Logo for 24 Seven

Privacy Policy

Last updated and effective as of August 2024

Introduction

Welcome to the 24 Seven Group’s privacy policy.

24 Seven Group (“us” or “we”, or “our”) respects your privacy. This privacy policy will describe how we process your personal data when you visit our Sites or otherwise interact with us (collectively, the “Services”) and your privacy rights under Applicable Privacy Law. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy. 

Please note that certain defined terms include hyperlinks to help individuals navigate this privacy policy.                        

Scope and purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of our Sites, including any data you may provide through the Services as a (i) website user, (ii) job candidate, (iii) client, or (iv) supplier of the 24 Seven Group. This privacy policy has been designed with reference to Applicable Privacy Law.

The Sites are not intended for individuals under the age of 18 years of age (“children”) and we do not knowingly collect data relating to children. If you learn that data of children has been provided to us, please contact us so that we may delete the information.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you have a full understanding of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Such supplemental policies may include our:

Please note that 24 Seven staff members should refer to our separate “Employee Privacy Policy” which is posted within our internal company systems.

Data subject privacy notices

We have divided this privacy policy into different “privacy notices” for the various categories of individuals that we process personal data: (i) website users, (ii) job candidates, (iii) clients, and (iv) suppliers.

Each privacy notice will describe for the specific data subject:

  • which 24 Seven Group entity or entities serve as data controller for personal data processing;
  • the types of personal data we process pursuant to the Services;
  • the purposes / legal bases of data processing;
  • the sources from which we have collected personal data;
  • the recipients with whom we share personal data and the purposes / legal bases for which they process that data; and
  • our data retention practices.

Please click on the relevant link below to access the privacy notice that is applicable to you.

Contact details

We have appointed a data privacy manager who is responsible for overseeing questions and requests in relation to this privacy policy. If you have any questions about this privacy policy, or wish to exercise your legal rights, please contact the data privacy manager using the details set out below.

For United States or Canada inquiries:

Email address: DPM@24seveninc.com

Postal address:
105 Maxess Road Suite 201N
Melville, NY
11747

For United Kingdom or EU inquiries:

Full name of legal entity: 24 Seven UK Limited

Email address: DPM@24seveninc.com

Postal address:  
2 Stephen Street
Fitzrovia
London
W1T 1AN

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. We reserve the right to amend this privacy policy from time to time consistent with Applicable Privacy Law, so we suggest you check back from time to time to stay informed of such changes. Any changes will be immediately incorporated into this privacy policy and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.  We will not collect new types of personal data beyond what is disclosed in this privacy policy without providing you notice prior to the collection of that personal data. Your continued use of the Services after any changes are made to this privacy policy constitutes your acceptance of the changes.  If any changes are unacceptable to you, you should cease all use of the Services.  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Change of purpose

We will only use your personal data for the purposes for which we collected it as described in this privacy policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and, to the extent applicable, we will explain the legal basis which allows us to do so by sending a notice to the email address you provided and/or by posting a new a revised privacy policy with a new “last updated” date and, to the extent required under law, obtaining your consent.

Third-party links

Our Sites may include links to third-party websites, plug-ins, and applications (including social media services) (“third-party sites”). Clicking on those links or enabling those connections may allow such third-party sites to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy statements or privacy practices, including their level of data sharing with other third parties. Additionally, we are not responsible for the data processing practices of the internet browser service provider you choose to use when accessing one of our Sites.  When you leave our Sites, we encourage you to read the privacy policy of every website you visit or internet browser service provider you use.

Your Legal Rights and Choices

Depending on the Applicable Privacy Law where you reside, you may submit requests based on a number of privacy rights that may be available to you and which are further described below. If you wish to exercise any of the rights set out below, please contact us.

Access.

You could have the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Correction.

You could have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Deletion.

You could have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legitimate reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data in certain instances, such as where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objection. (For EU/UK residents only)

You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms (although we will always remove your details from any marketing database if you ask us to do so).

Restriction. (For EU/UK residents only)

You have the right to request restriction of certain processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful, but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Data Portability.

You could have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that, for UK and EU residents, this right may only apply to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Opt-Out Rights. (For certain US residents only)

You could have the right to opt-out of certain uses of your personal data, including:

  • selling your personal data for valuable consideration;
  • sharing your personal data for targeted advertising purposes;
  • the processing of your personal data for the purposes of creating a profile based on your interests or behaviour which is used in such a way that would produce legal ramifications or similarly significant real world effects on you (if applicable);
  • any automated decision-making activities about you with respect to personal data (if applicable); and
  • limiting the processing of your sensitive personal data for purposes of inferring characteristics about you (if applicable).

