Last Updated: 18 September, 2023
This Policy applies when you:
- create, activate and use a TalentNeuron user account and/or license;
- express an interest in or have signed up for our products including newsletters, apps, extensions, webinars, and e-books;
- register for, and attend a virtual webinar or in-person TalentNeuron meeting; or
- visit our websites, including our public and/or client websites, or social media sites (collectively, the “Websites”).
It does not apply to websites and mobile applications owned or operated by third parties and are not branded with TalentNeuron logos. Please review the privacy policies on those websites and applications directly to understand their privacy practices.
For purposes of this Policy, TalentNeuron is the controller (or business, as applicable) of personal information collected via our Websites and services. If you are a California resident, we provide additional information about how to exercise your data access rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”) in the “Your California Privacy Rights” section below.
For purposes of this Policy, unless otherwise required by applicable law, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. “Personal information” does not include information that is considered publicly available, aggregated, or deidentified under applicable law.
1. INFORMATION WE COLLECT
1.1 Sources from which we collect personal information
We may collect and process your personal information directly from you or from the following sources:
- Communications via our Websites: When you provide it to us through communications via our Websites, including through our contact information, when you register an account with us, and similar situations in which you have chosen to provide the information to us, including for customer services support. Any of our communications with you, including any phone calls, may be monitored and recorded for quality purposes.
- Products or services you request: Where you request a good or service from us, we will collect your personal information to process your request and otherwise contact you following a purchase.
- Referrals or recommendations: Referrals or recommendations, including from within the TalentNeuron group, from a third party, or from our send-to-colleague functionality, as described further below in Section 1.4;
- Social media: Social media sites and other external internet sites, such as Facebook, Twitter, or LinkedIn.
- Public resources: Resources such as telephone directories, newspapers, commercially available data resources, public registries, or public records.
- Interaction with our Websites and use of our services: When you use our Websites, we will automatically receive information using cookies and similar technology, including IP address, device identifiers, browser details, and information about usage of the Websites and related Internet activity (such as the site you came from, search engine(s) and keywords you used to find our Websites, the pages you view within our Websites, and access times). To offer you a consistent and personalized experience in your interactions with us, information collected through one service we provide may be combined with information obtained through other services. For example, we may use services from other companies that enable us to derive a general geographic location based on your IP address or other factors in order to customize certain services to your geographic area.
1.2 Categories of personal information collected
The categories of personal information we may collect and process (but only to the extent and in a manner consistent with applicable law) are as follows:
- Personal identifiers and personal details: We may collect your name, email address, social media handles, address, billing address, zip or postal code, telephone number, unique personal identifier, online identifier, Internet Protocol (IP) address, account name, or other similar identifiers. If you create an account, we also collect your username and password. We also collect identifiers that you post to our Websites.
- Demographic information: We collect your age, date of birth, gender, and other similar data when you choose to provide it to us as part of your profile, or when using features of our services or Websites.
- Commercial Information: We collect information such as products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies. This includes information about the transaction, such as product or service details and the date and location of the purchase.
- Payment Information: We collect billing information, such as your account number, credit card number, expiration date, card verification number, and billing address if you make a purchase.
- Internet or Other Electronic Network Activity Information: We may collect your IP address when you visit our Websites. We also use tracking tools like cookies and pixels to passively collect information about how you interact with our Websites and online content. This might include device identifiers, the type of browser and operating system you are using, your browsing and search history on our Websites, what areas of our Websites you visit and for how long, what products or content you view and click on, what site you came from to get to us and what site you go to when you leave us, and your interactions with our digital ads and content on other sites. We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. We may engage or otherwise allow other parties to also collect information on our Websites in these ways.
- Location Data: We may collect information about your general location using your IP address and your zip code.
- Audio and visual information: We may record audio during customer service calls for quality assurance purposes.
- Employment-related information: We may collect information about your work experience and previous employment, your education history, your resume, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa to work in the United States, and salary expectations. If you apply for a job, you can choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
- Inferences: We analyze your purchases, preferences, or other interactions and may create a profile for you to suggest other products or services you may be interested in.
- Information About Others: In some cases, we may also collect information you provide about others. We will use this information to fulfill your requests and will not send marketing communications to your contacts unless they separately opt in to receive communications from us.
