INTRODUCTION
This privacy policy (“Privacy Policy”) describes the information collection practices that Flo Recruit, Inc. (“Flo Recruit,” “we,” “us,” or “our,” if not explicitly referring to one company) follow when handling Personal Information(defined below) that we collect or receive in conducting our business, including through our products, services, content, websites, and user applications (the “Sites”), as further explained below.
EU Users. If you are a resident of the European Union (“EU”), you may have additional rights under the EU GeneralData Protection Regulation(the “GDPR”) with respect to your PersonalInformation, as outlined below. For the purposes of this Privacy Policy, references to the EU also include the United Kingdom, Switzerland, and the EuropeanEconomic Area countries Iceland, Liechtenstein, and Norway.
California Users. If your Personal Information is subject to the California Consumer Privacy Act, California Civil Code §1798.100 et seq. (with any implementing regulations and as may be amended from time to time, “CCPA”),please review this Privacy Policy and see the section below regarding CaliforniaUsers for a description of your rights under and other information related to the CCPA.
Nevada Users. If the information we collect from or about you is subject to Nevada’s data privacy law, Nevada Revised Statutes § 603A.300 et seq. (with any implementing regulations and as may be amended from time to time, “Nevada Privacy Law”), please review this Privacy Policy and see the section below regarding Nevada Residents for a description of right under and other information related to the Nevada Privacy Law.
DEFINITIONS
“Data Processor” means a third party that processes Personal Information on behalf of and pursuant to the instructions of Flo Recruit.“Personal Information” means any information relating to an identified individual, or to an individual who can be identified, directly or indirectly, by reference to such information, which may include, an identification number or one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity. Without limiting the foregoing, Personal Information does not include information that is de-identified or corporate information that relates to an organization but not to an individual, such as a corporate name, corporate address or general corporate phone number.
INFORMATION WE COLLECT FROM OR ABOUT YOU
Personal Information You Provide To Us. We collect Personal Information that you provide to us through our Sites, and in connection with other business dealings we, or our channel sales and business partners, may have with you. Such information may include:
- First and last name
- Company name
- Title
- Email address
- IP address
- Login user name and password
- Mailing address
- Telephone number
- Personal preferences regarding services
- Location
Information we receive from third party sources: Some third parties such as our business partners and service providers provide us with PersonalInformation about you, such as the following:
- Account information for third party services: If you interact with a third party service when using our Sites, such as if you use a third party service to log-in to our Sites (e.g LinkedIn), or if you share content from our Sites through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.
- Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements, or communications:
--> Job Title/Function
--> Business Address
--> Topics of interest
--> Firmographic information (company size by employees or approximate revenue band)
--> Role in purchase decisions
Information we automatically collect when you use our services: Some PersonalInformation is automatically collected when you use our services, such as the following:
- Computer name
- Hostname
- External IP
- OS type
- OS version
- Endpoint Scans collect additional data:
--> IP address (source and destination)
Website Usage Information We Collect. In addition to Personal Information that you choose to submit to us, whenever you visit or interact with our Sites, we may collect or store information about your interaction with our Sites(“Usage Information”). This Usage Information may include:
- your IP address or any other unique identifier assigned to the device that you use to access our Sites;
- the functionality and characteristics of your device, including type of browser, operating system and hardware, mobile network information, and in some cases location information;
- the URL that referred you to our Sites, if any;
- your activities on our Sites, such as which webpages you visit, what terms you searched within our Sites, and which links within our Sites that you click on; and
- the time of day that you visited our Sites and how long your visit lasted.
Usage Information is typically anonymous information; however, if it is combined with your Personal Information in a manner that reasonably allows it to be associated with your identity, or is otherwise considered PersonalInformation under applicable law, it will be treated as Personal Information under this Privacy Policy, and, if you are an EU resident, it may be consideredPersonal Data and be subject to the section applicable to EU users below.