Withdraw Consent.

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.  Please review the relevant data subject privacy notice that applies to you for details of the lawful bases (other than consent) for which we process your personal data.

Complain/Appeal.

You may have the right to complain or appeal to us if we reject your request or you believe we have violated your privacy rights. Also, depending on where you reside, you may have the right to submit a complaint with your respective data protection authority and/or state Attorney General.

For example, data subjects may complain to:

We would, however, appreciate the chance to deal with your concerns before you approach your applicable data protection authority so, please contact us in the first instance.                          

No Discrimination.

You have the right to not have discriminatory action taken against you for exercising your rights.

How to Submit a Privacy Request

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Steps to submit a privacy request

If you would like to exercise any of the rights described in the “Your Legal Rights and Choices” section above (“privacy request”), please contact us. We will not discriminate against you for exercising your rights under Applicable Privacy Law. Further details on the steps needed to complete a privacy request are detailed below.

Step 1: Verifying the privacy request

Before we can fulfil your privacy request, we need to: (i) verify your identity or authority to make the request and (ii) confirm the personal data you are requesting belongs in fact to you.  If you have a password-protected account with us, we may use our existing authentication procedures to verify your identity, however, you are not required to have an account with us to make a privacy request.  For most other privacy requests, we will ask you to provide information that matches at least two pieces of personal data we store about you before responding to your privacy request.  If you would like to request specific pieces of personal data that we have collected, or if you would like us to access or delete highly sensitive personal data, you must match at least three pieces of information we store about you, and you may be required to provide a signed declaration under penalty of perjury that you are the consumer whose personal data you are requesting. We may refuse any privacy request made regarding collected personal data if we are unable to verify your identity or if we cannot authenticate the legitimacy of your privacy request using commercially reasonable efforts.  Under such circumstances, we may follow up with you for additional information as reasonably necessary to authenticate your privacy request.  We will only use personal data provided in a verifiable consumer privacy request to verify your identity or authority to make the privacy request or if use of your personal data is required to comply with applicable law.

Authorized agents

You may grant an authorized agent written permission to submit privacy requests, but we may deny authorized agent privacy requests if we are unable to verify your identity directly as the subject of the personal data at issue.  To verify a privacy request from an authorized agent, we may require proof that you gave the authorized agent signed permission to submit the privacy request, such as by requiring you to directly confirm with us that you provided permission for the authorized agent to submit the privacy request, and/or we may ask you to verify your identity directly with us.

Step 2: Responding to a privacy request

After verifying your identity, we will respond to your privacy request by either fulfilling the request or explaining why we are denying the privacy request.  The timeframe in which we respond will vary based on the Applicable Privacy Law where you reside. If we deny your privacy request, you may have the option under Applicable Privacy Law to appeal this decision by contacting us. If you are concerned with the result of your appeal, you may have the right to contact your State Attorney General or applicable data protection authority.      

Deletion requests

Please note that for deletion requests, any removal of content by us does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties who act outside of any business relationship with us or may not cooperate with our request for them to delete your personal data, or federal or state law may require maintenance of the content or information.  We will do our best to accommodate your deletion request, but we cannot guarantee we can remove all personal data from its specified uses. Therefore, please be as specific as possible in the privacy request. If the privacy request relates to information that we need to make the Services function properly, you may not be able to use the Services properly moving forward. We reserve the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your personal data. 

How to opt-out

As discussed in the “Your Legal Rights and Choices” section above, you may have the right to opt out of certain uses or disclosures of your personal data. Please review our Cookie Policy and the applicable privacy notice that pertains to you to learn more about how to exercise your opt out rights. 

Automated Decision Making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.

Save for website users (please see below), we do not envisage that any decisions will be taken about you using automated means.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. Data retention timeframe may vary based on your relationship with us. For further information on the specific data retention timeframes for your information, please see the applicable privacy notice that pertains to you.  

In some circumstances you can ask us to delete your data: see the “Your Legal Rights and Choices” section for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

International transfers

We may share your personal data within the 24 Seven Group, which may involve sharing your personal data with entities located outside of the country where you reside. In particular, we will store your details in our secure data storage centre located in the USA.

Whenever we transfer your personal data out of the country where you reside, we will comply with our cross-border data safeguard obligations under Applicable Privacy Law by ensuring at least one of the following safeguards is implemented:

  • Where applicable, we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by your applicable regulatory authority, including for European and UK individuals, the European Commission. For information on the European Commission’s list of adequate countries, please visit https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.   
  • Where we use providers based in an inadequate jurisdiction, such as the US, we implement cross-border transfer mechanisms, as appropriate, to comply with Applicable Privacy Law.

