If you are under 13 years of age, please do not use our Sites or Services and do not send us any information about yourself.
If you are a California resident, you may have additional rights as described below in the section entitled “CALIFORNIA PRIVACY RIGHTS.”
If you are outside the United States, by using our Sites or Services or by providing your information to us, you are consenting to having your Personal Information transferred to and stored in the United States. Specific additional rights may apply where required by applicable law.
INFORMATION WE COLLECT
We collect certain information that identifies, relates to, describes, and is reasonably capable of being associated with a particular consumer, household, or device (“Personal Information”). Personal Information does not include publicly available information in government records or de-identified, anonymized, or aggregated consumer information.
We collect Personal Information and other information from or about you in a few different ways. Specifically, we may collect or receive information: (1) directly from you through information you provide; (2) indirectly from you by observing your actions on our website; and (3) from third parties such as Facebook, Instagram, Glassdoor, ADP, Calendly, Listrak, ADP, Reach/HRIS, SABA/Halogen and LinkedIn. Each of these is discussed in more detail below.
INFORMATION YOU PROVIDE
You may provide information to us in a number of ways.
When you contact us, the email address and/or telephone number you use to communicate with us generally will be collected and any additional information you provide may also be collected.
If you post information on our social media pages, that information may be collected and used by us (as well as other users of those sites and the public generally). Please do not post any information on any site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
When you submit a resume or application for employment, any information you provide will be collected and we may also obtain additional information through references, former employers, background checks, and credit reports.
Please note that, if you are visiting our website from a location outside of the United States, you will be connected through and to servers located in the United States. All information you provide will be maintained in our web server(s) and internal systems located in the United States. We do not transfer or store Personal Information outside the United States unless it is required for the provision of services to our clients or required by a governing authority.
INFORMATION INDIRECTLY COLLECTED FROM YOU
Cookies and Other Technologies. We automatically collect information from you using cookies and other technologies on our website.
We use three primary types of cookies:
Functional Cookies – These cookies support the use of the website and enable certain features to enhance your experience. For example, functional cookies remember your selections as you move from page to page.
Performance Cookies – These cookies collect information needed to support the website and our applications and allow us to identify problems and improve the website – for example, performance cookies may provide us with information about how you came to our website and how you navigate through our website.
Targeting Cookies – These cookies may be used to collect information from you to help us improve our products and services and to serve you with targeted advertisements that we believe are relevant for you.
Clear GIFs (a.k.a. web beacons, web bugs or pixel tags), are tiny graphics with a unique identifier, similar in function to cookies. Clear GIFs are embedded invisibly on web pages. We may use clear GIFs, in connection with our website to, among other things, track the activities of visitors, help us manage content, and compile statistics about usage of the website. We and our third-party service providers also use clear GIFs in HTML emails to our client, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
“Do Not Track” is a privacy setting that users can set in certain web browsers. If turned on, these settings request that website not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals.
Traffic Data. We automatically track and collect general log information when you visit our website, including your: (a) Internet Protocol (IP) address; (b) domain server; (c) operating system; and (d) type of web browser; and (e) the pages you visit on our website (collectively “Traffic Data“). Traffic Data does not personally identify you. We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of our website. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and clear GIFs (Graphics Interchange Format, a software technology also known as a pixel tag).
INFORMATION FROM THIRD PARTIES
Social Media Sites. To the extent you post information on our social media sites, we may collect such information. We may also receive Personal Information about you through our business relationships with certain social media sites such as Twitter, Facebook, Instagram, and LinkedIn.
CATEGORIES OF INFORMATION COLLECTED
In the 12 months preceding the Last Updated date of this Policy, we have collected or received the following categories of Personal Information about consumers:
Category, examples, and if it’s collected:
- A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, education, employment. Some personal information included in this category may overlap with other categories.
- Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
- Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information. Genetic, physiological, behavioral, and biological characteristics, such as DNA sequences, fingerprints, facial geometry, voiceprints, iris or retina scans, and sleep, health or exercise data.
- Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data. Physical location or movements.
- Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information. Current or past job history or performance evaluations.
- 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, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
HOW WE USE YOUR INFORMATION
We and our service providers may use Personal Information for the following purposes:
To respond to your inquiries.
To provide advertising, creative, analytics, and media services to our clients.
To manage any contractual relationship between us.
To present our website and related content to you.
To evaluate and make improvements to our website or social media presences.
To diagnose and fix problems with our website.
To secure our website and to prevent or detect criminal, unlawful, or harassing actions or conduct.
To personalize marketing materials and promote our products and services, to provide you with products or services you have requested, and to provide news and event information.
If you apply for a job, to verify previous employment and to conduct background checks (as permitted by law).
To provide any legally required reporting to governmental or regulatory entities.
On other occasions where we ask you for consent, we will use the information for the purposes we provide at that time. You have the right to withdraw your consent at any time; however, we may have other legal grounds for storing and/or using your information, including those identified above.
