Effective Date: July 25, 2014
TalentCircles, Inc. complies with the U.S. – E.U. Safe Harbor framework and the US – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries. TalentCircles, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view TalentCircles, Inc.’s certification, please visit http://www.export.gov/safeharbor/.
Terms Applicable to Users of the Website and To Information Shared Offline
Information We Collect
Information We Automatically Collect
When you access our Website, whether by computer, mobile phone or other device, we automatically collect certain information about your use of our Website (this information may include without limitation: geographical location and IDs of your computer, mobile or other device; bandwidth used; system and connection performance; browser type and version, operating system; referral source; length of visit; page views; IP address or other unique identifier for your computer, mobile phone or other device; your mobile carrier) using technologies such as Cookies and web beacons.
This information is not linked to personally identifiable information.
Information You Provide To Us
In some situations you may provide us with your personal identifying information (called “PII”). PII could include, without limitation, your name, street address, telephone number, email address, information about your company or business, and, if necessary, date of birth and credit card and/or other payment/ordering information, and any other information we collect about you that by itself is not PII but if combined with PII could be used to personally identify you.
You also may provide us with PII when you:
submit the contact form on our Website
complete a survey
submit a product testimonial
make a purchase from TalentCircles, Inc.
subscribe to our Website Services, email notifications and/or newsletters
provide comments on our blog
engage in any other transactions between you and us on or in relation to our Website or Services.
How We Use Your Information
TalentCircles, Inc. will use Information we Automatically Collect to:
Improve your experience on our Website and our Services, to count users who visit our Website or open our HTML-formatted email messages, improve the delivery of our ads and web pages to you help us better manage content on our Website by informing us what content is effective and by helping to measure traffic on our Website.
We may use IP addresses to help diagnose problems with our server, administer our Website, analyze trends, track users’ movement, gather broad demographic information for aggregate use in order for us to improve the Website, and deliver customized content.
TalentCircles, Inc. will use PII to:
- respond to your inquiries, and/or other requests or questions
- enable your use of the Services available on our Website
- contact you regarding your purchase,
- collect payments from you
- provide Services purchased from TalentCircles, Inc.
and to send you:
- information and updates related to your purchase
- email notifications which you have specifically requested
- email marketing communications relating to our business which we think may be of interest to you
- email messages containing company news, product or service information.
Sharing PII with Third Parties
We may use third parties to perform certain services on our behalf. We may share your PII including payment information, with these third parties solely to enable them to perform the services for us.
Such third parties include those:
- hosting our Website
- managing the functionality of our Website
- processing payments
- fulfilling and processing orders
- assisting with promotions
- enabling us to send you email.
We require that those third party vendors maintain at least the same level of confidentiality that we maintain for such information. We do not provide your PII to parties unconnected with the Services we provide. Your information will not be sold to nor will it be exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering a product or Service.
Posting In Public Areas Of Our Website
We may select and post customer testimonials on our Website, which may contain PII such as your name, your title and/ or the city, state, or country in which you live. We encourage you to create an anonymous unidentifiable screen name when posting testimonials.
We will obtain your consent prior to posting any testimonial with your name.
If you would like us to remove or delete your name or testimonial from our Website, you may contact us at firstname.lastname@example.org.
Note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of our Website for a period of time.
Third Party Websites
TalentCircles, Inc. is not responsible for the treatment of your PII or any of your information by any third party.
You may opt out of having your PII shared with third parties except as required by law and you may also request updates or changes to your information or your preferences regarding receiving future promotional messages from us.
Please note that if you opt out of promotional/ marketing emails, you may continue to receive certain communications from us, such as administrative and Service announcements and/or messages about your account/profile.
Changing or Updating Your Information
By contacting us, you can review and change or update personal information you have provided and your subscriptions or preferences regarding information you receive from us. We will implement your requested changes as soon as we reasonably can. When you edit your information or change your preferences, information that you remove may remain in our databases or backup media because it is not always possible to completely remove or delete information from those locations. If you have made any postings in a Public Space of our Website, these cannot generally be removed.
Disclosure of Information/Sharing Your Information
We may disclose your PII (a) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders or (b) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change or (c) to our subsidiaries or affiliates only if necessary for business and operational purposes or (d) to our vendors if necessary in order to provide you with Service as further described below.
Without your express consent, your information will not be sold, exchanged, transferred, or given to any other entity, other than companies acting as our agents to perform task(s) on our behalf and under our instructions, for any reason that is not compatible with the reason that you originally shared the information (except as described above).
If you do agree to allow us to share your PII with third parties for other reasons, you may opt in by emailing your consent to email@example.com. You may revoke this permission (opt out) at any time. See the section ‘Opting Out’ for more information.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our Website users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
Notice to California Residents – Your California Privacy Rights
Terms Applicable To Users Of The Platform
How The Platform Operates
Collection Of PII
In order to use the Talent Network, both Recruiters and Members must register for account credentials. When you register for account credentials, you elect to share certain personal identifying information (called “PII”). PII may include your name, email address, and a password that you create. Recruiters and Third Party Application Developers might use the Platform to collect, use, and retain part of or all information, including PII and Network Data, that is disclosed and uploaded by Members in connection with their use of Networks. “Network Data” means all data shared from a Network or Member and includes registration information (including the Internet protocol (IP) address used by a Member at the time of registration), profile data, answers to Network profile questions, all Content and other information contributed by Members, and statistical information and analytics relating to usage and interactions within the Network. When a User signs up to become a member of a Network, he or she is providing PII to that Network’s Network Creator and such Network Creator and its designated administrators will have access to all PII and Network Data associated with any such Network. In addition, Recruiters will have the ability to reset Member passwords in the event that a Member loses or cannot remember it. Recruiters and Third Party Application Developers might also collect additional types of PII. Additionally, for each Third Party Application that you add to your Network or your profile, you should check with the Third Party Application Developer regarding its policies governing its collection, use and disclosure of PII.
