This privacy policy applies to all information collected by Tekberry, Inc. (“Tekberry,” “we,“ “us,“ “our“) and its affiliates (as applicable, SOAL Technologies and its subsidiaries and affiliates, herein “Controller”). This privacy policy describes the personal information we collect, how we use it, and your rights regarding this information. 

This Privacy Notice applies to our job candidates and recipients of our career services, people we source or place on assignment with one of our clients, individuals to whom we provide outplacement or career transition services, users of the website and our Career Portal, and representatives of our business partners, clients and vendors.

With this data protection notice, we are providing information about why we collect and use your personal information, how your information is shared, retained and protected, and how you can exercise your personal choices.  We will also explain how you can find out what personal information we hold about you. 

This data protection notice applies to the processing of personal information we collect when you visit our websites, apps or Career Portal (“Sites”), use our services, or when you provide it to us in any other way. We also collect information from third party sources such as Job Posting websites that provide access to uploaded resumes and job posting applicants. Additional detail about our practices is provided below based on whether you are a website visitor, candidate, temporary worker or employees, prospective client or client.

We provide staffing services to clients and job services to candidates seeking current or future job opportunities. We collect personal information to help connect candidates with jobs at Tekberry and Tekberry clients. We will process your personal information in accordance with this data protection notice (such personal information sometimes also referred to as “data”). For greater clarity, processing means any operation or set of operations which is performed on your personal information, such as collection, storage, adaptation, disclosure, restriction, deletion or destruction, among others (collectively referred to as “processing” or “process”). 

Web beacons

Our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users, to query whether users do not open our emails and wish to continue receiving them, and to inform our advertisers in aggregate how many users have clicked on their advertisements. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you should select to receive emails from us in plain text rather than HTML.

What personal information does the Company collect and use?

We collect personal information about you in various ways, such as through our Sites, social media websites and third-party job posting websites; at our events and through phone; through job applications and in connection with in-person recruitment; and in connection with our interactions with clients and vendors. We may collect the following types of personal information (as permitted under local law): 

• contact information (such as name, postal address, email address and telephone number);
• username and password when you register on our Sites;
• information you provide about friends or other people you would like us to contact. (The Controller assumes that the other person previously gave an authorization for such communication); and
• other information you may provide to us, such as in surveys or through the “Contact Us” or “Apply” features on our Sites

In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data (as permitted under local law): 

• employment and education history;
• language proficiencies and other work-related skills;
• Social Security number, national identifier or other government-issued identification number;
• date of birth;
• gender;
• bank account information;
• citizenship and work authorization status;
• benefits information;
• tax-related information;
• information provided by references; and
• information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment. 

We may also collect the following types of personal data upon receiving your explicit consent (where required by applicable law): 

• disabilities and health-related information; and
• results of drug tests, criminal and other background checks. 

In addition, we may collect information you provide to us about other individuals, such as information related to emergency contacts.

Why do we process your personal information and how long do we keep it for?

Purpose of processing:

To respond to your request or questions, or provide information to you, when you contact us, make a request to us, or otherwise make your contact information available to us.

To send you direct marketing via e-mail, messaging, phone, social media or any other channel. This includes information such as job openings, events or newsletters that may be of interest to you.

Type of data

Contact forms and Surveys Data, Identity Data, Contact Data, Communications Data, Social Media Data if applicable

Legal basis to process your personal information

Consent where we are required under the law to obtain consent.

Fulfilment of our legitimate interests to promote our job openings and services where we are not obliged to obtain consent by law.

Retention period

For as long as you have opted in to receive our communications.

How do we collect your personal information?

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

1. Direct interactions. You may give us your Identity Data, Contact Data, Contact Forms and Surveys Data, Communications Data, Social Media Data and Events Data by filling in forms or by corresponding with us by, phone, email or otherwise.
2. This includes personal information you provide when you:
   • apply for our job openings;
   • log in to our Career Portal;
   • subscribe to our publications or notices;
   • request information about job opportunities to be sent to you;
   • give us feedback or contact us.
3. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies and from the communications we receive from your browser. Please see our Cookie Policy for further details about how we use cookies and other similar technologies.
4. Third parties or publicly available sources. We will receive personal information about you from various third parties and public sources as set out below:
   • Public information made available by you on social media and similar websites and apps such as Job Posting websites;
   • Public information about you in directories, for example of professional memberships or qualifications. 

What marketing communications do we send?

Communication with Individuals
We will only send marketing communications to you, as an individual, if you have consented to us doing so.