Data security

We have put in place security measures intended to protect personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Terms of Use

This privacy policy is incorporated into and governed by our Terms of Use.

IF YOU DO NOT AGREE WITH ANY ASPECT OF THIS PRIVACY POLICY, THEN PLEASE DO NOT ACCESS OR USE THE SERVICES OR OTHERWISE PROVIDE US WITH YOUR PERSONAL DATA. YOUR CONTINUED USE OF OUR SERVICES SIGNIFIES YOUR ACCEPTANCE OF THIS PRIVACY POLICY.

IF YOU LEARN OF A POTENTIAL VIOLATION OF THIS PRIVACY POLICY BY US OR AN OUTSIDE PARTY, PLEASE CONTACT US.

WEBSITE USERS

1. DATA CONTROLLER

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. DATA RETENTION

1. Data Controller

2. The data we collect about you

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, age range, date of birth (if required to verify eligibility for Services), and gender.
  • Contact Data includes address, email address, and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location (at the state and/or country level), browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access one of the Sites.
  • Profile Data includes your username and password, preferences, feedback, and survey responses. 
  • Usage Data includes information about how you use our Services or otherwise interact with one of one of the Sites.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any sensitive personal data or Special Categories of Personal Data. However, if you voluntarily provide us with this type of information, you hereby consent to our processing of such information in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a particular Service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
    • apply for our Services;
    • create an account on one of the Sites;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion, or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Sites, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this information, which may include personal data to the extent such information is reasonably capable of being associated with you or your device, directly or indirectly, by using cookies, server logs and other similar online tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Technical Data from the following parties:

4. How we use your personal data

We will only use your personal data when the law allows us to. Depending on where you reside, we may be required to process data only if we have a legal basis. Most commonly, we will rely on the following legal bases when using your personal data:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation. 

Click here to find out more about the types of lawful bases that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and, to the extent applicable, which of the legal bases we rely on to do so (these are set out in brackets). Our legitimate interests include to keep our records updated and to study how clients and candidates use our services, develop and grow our business, and inform our marketing strategy and provision of administration and IT services, as well as network security.

Note that we may process your personal data for more than one legal basis and/or purpose depending on why we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out below: 

  • To register you as a new client or candidate (performance of a contract with you);
  • To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and/or asking you to leave a review or leave a survey (performance of a contract with you, necessary to comply with a legal obligation and/or necessary for our legitimate interests);
  • To enable you to partake in a prize draw, competition, or complete a survey (performance of a contract with you and/or necessary for our legitimate interests);
  • To administer and protect our business and our Sites, including for example, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data (necessary for our legitimate interests and/or necessary to comply with a legal obligation);
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (necessary for our legitimate interests);
  • To use data analytics to improve our Sites, Services, marketing, customer relationships, and experiences (necessary for our legitimate interests);
  • To make suggestions and recommendations to you about services that may be of interest to you (necessary for our legitimate interests); and
  • To comply with our legal and regulatory obligations and to exercise our legal rights (necessary to comply with a legal obligation).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us (opted in) or used services from us and you have not opted out of receiving that marketing.  You will be given the opportunity each time you receive marketing communications from us to unsubscribe from future communications of that nature.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.

Cookies and other online tracking tools

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly.

For more information about the online tracking technologies, we use and how you can opt out, please see our Cookie Policy.

SMS Texts

24 Seven and its affiliates, and contracted partners engage with candidates via calls, AI-generated calls, text messages, and/or emails to share job opportunities. Consistent with our privacy policy, information obtained will not be shared with third parties/affiliates for marketing/promotional purposes. Frequency varies for text messages. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. You can reply STOP to cancel and HELP for help.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in “Purposes for which we will use your personal data above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data retention

For website users, we will generally keep the types of personal data set out above for two years from your last visit to our Sites. Please see the “Data retention” section of the main privacy policy for more information on our data retention practices.

CANDIDATES (INCLUDING POTENTIAL CANDIDATES)

This section covers the following four categories of candidates and potential candidates:

  • Potential candidates whose details remain on third party sites such as LinkedIn and job boards;
  • Potential candidates who are put forward for roles;
  • Freelance contractors who carry out temporary placements; and
  • Candidates who are placed into permanent placements.

1. DATA CONTROLLER

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. DATA RETENTION

1. Data Controller

All entities within the 24 Seven Group

2. The data we collect about you

For those potential candidates whose details remain on third party sites such as LinkedIn and job boards, the processing activities are minimal because their personal data are never put on to our systems. 