1.3 How we use your personal information
We process your personal information only as necessary to enable us to provide our products and services, to perform our contracts entered into between you and us, to support our business functions, to ensure compliance with applicable laws, and for the purposes of our legitimate business interests, including the following:
- To create, activate and use a TalentNeuron user account and/or license;
- To facilitate the business through communication with corporate clients and other business contacts, for example, to communicate about webinars;
- For internal analysis and research to help us improve our existing products and services, and create new products and services;
- To send marketing to business contacts regarding our services and products which may be of interest and to promote our business and brand;
- To administer our Websites, investigate any complaints, and provide more customized customer service;
- To monitor social media content to manage relations with our clients and promote our business and brand;
- To personalize your experience of our Websites;
- To perform statistical and trend analysis to improve the user experience and performance of our Websites;
- To detect and prevent fraudulent and/or unlawful use of our Websites, products and services.
Where we collect and use information for our legitimate interests as mentioned above, we will not unfairly place our legitimate interests above what is best for you. Legitimate interests are our business or commercial reasons for using your personal information, such as (i) keeping our records up to date; (ii) providing the services to you; (iii) maintaining or administering the services; (iv) performing business analyses or for other internal purposes to improve the quality of our business and the services we offer; (v) prevention of fraud and financial crime to protect the public; (vi) communicating with you concerning programs or services consistent with our obligations to provide those services or otherwise; and (vii) participating in litigation, investigations, regulatory or governmental inquiries or for other legal or regulatory purposes involving our customers who use or have used our services or other third parties. For more information regarding our legitimate interests as applied to your personal information, please contact using one of the methods listed in Section 13 below.
Where you consent to our collection and use of your personal information (when required under applicable law), and we rely on your consent, you have the right to withdraw consent by contacting us using one of the methods listed in Section 13 below.
In certain circumstances, if you do not provide personal information which is required (for example, in relation to activating your TalentNeuron license), we will not be able to perform our contractual obligations or provide you with products and services. When this is the case, we will make it clear.
1.4 Additional information
Recorded Communications with TalentNeuron
We may ask to record calls for training, quality and research purposes. All recordings will be treated as confidential. If you do not want us to record your call, you will be given a chance to opt out. If your call is already in progress, you may ask us to turn off the recording at the start of the call.
Communication with Colleagues
You may use the send-to-colleague functionality on some of our Websites to send your colleagues information from TalentNeuron. In order to fulfill this request, we will ask you for your colleagues’ names and email addresses. We do not retain this data after the email is sent. Please be aware that your name and email address may be included in the communication sent to your colleague.
2. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your personal information to third parties as follows:
- To TalentNeuron group companies in order to process the data for the above mentioned purposes;
- When we have your consent or authorization to do so;
- To third parties who work on our behalf to service or maintain business contact databases and other IT systems, e.g., suppliers of the IT systems which we use to process personal information
- To third parties providing services to us or on our behalf who have a need to access your information, e.g., our professional advisors (e.g. auditors and lawyers)
- To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (e.g., disclosing data in appropriate situations for national security or law enforcement purposes);
- Subject to applicable law, in the event that TalentNeuron is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such a transaction, or for pre-transaction review in relation to such transactions.
Your personal information may be shared if we anonymize and/or aggregate it, as in these circumstances the information will cease to be personal information.
We may share information with our organizational clients about how their employees use the Websites and the resources available to them through the Websites (e.g., how employees used certain features of the Websites, utilization trends, which features were most popular with the client’s employees).
3. CHOICES ABOUT YOUR INFORMATION
We believe it is important to give you choices about the use of your information. We will use your information as described in this Policy. If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.
We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us using one of the methods listed in Section 13 below. If you gave us your email address to receive marketing communications, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information with third parties for their own promotional or marketing purposes unless you give us consent to do so or where permitted by applicable law.
We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot guarantee or warrant the security of any information you transmit via our Websites or apps. Please note that you are responsible for maintaining the security of your credentials used to access any TalentNeuron service or account, and you must report suspected unauthorized activity to us.
We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.
5. RETENTION PERIODS
We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained, and/or whether additional legal/regulatory obligations require us to retain it.
In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:
- the period required by tax and company laws and regulations; and
- as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.
6. COOKIES AND SIMILAR TECHNOLOGIES
Note that you may encounter cookies from our third-party providers that we have allowed on our Website that assist us with various aspects of our site operations and services.
Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.
We use various types of cookies, including session and persistent cookies and similar technologies, local shared objects, pixels, and gifs, and we permit some third-party cookies. Persistent cookies remain on your computer until you delete them, while session cookies are based on your browsing session and are deleted once you close your browser. First party cookies are used and controlled by us to provide services on our Websites, while third-party cookies are placed by our service providers and/or trusted third parties.