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may share your Personal Information as follows:
Service Providers. We may disclose Personal Information to third party vendors, service providers, contractors or agents who perform functions on our behalf (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as providing data storage and management, or providing analytics services. We only provide our Service Providers with the information or access to information necessary for them to perform these services on our behalf. Each Service Provider must agree to use commercially reasonable security procedures and practices, appropriate to the nature of the information involved, to protect your Personal Information from unauthorized acquisition, access, use, or disclosure. Service Providers may only use the Personal Information we provide to provide services to us.
Business Transfers. If we are acquired by, or merged with, another entity, if substantially all of our assets are transferred to another entity, or as part of a bankruptcy proceeding, or if we are evaluating or in negotiations with respect to any such transaction, we may transfer, or make available, the Personal Information we have collected from you to the other entity or resulting legal entity.
Legal Process. We also may disclose the Personal Information we collect from you to comply with applicable laws or regulations, a government investigation, a judicial proceeding, court order, or other legal process, such as in response to a subpoena, or to present evidence in litigation in which we are involved.
Aggregated and De-Identified Information. We may share aggregate or de-identified Personal Information with our clients for marketing, advertising, research, or similar purposes.
Job Applications. If you apply for a job position, some of your Personal Information may be shared with third parties in order to confirm your education, work history, and references, and to obtain background checks and credit reports if permitted by law.
In the 12 months preceding the Last Updated dated of this Policy, we have disclosed the following categories of Personal Information for a business purpose as described above:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.
SALE OF PERSONAL INFORMATION
We do not sell the Personal Information of anyone.
Our Sites and our Services are not targeted or directed to children under the age of 13. Further, we do not knowingly collect Personal Information from children under the age of 13. If you become aware that your child has provided personally identifiable information without your consent and/or is under the age of 13, please contact us at 239.494.3608. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will take commercially reasonable efforts to delete such information from our records.
YOUR PRIVACY CHOICES
You may opt-out of receiving email communications and other marketing materials from us (or any third-party email marketing service we may use) via links provided in each email (usually at the bottom of the email).
LINKS TO THIRD PARTY WEBSITES OR PLATFORMS
We make no representations or warranties, express or implied, regarding the content of any of these linked website or platforms. WE EXPRESSLY DISCLAIM ANY AND ALL LIABILITY FOR YOUR INTERACTION WITH SUCH THIRD-PARTY WEBSITES OR PLATFORMS.
SECURITY OF YOUR INFORMATION
We use commercially reasonable security safeguards to help protect Personal Information from unauthorized access, alteration, loss, or disclosure. Despite these efforts, please understand that no system is perfect and we cannot guarantee that unauthorized access, theft, or loss of data will not occur. Please advise us immediately at 239.494.3608 of any incident involving Personal Information in our custody or control.
CHANGES TO THIS POLICY
CHOICE OF LAW, JURISDICTION, AND VENUE
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act (CCPA) and California’s “Shine the Light” law provide consumers who are California residents with specific rights regarding their Personal Information. If you are a California resident, this section describes your rights and explains how to exercise those rights.
Right to Information. Subject to certain limits, you may ask us to provide the following information for the 12-month period preceding your request:
The categories of Personal Information we collected about you;
The categories of sources from which the Personal Information was collected;
The business or commercial purpose for collecting the Personal Information;
The categories of third parties with whom we shared the Personal Information;
If we disclosed Personal Information for a business purpose, a list of the disclosures including the Personal Information categories that each category of recipient received; and
The specific pieces of Personal Information we collected about you (also called a data portability request).
We do not provide these information and data portability rights for B2B Personal Information.
Right to Delete. You also have the right to ask us to delete any Personal Information that we have collected about you, subject to certain limitations as set forth under CCPA. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a good or service you requested, take actions reasonably anticipated in the context of our business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law.
Right to Nondiscrimination. We will not discriminate against you if you exercise your privacy rights under California law, including by:
Denying you goods or services.
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, the CCPA permits us to offer you certain financial incentives that can result in different prices, rates, or quality levels, which are related to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We do not currently offer any financial incentives in exchange for Personal Information we collect.
Submission of Requests for Information or Requests to Delete. If you are a California resident, you may submit a request for information or a request to delete by:
Calling us at 239.494.3608. Please provide your name, telephone number, and type of request (that is, a request for categories of information, a request for specific pieces of information, and/or a request to delete).
To protect your privacy and security, we will also take reasonable steps to verify your identity before providing your Personal Information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your Personal Information. If you want to authorize someone else to make a request on your behalf, please contact us at 239.494.3608 and provide your name, telephone number, the name of the person you want to authorize to make a request, and the type of request the person is authorized to make (that is, a request for categories of information, a request for specific pieces of information, and/or a request to delete). We will contact you if we need more information.
Responses to Requests. We do not charge a fee to respond to your request unless it is repetitive (more than twice in a 12-month period) or excessive. We generally will respond to your request within 45 days of its receipt. If we need more time to respond, we will inform you of the reason and we may take up to an additional 45 days to respond.