We do not retain potential candidates’ personal data unless or until we consider that they may be suitable for placing with one or more of our clients.  The details set out below relate to the other three categories of candidates and potential candidates outlined above.

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • The information you have provided to us in your curriculum vitae or resume, cover letter, and enquiry forms;
  • The information you have provided on our application form or during the interview process, including name, title, address, telephone number, personal email address, date of birth, gender, employment history (including previous employers, positions and work experience, professional licenses, certificates or other qualifications, and employment references or referrals), educational history and qualifications (including your highest level of education, the schools you attended and when you were in attendance, degrees, certificates or other educational qualifications you earned, and school transcripts or educational references), salary details (including previous or desired salary, bonus, benefits and expenses), and other qualifications;
  • Any information you give us on the types of roles and organisations you are interested in;
  • Your national insurance number and tax code; and
  • Test results for any application assessments conducted by our clients.

We may also collect, store, and use the following types of more sensitive personal data:

  • Financial information, such as your bank account details (bank name, address, account number and sort-code) so we can pay you for assignments you work on with clients.
  • Your social security number and/or driver’s license for identity verification purposes
  • Information about your race or ethnicity, religious beliefs, veterans status, national origin, gender identity, marital status, sexual orientation, and political opinions, but only to the extent required for legal reporting purposes or to the extent you voluntarily provide this information to us.
  • Information about your health, including any medical condition, health, and sickness records for purposes of facilitating disability accommodations and confirming drug test results or vaccine status.
  • Information about criminal convictions and offences when conducting required background checks or security clearances.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with recruitment services). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • You, the candidate;
  • Disclosure and Barring Service or third-party background check providers in respect of criminal convictions (where applicable due to assignments you are asked to work on);
  • Our service providers acting on our behalf including communications providers, scheduling providers, and application providers; and
  • Data from third parties in a publicly accessible source such as your LinkedIn details and job boards and information disclosed within.

4. How we use your personal data

We will use the personal data we collect about you to:

  • Identify you as a potential candidate and review your application for a position with us and/or one of our clients;
  • Assess your skills, qualifications, and suitability for a potential position or other opportunities with us and/or a client;
  • Verify the information provided to us in connection with your application or received from other sources including for purposes of carrying out background and reference checks, where appropriate;
  • Communicate with you about the recruitment process, including providing the status of your application or other opportunities with us that may be of interest to you;
  • Facilitate the recruiting and interview process;
  • Assess and improve the performance and success of our recruiting and hiring process;
  • Conduct internal investigations, audits, compliance, risk management, problem resolution and security operations;
  • Fulfil contractual obligations to you and other third parties; and
  • Keep records related to our hiring processes and services with you.

Depending on where you reside, we may be required to have a legal basis for our processing activities. With respect to your personal data, we rely on the following legal basis: legitimate interests, performance of a contract, and compliance with laws.

It is in our legitimate interests to decide whether to assign you to our assignments or put you forward for permanent positions with our clients since it would be beneficial to our business to appoint someone to that assignment/role with our clients. We also need to process your personal data to decide whether to enter into a contract with you. Having received your CV and the results from any tests or interviews with us or our client, we will then process that information for the purpose of considering your suitability for an assignment.  If you are offered an assignment, we will then carry out any further steps necessary, such as take up references, carry out a criminal record check or any other background checks required by our client for the assignment.

If you are unsuccessful in securing a particular assignment or role (or decide not to take it up), we will retain your personal data for consideration for other assignments or roles unless you tell us otherwise.

5.  Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out at “How we use your data above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data retention

How long will you use my personal data for?

  • We will generally keep the personal data of each category of candidates/potential candidates as follows, unless there is a specific legal requirement that requires us to retain any information for longer:
  • Potential candidates whose details remain on third party sites such as Linked-In and job boards – no personal information retained;
  • Potential candidates who are put forward for roles – 12 months from the date of the last recruitment activity, such as interview with a client;
  • Freelance contractors who carry out temporary placements – 6 years from the end of the contractual relationship; and
  • Candidates who are placed into permanent placements – 12 months from the date of the placement.

Please see the “Data retention” section of the main privacy policy for more information on our data retention practices.

CLIENTS

1. DATA CONTROLLER

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. DATA RETENTION

1. Data Controller

All entities within the 24 Seven Group

2. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you (in this “Clients” section of the privacy, “you” shall collectively refer to your company or organization and to you as its representative) which we have grouped together as follows:

  • The information you have provided to us in enquiry forms; and
  • The information you have provided in communications with us, including name, title, employer, job title, address, telephone number, and email address.

