. You may exercise this right by emailing us at [email protected] and specifying you wish to opt-out.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
- Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf by us with a copy of your power-of-attorney document granting that right.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such personal information. To exercise a request, please write us at the address set out in “Contact Us” below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.