We use certain common methods and technologies to collect and store UsageInformation about your interaction with our Sites (“Analytic Technologies”). TheseAnalytic Technologies may be downloaded to the personal computer, laptop, tablet, or mobile phone that you use to access the Sites (“Your Device”). The specific Analytic Technologies that we use are as follows:
- Cookies. A cookie is a data file placed on Your Device when you visit our Sites. We use cookies only to facilitate the use and navigation of our Sites and to remember you and your preferences in case you revisit our Sites in the future and to conduct range measurement. Information collected relates to technical information (e.g. your browser, a timestamp, and a unique identifier). Almost all browsers allow blocking of cookies in their entirety, removal of existing cookies, or warning to prevent the placing of a cookie. You can find more information on this functionality in the documentation or in the help file of your browser. Please note that blocking of cookies might impede your use of our Sites. If you are a resident of the EU or other jurisdiction that requires us to obtain your consent to use cookies on our Sites, then you will have an opportunity to manage your cookie preferences on such Sites; except that certain cookies are essential to enable core site functionality, and you cannot choose to disable those cookies.
- Do Not Track Policy. Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Sites.Just like any other usage information we collect, this information allows us to improve the Sites and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track”option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Sites do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Sites and after you leave our Sites.
- Analytics. We use analytics applications, including “Fullstory”, to collect information about use of the Sites. Fullstory collects information such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to coming to a website. We use the information obtained from these applications only to improve our Sites and our product and service offerings. The information generated about your use of ourSites will be transferred and saved to the vendor’s server in the UnitedStates. You can opt-out of Fullstory tracking by emailingkatherine@florecruit.com with your request.
- Web Beacons. A web beacon, including tracking pixels, is a small graphic image or other web programming code, also known as “1×1 GIF” or “clear GIF.” We may download web beacons to Your Device when you access our Sites or through email messages that we send to you. Web beacons are used to improve your experience on our Sites. Web beacons also help us to understand whether users read email messages and click on the links contained within those messages so that we can deliver relevant content and messages. Our web beacons may collect certain of your contact information(e.g., the email address associated with an email message that contains a web beacon).
- Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with our Sites, such as which links within our Sites you click on, which type of browser or device you use (e.g. mobile or desktop version). We use such information to enhance the user experience. This code is downloaded onto Your Device when you access ourSites and is deactivated or deleted when you leave our Sites. Identification of the user does not take place.
Information We Receive From Third Parties. We may receive PersonalInformation about you from third parties who recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number, and email address. It may also include information on the content, products, or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business. We may also obtain Personal Information about you from third parties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction. This Personal Information will be treated in accordance with thisPrivacy Policy.
HOW WE USE YOUR INFORMATION
Business Use. We use your Personal Information primarily to facilitate our ongoing and proposed business dealings with you (“Business Use”). This includes to: (1) process business transactions with us that you initiate, including without limitation orders of services and the creation of user profiles; (2)establish and maintain customer accounts so that we may provide services of ours requested by you or your company; (3) register you as a user of these services so that you may access them through our Sites or otherwise; (4)communicate with you about updates, maintenance, outages, or other technical matters concerning these services; (5) provide you with training and support regarding usage of these services; (6) notify you about changes to any of the policies and procedures for use of these services; (7) verify the accuracy of account and technical contact information we have on file for you and your company in relation to these services; and (8) respond to questions or inquiries that you or your company may have about our services.
We also may use your Personal Information as required for us to comply with laws and regulations relating to the services that we provide in any of the jurisdictions in which we or our affiliated companies operate, including theUnited States, and we may use Usage Information internally within Flo Recruit to help us improve our services, or to develop new services. We may also use your Personal Information to personalize the content of the Sites and communications based on your preferences, and to comply with our legal or contractual obligations and to resolve disputes. Additionally, we may use yourPersonal Information to protect against or deter fraudulent, illegal, or harmful actions and to enforce our terms and conditions of use (depending on which product or service you are using).
Marketing Purposes. With your consent or as otherwise permitted by applicable law, we may use your Personal Information for purposes relating to the marketing of our content and services, or those of our business partners (“Marketing Purposes”). This includes to: (1) send you newsletters, press releases, event announcements, and other similar communications regarding the services that we offer; (2) market or promote our services to you, including by offering you trial or limited access to certain of our services; (3) solicit input from you regarding improvement of our services; (4) inform you of third-party offerings that we think you or your company may be interested in which relate to our services; (5) send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our services; and (6) other purposes that we disclose to you at the time we obtain your consent.
Data Integrity. You are responsible for the accuracy of all PersonalInformation that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your Personal Information, and to update that information as appropriate. We will take reasonable steps to ensure that thePersonal Information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.