We do not anticipate that we will collect any types of sensitive personal data or Special Categories of Personal Data from you. However, if you voluntarily provide us with this type of information, you hereby consent to our processing of such information in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with recruitment services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • You, as the client or a representative of the client; and
  • Data from third parties in a publicly accessible source such as your LinkedIn details, business website and information disclosed within.

4. How we use your personal data

We will use the personal data we collect about you to:

  • Carry out our recruitment services with you or on your behalf;
  • Fulfil requests to place candidates within your organisation;
  • Obtain feedback on services we have provided to you in the past;
  • Communicate with you about our processes;
  • Forward you details of candidates we believe may be of interest to you;
  • Provide you with our latest marketing materials; and
  • Record your candidate and communication preferences in receiving marketing from us and third parties operating on our behalf.

Depending on where you reside, we may be required to have a legal basis for our processing activities. With respect to your personal data, we rely on the following legal bases: legitimate interests, performance of a contract, and compliance with laws. It is in our legitimate interests to decide what recruitment services we are to provide to you since it would be beneficial to our business to appoint candidates within your organisation to fulfil your requests. We also need to process your personal data to decide whether to enter into a contract with you. It is also in our legitimate interests to provide you with marketing updates, both on the services that we provide and candidates who may be of interest to your sector.

You have the right to withdraw consent to marketing at any time by contacting us.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above at “How we use your personal data.

 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data retention

How long will you use my personal data for?

For clients, we will generally keep the types of personal data set out above for six years from the end of your last engagement with us (or if we do not provide any services from you, six years from the date of your initial enquiry).  Please see the “Data retention” section of the main privacy policy for more information on our data retention practices.

SUPPLIERS

1. DATA CONTROLLER

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. DATA RETENTION

1. Data Controller

All entities within the 24 Seven Group

We may collect, use, store and transfer different kinds of personal data about you (in this “Supplier” section of the privacy, “you” shall collectively refer to your company or organization and to you as its representative) which we have grouped together as follows:

  • The information you have provided to us in enquiry forms; and
  • The information you have provided in communications with us, including name, title, employer, job title, address, telephone number, and email address.

We do not anticipate that we will collect any types of sensitive personal data or Special Categories of Personal Data. However, if you voluntarily provide us with this type of information, you hereby consent to our processing of such information in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide services to us. In this case, we may have to cancel a service you provide to us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • You, the supplier; and
  • Data from third parties in a publicly accessible source such as your LinkedIn details, business website profile and information disclosed within.

4. How we use your personal data

We will use personal data we collect about you to:

  • Contract with you to provide services;
  • Obtain and provide feedback on services you have provided to us in the past; and
  • Communicate with you about the services.

Depending on where you reside, we may be required to have a legal basis for our processing activities. With respect to your personal data, we rely on the following legal bases: legitimate interests, performance of a contract, and compliance with laws. It is in our legitimate interests to decide what services you provide to us. We also need to process your personal data to decide whether to enter into a contract with you.

Where applicable, you have the right to withdraw consent to marketing at any time by contacting us.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the “How we use your personal data section above.

  • Internal Third Parties 
  • External Third Parties
  • We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data retention

How long will you use my personal data for?

For suppliers, we will generally keep the types of personal data set out above for six years from when you last performed services for us. Please see the “Data retention” section of the main privacy policy for more information on our data retention practices.

GLOSSARY

LAWFUL / LEGAL BASIS

Other than consent, the most commonly used lawful bases for processing are the following:

Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

PERSONAL DATA

Aggregated Data” typically means data that have been combined or collected together in summary or other form such that the data cannot be identified with any individual. Aggregated data could be derived from your personal data but is not considered personal data under Applicable Privacy Law. 

Personal Data or Personal Information generally means information that can directly or indirectly be used to identify an individual or in some cases, an individual’s household. Personal data does not include data that is anonymized / de-identified or, under Applicable Privacy Law, data that is publicly available.

Sensitive Personal Data”or “Special Categories of Personal Data” may vary under Applicable Privacy Law but the terms typically mean information pertaining to an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and/or health, genetic, and/or biometric data.  Depending on the Applicable Privacy Law, sensitive personal data may also include government ID numbers, precise geolocation data, national origin, pregnancy status, transgender or nonbinary status, information on the status of a victim of a crime, the contents of mail, email, and text messages (unless the business is the intended recipient), financial information, username and a passcode or other information that one could use to gain access to a financial account.