To receive marketing or communications about job openings, you can opt-in by checking the relevant box located on the form on which we collect your data, or we can send you these communications based on our legitimates interests to promote our services where we are not obliged to obtain your consent by law.

Communication with Businesses
We process your data within the scope of an existing business relationship with you or your company because:

• We have a contract with you (or are considering entering into a contract with you). In this case, the personal information we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship; or
• It is in our legitimate interests for the conduct of our business activities (for example, to communicate with you in a ‘business to business’ capacity in order to promote our services that we believe will be of interest to you or your company). In that regard, we may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company; or
• You consented to receive our marketing communications via e-mail or SMS as an individual at our clients/companies. In this case, we will send you marketing communications to develop or maintain a business relationship in accordance with applicable electronic and marketing communications laws. These communications may include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click on. We will usually offer you a check box on the forms we use to collect your personal information. If you agree to receive the communications, you must click the box.

How to unsubscribe?
In any case, where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the email. The same can be done when we send SMS by replying STOP. In addition, you can also exercise your opt-out right at any time by contacting us through our website.

Do we use artificial intelligence?

Yes, we do use artificial intelligence (AI) at times. However, we do not use your personal information in any automated decision making (a decision made solely by the creation and application of technologies without any human intervention) or profiling (processing of personal information with a range of technologies that reduce human intervention to evaluate certain conditions about an individual) that produces a legal effect or similarly significant effect concerning you.

We use a range of technologies to analyze data. In all cases, there is always human intervention in these processes, as we use these tools to support our expert human decision makers.

For example, when you are searching for a job as a “warehouse worker” we will display alternative but close job offerings like “pick packer” as well. The piece of processing that might use AI (for instance machine-learning, logic- or knowledge based and statistical approaches) is based on Natural Language Processing techniques to calculate similarities of words and word meanings. In any case these results are only shown to you as recommendations to make an informed decision about your application.

We use or provide technologies through our website that use artificial intelligence:

Do we share your data with third parties?

To facilitate our efficient use of your information and to provide you with the content and/or resources and/or services, we disclose your information to third parties. However, this disclosure will only occur in the following circumstances:

• To our clients. We will, for example, engage a client to carry out administrative and operational work in support of our relationship with you. The client(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; the relevant clients are those seeking our workforce augmentation services, and back office finance and accounting management providers (who need to handle details of candidates in order to process accounts payable and receivable).

• To affiliates. Your information may be shared with the Controller of other relevant job opportunities that are available to them and that might align with your interests and skillsets.
• To government or law enforcement authorities. We will share your data with government, police, regulators or law enforcement agencies authorities if, at our sole discretion, we consider that we are legally obliged or authorized to do so or it would be prudent to do so.

What data security measures do we have in place?

We understand how important is to protect your personal information. We have implemented operational procedures and adequate technical and organizational security measures to prevent any unauthorized access, alteration, deletion or transmission of this personal information.

Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party; for this reason, any transmission is at your own risk.

What are your rights regarding your personal information?

Under applicable data protection laws, you have the following rights:

• Right to access and obtain a copy of your personal information
  You are entitled to request confirmation of whether we process any of your personal information. Where this is the case, you may have access to your personal information and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information. In some limited circumstances, you also have the right to request that we transfer (“port”) your personal information direct to another third-party provider.
• Right to correct your personal information
  If you can demonstrate that the personal information we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
• Right to be forgotten or to delete personal information
  In certain circumstances you have the right to have your personal information deleted. You may make such a request at any time and we will evaluate if your request should be granted, however this right is subject to any legal obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
• Right to restrict or object to the processing of your personal information
  In certain circumstances you have the right to obtain restriction of the processing of your personal information, or to object to certain processing thereof on grounds relating to your particular situation.
• Right to withdraw consent
  You have the right to withdraw consent at any time where we are relying on consent to process your personal information. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.  

If you want to exercise any of your rights, please use our Contact Us form.

Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your personal information has arisen.

How do we handle changes to this Privacy Notice?

The terms of this Privacy Notice may change from time to time. We shall publish any material changes to this Privacy Notice through appropriate notices either on this Website or contacting you using other communication channels.

Contact

In case you:

• have any questions or concerns regarding this Privacy Notice,
• would like further information about how we protect your information (for example when we transfer it outside your country), or
• want to contact Tekberry, please email Tekberry at support@tekberry.com
• To exercise any of your rights related to your personal information, please fill in the Contact Us form.