WITH WHOM WE MAY SHARE INFORMATION
Within Flo Recruit. Flo Recruit is a company that transacts business across national borders. Accordingly, from time-to-time and subject to the provisions of this Privacy Policy governing “CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES” (see below), we may share your PersonalInformation and Usage Information within Flo Recruit (i.e., between and among Flo Recruit and its subsidiaries). Such information may be used by each Flo Recruit entity for internal business and operational purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorized by you.
Outside of Flo Recruit. We may share your Personal Information with Customers,Data Processors and Partners, as described below, and with other third parties for purposes disclosed to you at the time you provided the information, or as subsequently authorized by you. From time to time, we also may offer you the option of sharing your Personal Information with third parties in order to receive information and/or marketing offers from them or other persons. If you consent to the sharing of your Personal Information for these purposes, it will be subject to the privacy policies and business practices of those third parties.If you later decide that you no longer want us to share Personal Information with such third parties, please contact us as indicated below under the section“CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES.” We will process your request in a reasonable period of time. Note, however, that if you no longer wish to receive communications from a third party which has already received your Personal Information from us, you will need to contact that third party directly to inform them of this.
Customers. We share your PersonalInformation with Flo Recruit customers, including employers and recruiters, to facilitate in their recruiting processes. All such sharing is subject to your first consenting to such disclosure. If you consent to the sharing of your PersonalInformation with our customers, it will be subject to our privacy policy and terms of use.
Data Processors. We may, from time to time, employ DataProcessors to perform services on our behalf, such as: (1) hosting our Sites, products, and other applications; (2) designing and/or operating certain features available through our Sites; (3) sending emails and other communications relating to our services; (4) fulfilling and processing orders for our services; (5) assisting with promotions and conferences relating to our services, or those of our business partners; (6) providing analytic services, such as in relation to the tracking of usage of our Sites; or (7) performing other administrative services for us. We may provide these Data Processors with access to your Personal Information in order for them to complete a requested transaction or otherwise perform services for us or for you on our behalf. Prior to allowing our Data Processors to access your Personal Information, we will enter into a data protection agreement or addendum (“DPA”) with them to ensure that they handle and process the information in accordance with this PrivacyPolicy and applicable law as instructed by us.
Partners. We may also share your contact information with the following partners so that we can better serve you:
-Managed Service Providers: we may share your contact information with third parties that provide an offering or service that runs the Flo Recruit product for you. If that managed service provider is also a Flo Recruit reseller or distributor, you may purchase the Flo Recruit product directly through them.
-Implementation Partners: we may share your contact information with partners who can help you with implementation and integration of Flo Recruit into your environment.
-Training Delivery Partners: we may share your contact information with partners that we work with to deliver training for Flo Recruit products in certain locations, so that such partner can facilitate the delivery of the training directly to you.
-Applicant Tracking Partners: we share your contact information with partners that provide applicant tracking systems to improve your user experience and improve the likelihood of matching applicants with employers.
Site Hosting. Our Sites and the servers on which they are hosted are operated in the United States in which we conduct our business. Thus, yourPersonal Information associated with our Sites may be transferred to and/or processed in a country other than that from which it was collected. The data protection laws in those countries may differ from those of the country in which you are located. The servers may be operated by third party hosted service providers.
Links to Other Websites and Applications. The Sites may contain various links to, as well as plug-ins or widgets from, social media and other third-party websites or applications, which may provide additional information, goods, services, and/or promotions. These third-party websites or applications are owned and operated independently of Flo Recruit, and may have their own separate privacy and data collection practices. We are not responsible for the privacy practices of any third party; therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your PersonalInformation with them.
Community Forums. Our Sites may offer message boards, chatrooms, blogs, and other public areas (“Community Forums”) where you can interact with our employees, other customers, post images, data, requests, questions, comments, suggestions, or other content, including your Personal Information (“User Submissions”). To participate in Community Forums, you may be asked to select a user name and password and/or provide us with your email-address, and to agree to the terms of participation for those Community Forums. We use this information to identify you and to contact you, if needed, for the provision of those Community Forums. You are able to change your email preferences or discontinue your participation in the Community Forums at anytime. Your password and your email-address will not be visible to other users or shared with third parties. You should be aware that any User Submissions you post to a Community Forum, as well as your user name, may be viewed by other members of that forum. If you choose to voluntarily post User Submissions to a Community Forum, be aware that such information is viewable by anyone else on that Community Forum. Think carefully before you post and use caution before disclosing anyPersonal Information in a Community Forum. We are not responsible for the accuracy, use, or misuse of any User Submission that you disclose or receive through a Community Forum. We might also delete User Submissions without further notice if they include harmful or inappropriate content (e.g.,pornographic material, content encouraging vandalism, crime, terrorism, racism, violence, or cruelty), or infringe any third party’s rights or applicable law.