THIRD PARTIES

Internal Third Parties” mean other companies in the 24 Seven Group acting as joint controllers or processors and who are based in the UK, the US and Canada.

External Third Parties” mean companies outside of the 24 Seven Group. Examples of External Third Parties are:

  •  Service providers acting as processors based in the U.S.A., U.K. and Canada who provide services on our behalf including, for example, data storage, IT and system administration services, background check services (for candidates), etc.;
  • Professional advisers acting as processors or joint controllers or controllers in their own right including lawyers, bankers, auditors and insurers based in the U.S.A., U.K. and Canada who provide consultancy, banking, legal, insurance and accounting services;
  • Regulators, law enforcement, judicial bodies, and other authorities acting as processors or joint controllers or controllers in their own right; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

ANNEX

24 Seven Talent Group Entities:

  • 24 Seven Topco, LLC
  • 24 Seven Midco, LLC
  • 24 Seven Holdco, LLC
  • 24 Seven, LLC
  • 24 Seven UK Limited
  • 24 Seven Talent Source ULC
  • 24 Seven Canada LLC
  • 24 Seven Minnesota, LLC
  • Creatis, Inc.
  • Antenna, LLC
  • Simplicity Consulting, LLC
  • Sage Consulting Associates, LLC
  • The Cydio Group, LLC
  • McKinley Marketing Partners, LLC
  • SketchDeck, LLC
  • Filter, LLC

24 Seven Talent “Sites”:

Applicable Privacy Law

Depending on where you reside, 24 Seven may be required to process your personal data in accordance with certain data protection laws. Such data protection laws may include, for example, the following:

  • EU General Data Protection Regulation (“GDPR”)
  • UK Data Protection Act 2018 (“UK GDPR”)
  • California Consumer Privacy Act, including subsequent amendments (“CCPA”)
  • Other applicable U.S. state comprehensive privacy laws where we do business (collectively, “Other State Privacy Laws”)
  • Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”)
  • Other Canada provincial privacy laws that may apply to 24 Seven Group  (“Provincial Laws”)

COOKIE POLICY

Information about our use of cookies and other tracking technologies

Our Sites use cookies and other online tracking technologies such as pixels (collectively, “cookies”) to distinguish you from other users of our Sites.  Cookies are small text or image files that are sent by us to your machine which we can access and use to identify your device when you visit our Sites in the future.  In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide device level tracking data to third party applications like Google Analytics, HubSpot, and ZoomInfo. 

The use of cookies helps us to provide you with a good experience when you browse our Sites and also allows us to improve our Sites and provide you with relevant ads relating to our talent services.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies (see Chrome, Safari, Firefox, & Internet Explorer). If you are using any other web browser, please review your browser’s official support documents.  Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Sites. 

For more information about deleting or controlling cookies, please see www.AboutCookies.org.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Sites. They include, for example, cookies that enable you to log into secure areas of our Sites, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality/personalization cookies. These are used to recognise you when you return to our Sites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our Sites, the pages you have visited, and the links you have followed. We will use this information to make our Sites and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.

ANNUAL PRIVACY POLICY FOR CALIFORNIA RESIDENTS

This ANNUAL PRIVACY POLICY FOR CALIFORNIA RESIDENTS (“California Notice”) supplements the information contained in the main privacy policy applicable to the 24 Seven Group (“we” or “us”) and applies solely to individuals who reside in the State of California (“consumers” or “you”). This California Notice sets out how we use and protect any personal information you may have provided to us through your use of the Service, by computer or mobile device, social media, by phone via text message, in writing or otherwise. We adopt this California Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws.

This California Notice explains how we collect, use, share, and store your “personal information” (as defined under the CCPA) in the past 12 months, and how you may exercise certain rights you have in connection with your privacy and personal information.

The categories of personal information under the CCPA are as follows in the table below.

CategoryExamples
A. IdentifiersA name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account username, screen name, password, or other similar identifiers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))A name, signature, address, telephone number, education or employment history, bank account number, credit card number, debit card number, or any other financial information
C. Protected classification characteristics under California/federal lawAge (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status
D. Commercial informationRecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
F. Internet or other similar network activityBrowsing history, search history, information on a consumer’s interaction with a website, video, application, or advertisement, including user generated content
G. Geolocation dataPhysical location or movements
H. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information
I. Professional / employment informationCurrent 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) (FERPA))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
K. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
L. Sensitive personal information(1) social security, driver’s license, state ID card, or passport number (2) account log-in, financial account, debit card/credit card number in combination with any required security or access code, password, or credentials allowing account access (3) precise geolocation (within a radius of 1,850 feet) (4) racial or ethnic origin, religious or philosophical beliefs, or union membership (5) contents of mail, email, and text messages (unless we are the intended recipient) (6) genetic and health data (7) biometric information for identification purposes (8) sex life or sexual orientation

Under California law, personal information is generally defined under California law as information that, by itself or in combination with other information, identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. Any personal information that we collect will be treated as set forth below and/or in our main privacy policy.