- Strictly necessary cookies: these are essential in order to enable you to move around the Website and use its features. Without these cookies, the services you have asked for cannot be provided.
- Performance cookies: also known as “analytical” cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around and use the Website. For example, they allow us to understand which pages are visited most often, and if visitors get error messages from web pages. All information collected by these cookies is aggregated and therefore anonymous.
- Functionality cookies: these cookies are necessary for the Website to operate and allow us to remember what choices you make and provide enhanced, more personal features. The information these cookies collect is typically anonymized and is not used to track your browsing activity on other websites.
- Advertising and marketing cookies: these cookies are used to send you advertising and marketing-related material tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. The third parties that provide these cookies may collect and combine information about your online activities over time, on other devices, and on other websites or online services, if those websites and online services also use the same advertising partners. Thus, although we do not track your website usage activity across non-affiliated websites over time, some third-party cookie providers may do so when you use the Websites.
6.2 Opting out of cookies
7. GLOBAL PRIVACY CONTROL SIGNALS
We receive and process Global Privacy Control Signals (“GPC Signals”) for requests to opt-out of sale or sharing. We process the commonly used and industry standard GPC Signals but because this is new technology and new providers may offer solutions, we will do our best to recognize, process, and honor a GPC Signal that meets the legal standards and is widely adopted in the industry.
Our Websites are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18. TalentNeuron does not knowingly collect personal information from individuals under the age of 18. If we discover that we have inadvertently collected personal information from anyone younger than the age of 18, we will delete that information. We do not sell personal information for valuable consideration or share the personal information for behavioral or targeted advertising of any individual we know to be under the age of 18.
9. YOUR DATA SUBJECT RIGHTS
In certain circumstances and jurisdictions, you have certain rights regarding your personal information. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. A summary of each right and how you can exercise it is set out below. To opt out of receiving commercial communications, please send an email to privacy@TalentNeuron.com. You may be able to use the Website to access and update the information that you have provided to us through your use of the Website or otherwise.
When you make a request, we may require that you provide information and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Where we receive your request to exercise one of these rights, we will respond without undue delay and within the time required by applicable law. This may be extended in certain circumstances, e.g., where requests are complex or numerous.
We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.
9.1 EU Privacy Rights
If you are a European Union resident, in accordance with TalentNeuron’s policies and procedures, you have the right to review, verify, correct, and request erasure of the personal information that we hold about you under certain circumstances. You also have the right to limit, restrict, or object to the processing of your personal information under certain circumstances. You may also have the right to request that we transfer your personal information to another party to the extent provided for under applicable data privacy laws. For more information on your rights, please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
If you want to review, verify, correct, or request erasure of your Personal Information; limit, restrict, or object to the processing of your Personal Information; or request a transfer of your Personal Information to another party, please contact us at privacy@TalentNeuron.com or write to us at
ATTN: Privacy Team
590 Madison Avenue,
40th Floor New York,
To protect your privacy and security, we also will take reasonable steps to verify your identity before granting access, making corrections, or following such a request to correct or delete your data.
When you contact us, we will respond as soon as possible and where possible within one month. If your request is more complicated, it may take longer to respond to you, but we will respond within three months of your request.
9.2 Your California Privacy Rights
California law requires us to provide California residents with additional information regarding how we collect, use, and share your personal information (“California Privacy Notice”). Persons with disabilities may obtain this notice in alternative format upon request by contacting us at privacy@TalentNeuron.com or calling +1-888-598-9905.
California Shine the Light. Although we do not currently share your information for other companies’ direct marketing purposes, residents of California have the right to request information from us regarding other companies to whom we have disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email privacy@TalentNeuron.com or write to us at:
ATTN: Privacy Team
590 Madison Avenue,
40th Floor New York,
Categories of personal information sold to or shared with third parties. We do not sell and have not sold your personal information or transferred personal information to third parties to use for their benefit in the past twelve (12) months. We do share and have shared certain personal information for targeted or cross-context behavioral advertising in the past twelve (12) months. However, we do not sell or share the personal information of minors under 16 years of age.
For purposes of this Policy, “sell” means the sale or transfer of your personal information to a third party for monetary or other valuable consideration, subject to certain exceptions in applicable law. For purposes of this Policy, “share” means transferring, making available or otherwise disclosing your personal information to another party for purposes of sending advertising to you based on your personal information obtained from your activities across distinctly-branded sites. “Share” and “sharing” as used in this section, does not include transfers of personal information described in this Policy as part of a corporate business transaction, such as a merger, acquisition, or joint venture, or in the event of insolvency, bankruptcy, or receivership. Should such an event occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy.