Promotions. We may offer various promotions (“Promotions”) through theSites or elsewhere that may require registration with your Personal Information. If you choose to enter or otherwise participate in a Promotion, your Personal Information may be disclosed to third parties in connection with administration of the Promotion, such as in connection with winner selection, prize fulfillment, and as otherwise required by law. By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice, and/or likeness in advertising or marketing materials. These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time.
Affiliates and Business Transfers. We may share your Personal Information with our affiliates. Additionally, Flo Recruit or any part of its business, including our Sites, may be sold at some point in the future. Should this occur, your Personal Information may be transferred to a subsequent owner, co-owner, or operator of the business unit or Site. We also may disclose and transfer your Personal Information in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process. In all such cases, this Privacy Policy will continue to govern the use and disclosure of such information.
Legal Protections and Law Enforcement. We may access, use, preserve, transfer, and disclose to third parties your Personal Information to: (1) satisfy any applicable law, regulation, subpoena, governmental request, or legal process if, in our good faith opinion, such is required or permitted by law;(2) protect and/or defend this Privacy Policy or other policies or terms of use applicable to our Sites, including investigations of potential violations thereof; (3) protect the safety, rights, property, or security of Flo Recruit or any third party; and/or (4) detect, prevent, or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, Internet service providers, wireless service providers, and/or law enforcement agencies, to access and use yourUsage Information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.
CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES
Upon your request, we will grant you access to your PersonalInformation that we hold, as well as such other related rights as are provided by applicable law. If you are a California or Nevada resident, please review the sections below entitled “CaliforniaResidents” and “Nevada Residents,” respectively, for further description of your rights. We reserve the right to take reasonable steps to authenticate the identity of any individual seeking access to Personal Information. We may provide web pages or other mechanisms on our Sites through which you can update subscription preferences. You can also contact us to update your Personal Information or change your preferences. Our contact information for these purposes is by email at privacy@florecruit.com. If you receive a marketing communication from us by email, you may also opt out of receiving future email marketing communications by following the opt-out instructions provided in that email. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters, and that these communications may be unaffected if you choose to opt-out from marketing communications.
In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of that information.In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. Also, if you have posted any User Submissions to a Community Forum, these communications cannot generally be removed.
INFORMATION SECURITY
We will take reasonable precautions to protect your Personal Information in our possession from loss, misuse, and unauthorized access, disclosure, alteration or destruction. We will make reasonable efforts to keep your PersonalInformation reliable for its intended use, accurate, current and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as credit card information. While we strive to secure your Personal Information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.
ENFORCEMENT
We will conduct periodic internal compliance audits of our relevant privacy practices to verify adherence to this Privacy Policy. We encourage you to raise any questions or concerns that you may have about the way we process yourPersonal Information by contacting us at the address set forth below. We commit to resolve questions and complaints about your privacy and our collection or processing of Personal Information about you. If you believe that we are not complying with the terms of this Privacy Policy or other legal requirements, you should first contact us by email at privacy@florecruit.com. We will investigate and will do our best to internally resolve any complaints and disputes you bring to our attention regarding the use and disclosure of yourPersonal Information.
CHILDREN
The Sites are intended for business use. We do not knowingly collect or solicitPersonal Information from anyone under the age of 16. If you are under16, please do not attempt to register for the Sites or send any PersonalInformation about yourself to us. If we learn that we have collected PersonalInformation from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided usPersonal Information, please contact us at privacy@FloRecruit.com.