Contact Information

If you believe there has been some violation of this California Notice, if you believe that personal information you supplied to us has been compromised or inappropriately accessed by a person outside of the 24 Seven Group, or if you have any questions about this California Notice, please contact us using the contact details in the main privacy policy

If you do not agree to the collection and use of your personal information as described in this California Notice or in our main privacy policy, please do not provide us with any information and cease using the Services.

Personal information Collection and Disclosures

A requirement under the CCPA is to provide California residents with information on our data collection, use, disclosure, and retention (“processing“) activities related to personal information in the preceding 12 months.

Categories of Personal information Collected, Their Sources, and Purpose

The charts below describe the categories of personal information we collected over the past 12 months, including the sources from which we obtained the personal information and the purposes for which such data was processed. Please note that not all categories or specific types of personal information described below will be collected or processed for every individual and our data collection practices may vary based on the nature of your relationship with us and what information you choose to provide to us.

WEBSITE USERS

CategoryDo we Collect?Information SourcePurpose
A. IdentifiersYESFrom you directly or through your interaction with us or through our ServicesTo register you as a new client or candidate

To manage our relationship with you and/or asking you to leave a review or leave a survey

To enable you to partake in a prize draw, competition, or complete a survey

To administer and protect our business and our Sites, including for example, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

To comply with legal/regulatory obligations & exercise our rights
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))YESFrom you directly when you contact us or sign up to receive content from us
C. Protected classification characteristics under California/federal lawYESFrom you directly or inferred from your interaction with us and our Services (age and gender only)To verify your eligibility to register you as a new client or candidateTo comply with legal/regulatory obligations & exercise our rights
D. Commercial informationNOWe do not collectWe do not collect
F. Internet or other similar network activityYESFrom your interaction with us and our ServicesTo deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

To use data analytics to improve our Sites, Services, marketing, customer relationships and experiences

To make suggestions/recommendations to you about services that may be of interest to you

To comply with legal/regulatory obligations & exercise our rights
G. Geolocation dataYESFrom your IP address (location at the state and/or country level) when you access our Sites
H. Sensory data;NOWe do not collectWe do not collect
I. Professional / employment information
CategoryDo we Collect?Information SourcePurpose
J. Non-public education information (per FERPA)NOWe do not collectWe do not collect
K. Inferences drawn from other personal informationYESFrom your interaction with us and our ServicesTo deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

To use data analytics to improve our Sites, Services, marketing, customer relationships and experiences

To make suggestions and recommendations to you about services that may be of interest to you

CANDIDATES

CategoryDo we Collect?Information SourcePurpose
A. IdentifiersYESFrom you directly or through your interaction with us or through our ServicesFrom public sources such as LinkedInTo assess your skills, qualifications, and suitability for the assignment(s) you applied for

To carry out background and reference checks, where applicable and required by our client

To communicate with you about the recruitment process

To keep records related to our hiring processes and services with you

To comply with legal/regulatory obligations & exercise our rights
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))YESFrom you directlyFrom public sources such as LinkedIn
C. Protected classification characteristics under California/federal lawYES  From you directly or inferred from your interaction with us and our Services
D. Commercial informationNOWe do not collectWe do not collect
F. Internet or other similar network activityYESSee Website User Table aboveSee Website User Table above
G. Geolocation data
H. Sensory dataNOWe do not collectWe do not collect
CategoryDo we Collect?Information SourcePurpose
I. Professional/ employment-related informationYESFrom you directlyFrom our vendors (background checks)From public sources such as LinkedInTo assess your skills, qualifications, and suitability for the assignment(s) you applied for

To carry out background and reference checks, where applicable and required by our client

To communicate with you about the recruitment process

To keep records related to our hiring processes and services with you

To comply with legal/regulatory obligations & exercise our rights
J. Non-public education information (per FERPA)NOWe do not collectWe do not collect
K. Inferences drawn from other personal informationYESFrom your interaction with usTo assess your skills, qualifications, and suitability for the assignment(s) you applied for.
L. Sensitive personal informationYESFrom you directlyFrom our vendors (background checks)To carry out background and reference checks, where applicable and required by our client