In the past twelve (12) months, we have shared the following categories of personal information with data analytics providers, operating systems and platforms, social networks, and cookie providers for the purposes described in Section 1.3 above:
- Personal identifiers and personal details
- Internet or Other Electronic Network Activity Information
- Geolocation Data
Please see Section 6 on “Cookies and Similar Technologies” above for information about the collection and use of personal information by third parties who process information collected by cookies and similar technologies that we permit them to use on the Websites.
Categories of personal information disclosed to service providers. We disclose personal information to certain third parties to enable them to fulfill the purposes described in Section 1.3 above. The personal information provided to our service providers is limited to that personal information which is necessary for them to fulfill these purposes. Our service providers have contractually agreed not to use your personal information other than as necessary to fulfill the applicable purposes and in accordance with California law. In the preceding twelve (12) months, we have disclosed the categories of personal information described in Section 1.2 above, with the following categories of service providers:
- Data Analytics Providers
- Operating Systems and Platforms
- Customer Support Providers
- Social Networks
- Workforce Management and Human Resource Management Providers
- Government Entities
We disclose personal information to our service providers in accordance with the purposes described in Section 1.3 above.
Individual Rights. California law may provide you with the following privacy rights:
- Right to Know and to Access. Subject to certain exceptions, and legal obligations, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, including whether we sell or share such information. You also have the right to request access to personal information collected about you and information regarding the following:
- The categories of personal information we collected about you;
- The categories of sources of that information;
- The business or commercial purposes for which we collect, sell or share personal information about you;
- The categories of personal information about you that we have disclosed about you and the categories of persons or vendors to whom it was disclosed for a business purpose; and
- The specific pieces of personal information we have collected about you.
This information is disclosed in Section 1 above. You may also submit a request for this information as described below. To protect your personal information, we may request additional information to verify your identify before we act on your request. To the extent legally required, we will provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We may provide this data to you via email to the email address you have provided with your request.
- Right to Correction. You have the right to request that we correct any inaccurate personal information we maintain about you. In response to your request, we may request additional information showing that the information you want to correct is inaccurate.
- Right to Deletion. You may request that we delete your personal information. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
- Right to Opt-Out of the Sale or Sharing of Personal Information to Third Parties. You have the right to opt out of the sale or sharing of your personal information by TalentNeuron to third parties.
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to fulfill the purposes reasonably expected by an average consumer who requests those goods or services. California law considers the following pieces of personal information to be “sensitive:” social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data. We do not knowingly collect or use sensitive personal information for any purposes, including to infer characteristics about you.
- Non-Discrimination or Retaliation. We will not discriminate or retaliate against you for exercising any of your data privacy rights.
How to submit a request. You or an authorized agent may submit a request to exercise your rights through one of the following means:
- By filling out a Consumer Data Request Form available .
- By calling us toll-free at +1-888-598-9905
- By emailing us at privacy@TalentNeuron.com.
California Online Privacy Protection Act Notice Concerning Do Not Track Signals. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please visit: www.allaboutdnt.org.
9.3 Nevada Residents
Nevada law requires us to provide certain Nevada consumers the ability to opt out of the “sale” of “personally identifiable information” as such terms are defined under Nevada law. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing privacy@TalentNeuron.com. Once verified, we will maintain your request in the event our practices change.
10. INTERNATIONAL TRANSFERS
TalentNeuron is a global company and we may transfer personal information to other TalentNeuron group companies or suppliers outside your country. TalentNeuron will take reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.
TalentNeuron may transfer and maintain the personal information of individuals covered by this Policy on servers or databases outside the European Economic Area (“EEA”). Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA.
The countries to which we transfer data outside of the EEA may include any of the countries in which TalentNeuron does business.
All TalentNeuron entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of information.
11. LINKS TO EXTERNAL WEBSITES
TalentNeuron’s services and technologies, including its Websites, may contain links to other websites or resources that are not part of the products, programs, or services run by TalentNeuron. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the privacy policies of those sites and are not covered by this Policy. We encourage you to read the privacy policies of those other websites.
13. CHANGES TO THIS POLICY
From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on this Website. We recommend you regularly review this Website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page. If you use our Website after any changes are effective, you are agreeing to comply with and be bound by them