EUROPEAN DATA SUBJECTS: PRIVACY SHIELD AND EU GENERAL DATA PROTECTION REGULATION (GDPR)
Privacy Shield. Flo Recruit, Inc. in the United States participates in theEU-U.S. Privacy Shield Framework (the “Privacy Shield”). Flo Recruit, Inc. is a company with international operations and customers. We have developed global data security practices designed to ensure that personal information is appropriately protected. When you submit Personal Information to Flo Recruit, Inc. you are consenting to the transfer of the Personal Information to the United States or other jurisdictions which maybe outside of the jurisdiction in which you reside and which may not provide the same protections and use restrictions on Personal Information as your jurisdiction of residence. Flo Recruit, Inc.’s participation in the Privacy Shield applies to allPersonal Information received in the United States from the European Union, such as Personal Information about former, current, or prospective corporate customer contacts received from the EU(collectively “EU PersonalData”).“Data subject” means an individual who is the subject of the EU PersonalData. We are committed to subjecting such EU Personal Data to the PrivacyShield, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, andRecourse, Enforcement and Liability (the “Privacy Shield Principles”). To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s PrivacyShield List https://www.privacyshield.gov/. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
You have the right to exercise choice (opt-out) from our disclosure of EUPersonal Data to a third party. (Please see the section on WITH WHOM WE MAY SHARE INFORMATION above for details of such disclosures.) If consent has been given, you also have the right to opt out of the use of your EU Personal Data for direct marketing purposes. To exercise these rights, please send us an email at privacy@florecruit.com or follow the instructions in any direct marketing message you may have received (e.g., click the provided opt-out link in the email message).
Please contact us as specified below if you have any questions, need access to your EU Personal Data, or otherwise need assistance. We remain responsible for our collection, use, and disclosure of EU Personal Data in accordance with thePrivacy Shield. We also are responsible for third party agents that are processing such data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. In certain situations, we may be required to disclose EU Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
If you are an EU data subject with an unresolved complaint or dispute arising under the requirements of the Privacy Shield, we agree to refer your complaint under the Privacy Shield to an independent dispute resolution mechanism. That independent dispute resolution mechanism is the International Centre forDispute Resolution, the international division of the U.S.-based AmericanArbitration Association. For more information and to file a complaint, you may contact the International Centre for Dispute Resolution by phone at+1.212.484.4181, or by visiting the website http://go.adr.org/privacyshield.html. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Privacy Shield. In addition, under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, EU data subjects may invoke binding arbitration before the Privacy Shield Panel jointly created by the U.S. Department of Commerce and the European Commission.
Please contact us at privacy@florecruit.com if you have any questions, wish to exercise your rights of access, or to request the correction, amendment, removal, and/or limitation of the use and disclosure of your EUPersonal Data or seek other assistance as described above.
GDPR. For this GDPR section, we use the terms “Personal Data” and“processing” as they are defined in the GDPR, but “Personal Data” means information that can be used to individually identify a person, and“processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Flo Recruit is the controller of your Personal Data processed in connection with the Sites. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data(i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of thisPrivacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@florecruit.com.
What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Sites. Please see the section INFORMATION WE COLLECT FROMOR ABOUT YOU above for details of the Personal Data we collect. For the purposes of this Privacy Policy, when we use the term Personal Information, that is intended to also indicate Personal Data pursuant to the GDPR and EUPersonal Data pursuant to the Privacy Shield in each case if the applicable data subject is an EU resident.
How Do We Use Your Personal Data? Please refer to the section on HOW WEUSE YOUR INFORMATION above for details of how we use and process your PersonalData.
Lawful Bases for Processing. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing may include consent, contractual necessity and our “legitimate interests,” as further described below.
- Contractual Necessity: When you purchase our services, we process your contact information (e.g., name, phone number, address, email address) as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms and Conditions or other agreement with you, which enables us to provide you with the services you request. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Sites or our services that require such data.
-Legitimate Interest: We may also process your contact information and other categories of Personal Data described in the INFORMATION WE COLLECT ABOUT YOU section above for our legitimate interest purposes.
- Examples of these legitimate interests include:
--> Operation and improvement of our business, products, and services
--> Provision of customer support
--> Protection from fraud or security threats
--> Protecting the security of your account with us
--> Providing you with a sign-in method
--> Determining your geographic location and preferences so that we can serve you better
--> Compliance with legal obligations
--> Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we processPersonal Data based on your consent, it will be expressly indicated to you at the point and time of collection. If you provide us with opt-in consent to receive marketing information from Flo Recruit, we will process your email address for the purpose of sending you marketing information about our services. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent any time by selecting“unsubscribe” in the marketing email.