To comply with legal/regulatory obligations & exercise our rights

CLIENTS AND SUPPLIERS

CategoryDo we Collect?Information SourcePurpose
A. IdentifiersYESFrom you directlyFrom public sources such as LinkedInTo facilitate the provision or receipt of Services

To provide or obtain feedback on Services

To communicate with you about provided Services

To provide you with our latest marketing materials (client data)

To record your candidate/communication preferences (client data)

To forward you details of potential candidates
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))YESFrom you directly  
C. Protected classification characteristics under California/federal lawYES  From you directly or inferred from your interaction with us and our Services (age and gender only)
D. Commercial informationNOWe do not collectWe do not collect
CategoryDo we Collect?Information SourcePurpose
F. Internet or other similar network activityYESSee Website User Table aboveSee Website User Table above
G. Geolocation dataYES
H. Sensory dataNOWe do not collectWe do not collect
I. Professional/ employment-related information
J. Non-public education information (per FERPA)
K. Inferences drawn from other personal informationYESFrom your interaction with us and our ServicesTo record your candidate/communication preferences (client data)
L. Sensitive personal informationNOWe do not collectWe do not collect

Disclosing Your Personal information

Over the last 12 months, we have disclosed your personal information with the following categories of third parties for the following purposes:                          

CategoryTypes of Recipients and Our Purpose for Sharing the Information
A. Identifiers.Internal Third Parties and External Third Parties
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California/ federal law.
D. Commercial information.Not applicable, we do not collect
F. Internet or other similar network activity.Third party marketing and social media providers, as described in the Cookie Policy

Internal Third Parties and External Third Parties
G. Geolocation data.
H. Sensory data.Not applicable, we do not collect
I. Professional / employment-related information.Internal Third Parties and External Third Parties
CategoryTypes of Recipients and Our Purpose for Sharing the Information
J. Non-public education information (per FERPA).Not applicable, we do not collect
K. Inferences drawn from other Personal information.Third party marketing and social media providers, as described in the Cookie Policy

Internal Third Parties and External Third Parties
L. Sensitive Personal informationInternal Third Parties and External Third Parties

Privacy Statements

Data Retention Period

Over the past 12 months we have retained your personal information in accordance with the retention timeframes noted in our main privacy policy for website users, candidates, clients, and suppliers.                                                                                               

Selling and/or Sharing Your Personal information

CANDIDATES, CLIENTS, AND SUPPLIERS

Over the past 12 months, we did not “Sell” nor “Share” your personal information, as such terms are defined under the CCPA. 

WEBSITE USERS

Over the past 12 months, we did not engage in any direct sale of your personal information as a way to generate monetary revenue.

However, as described in our main privacy policy and Cookie Policy, we have used certain third-party online analytics and advertising providers which may have access to your IP address, online ID, and online activity information. Such third-party access may cause you to receive targeted advertising based on your browsing behavior on our Site and elsewhere online.

As a California resident, such access for targeted advertising purposes may be considered “Selling” or “Sharing” your personal information under the CCPA. Under the CCPA, you have the right to opt-out of any such “Sale” or “Sharing” of personal information for targeted advertising purposes by using our interactive request form, which is available through the “Do Not Sell or Share My Personal Information” links on our Site. Go here if you wish to opt out of the selling and/or sharing of your personal information.  

Selling and/or Sharing Personal information of Minors

Over the past 12 months, we did not knowingly Sell or Share the personal information of minors under the age of 16 years old.

Sensitive Personal information Processing Activities

WEBSITE USERS, CLIENTS, AND SUPPLIERS

Over the past 12 months, we did not knowingly collect or use your sensitive personal information as defined under the CCPA).

CANDIDATES

Over the past 12 months, we did not use your sensitive personal information to infer characteristics about you (i.e., profiling) for a purpose that would grant you a right to limit such sharing.

Profling / Automated Decision making Activities

Over the past 12 months, we did not conduct profiling activities or make automated decisions about you based on your personal information.

California Notice of Financial Incentive

Over the past 12 months, we did not provide any financial incentives with respect to the collection of your personal information.

Your Rights and Choices

The CCPA provides California consumers with specific rights regarding their personal information which are further described in the “Your Legal Rights and Choices” section of the main privacy policy. If you would like to exercise any of your rights under the CCPA, please go to the “How to Submit a Privacy Request” section of our main privacy policy.  Please note that in certain instances we may be able to reject your request to the extent permitted under the CCPA.

Other California Privacy Laws

Shine the Light

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by contacting us.

Do Not Track

Some browsers also have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. We do not currently honor “do not track” signals.


chevron-down