Information Received From Third Party Sources
How PII Is Used
We may use PII to operate, provide, improve, and maintain the Platform, and our other Services and systems; to develop new products and Services; to prevent abusive and fraudulent use of the Platform and our other Services and systems; to send you administrative messages, and information about Networks, content; and for other administrative and internal business purposes.
When PII Is Disclosed
Our Platform’s Service Providers
We may provide PII to third parties for their use in performing internal business functions (e.g., maintenance, security, data analysis, email transmission, or data hosting) on our behalf.
We may disclose PII if we have a good faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. Additionally, we may disclose PII where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of our Platform, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government enforcement agencies.
Change Of Ownership
In the event of a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of your PII, including email addresses, to that entity. We will notify registered users in advance of such a transfer by a posting on our home page or elsewhere on the Platform and by sending an email to Members’ email addresses as provided to us.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.
We use industry standard security measures to protect against the loss, misuse, and alteration of PII under our control. Although we make good faith efforts to maintain the security of such PII, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information. To help maintain the security of your account credentials, please keep your password secure. If we learn of a security breach, we will attempt to notify you electronically so that you can take appropriate protective steps. By using the Platform or providing PII to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Platform. If a security systems breach occurs, we will post a notice on our homepage, or elsewhere on the Platform and will send notice to you by email at the email address you have provided to us.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.
Privacy Settings And Profile Updates
You may, at any time, update, correct, or delete certain categories of PII that you have provided to us by signing in to your Network and updating the information. Additionally, you may update, correct, or delete certain categories of PII within your profiles on Networks by following the directions on the Network’s “Account Settings” page. Members and Recruiters may restrict who may see certain aspects of their profile by following the directions on the Network’s “Account Settings” page. Members may also, at any time, elect to leave a particular Network and delete their content on such Network by contacting us through the Support link at the bottom right of each page.
We will retain your PII for as long as your account status is active or as needed to provide you Services. We will retain and use your PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Email Communications And Unsolicited Commercial Email
We may send you administrative messages, and updates regarding your account, the Platform, and our Services, by email. Recruiters may also send administrative or promotional messages to the extent permitted by applicable law and the Terms of Service. You can choose to opt out of receiving messages from our Talent Network by following the directions on the bottom of the email message you receive. The Terms of Service prohibit Users from engaging in any activity involving the sending of email in violation of applicable law, including CAN-SPAM and other laws regulating unsolicited commercial email. Violations of these policies may result in immediate termination of service and legal action against any senders or initiators of such messages.
Third Party Services
The Platform, and Networks, may contain links to websites and services provided by third parties. Any PII you provide on third party websites or services is provided directly to that third party and is subject to that third party’s policies governing privacy and security. We are not responsible for the content or privacy and security practices and policies of these third party websites or services. We encourage you to learn about third parties’ privacy and security policies before providing them with PII. Recruiters can enable “Social Sign In,” which allows Members to share their account credentials from certain third party services (such as LinkedIn, Facebook, Google+ or other services) to sign in or sign up for a Network. As part of the sign-up process, the third party service will transmit certain information used to complete the new Member’s profile page, including name, email address and, where available, profile photo, birthdate, gender and location. Any of the shared profile information, except for email address, can be updated or changed during sign up. The email address as well as personal and professional information can be changed after sign up. Recruiters can allow Members to share or “Like” content via Share Links or third party Services (such as Facebook, Twitter and Google+).
Terms Applicable to All Users
Cookies and Web Beacons
We may use web beacons (also known as clear GIFs) to access Cookies and count users who visit our Website or Platform or open our HTML-formatted email messages. Web beacons are single-pixel graphic files with a unique identifier, similar to Cookies. Web beacons are embedded invisibly on Web pages and are stored on a user’s hard drive. You can modify your browser settings to control web beacons.
TalentCircles, Inc. has implemented and follows commercially reasonable measures to protect against unauthorized access to and unlawful interception or processing of PII. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any information you transmit to us or from our Website therefore you use our Website at your own risk.
Questions or Concerns, Contact Us
or by postal mail at
Attn: Caleb Fullhart, Privacy Officer
1200 Bayhill Drive, Suite 114
San Bruno, CA 94066
If you need to communicate with us regarding your credit card or other payment information please contact us by phone at our designated customer support number. Do not include any account numbers in your email as email is not a secure form of communication.
Dispute Resolution for EU Safe Harbor Claims and U.S.-Swiss Safe Harbor Claims
If a complaint or dispute cannot be resolved through TalentCircles Inc.’s internal process, TalentCircles Inc. has agreed to cooperate with the EU Data Protection authorities and the Swiss Federal Data Protection and Information Commissioner and to participate in the dispute resolution procedures of the panel established by the EU Data Protection authorities.