- Other Processing Grounds: From time to time we may also need to processPersonal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers, and agents who work on our behalf and provide us with services related to the purposes described in this PrivacyPolicy or our Terms and Conditions. For more information on such third parties, please refer to the section titled WITH WHOM WE MAY SHARE INFORMATION above.
How Long Do We Retain Your Personal Data? We retain Personal Data about you in accordance with our company’s data retention policy. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation.Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of PersonalData and applicable processing activity. For example, we protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. We also require our supplier and vendors to protect such information from unauthorized access, use, and disclosure.
Personal Data of Children: The Sites are intended for business use. We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Sites or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at privacy@florecruit.com.
What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@florecruit.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by contacting us at privacy@florecruit.com to make such corrections.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. In certain circumstances, you can correct some of this information directly by contacting us at privacy@florecruit.com to make such corrections.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data),you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your PersonalData, if such use or disclosure is necessary to enable you to utilize some or all of our Sites.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Flo Recruit’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
CHANGES TO THE PRIVACY POLICY
We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law and the principles of the Privacy Shield. We will notify the changes that we make to this PrivacyPolicy by posting the revised Privacy Policy on the Sites, and such changes will be effective immediately unless otherwise stated. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent.
CALIFORNIA RESIDENTS RIGHTS
California enacted the CCPA in 2018, and it is effective as of January 1, 2020. The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information” (as defined under the CCPA). If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used in this section have the meaning ascribed to them in the CCPA. Flo Recruit is a“business.” For purposes of this section only and with regard to California residents only, Personal Information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. It does not include de-identified information, aggregate consumer information, or publicly available information, as those terms are defined in the CCPA.
Our Collection and Use of Personal Information. In the preceding 12 months, we may have collected from or about you all of the categories of Personal Information and from all of the sources listed in the section entitled “INFORMATION WE COLLECT FROM OR ABOUT YOU.” We may collect, use, or sell Personal Information for the business or commercial purposes listed above in the section entitled “WITH WHOM WE SHARE INFORMATION.”
Our Disclosure and Sharing of Personal Information.We may disclose your Personal Information to our service providers or other entities that have agreed to limitations on the use of your Personal Information or that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA or other applicable laws.
We also sell Personal Information within the meaning of the CCPA, including the Personal Information of minors under 16 years of age.
In the preceding 12 months, we may have sold the following categories of Personal Information to the following categories of third parties.
In the preceding 12 months, we may have disclosed for a business purpose the following categories of Personal Information to the following categories of third parties.
California Residents’ Rights Under the CCPA
If your Personal Information is subject to the CCPA, you may have certain rights with regard to such Personal Information, including the right to:
· Right to Notice. Be informed, at or before the point of collection, of the categories of PersonalInformation to be collected and the purposes for which the categories ofPersonal Information shall be used.
· Right to Request to Delete. Request that we delete any Personal Information about you that we have collected or maintained, subject to certain exceptions. We reserve the right to retain, and not to delete, certain Personal Information after receipt of a Request to Delete from you where permitted by the CCPA or where another law or regulation is applicable. We may retain your Personal Information if doing so is necessary for us or our service providers to, for example:
o Comply with a legal obligation.
o Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us. o Complete a transaction for which we collect the Personal Information, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
o Use your PersonalInformation, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.
· Right to Request to Know. Request that we, as a business that collects Personal Information about you and that sells and discloses for a business purpose Personal Information, disclose to you:
o The categories of Personal Information we have collected about you.
o The categories of sources from which we collected the Personal Information.
o The business or commercial purpose for collecting or selling the Personal Information.
o The categories of third parties with whom we share Personal Information.
o The specific pieces of Personal Information we have collected about you.
o The categories ofPersonal Information about you we have sold or disclosed for a business purpose.
· Right Not to BeDiscriminated Against. Not be discriminated against because you exercised any of your rights under the CCPA.
· Right to Request Opt-Out of Sale. Request that we, as a business that sells Personal Information, not sell your Personal Information. You can exercise your right to opt-out as explained below, including by filling out the interactive form available here.The CCPA does not restrict Flo Recruit’s ability todo certain things like comply with other laws or comply with regulatory investigations. Flo Recruit also reserves the right to retain, and not to delete, certain Personal Information after receipt of a request to delete where permitted by the CCPA.
How to Submit a Request to Know or to Delete Under the CCPA. If your Personal Information is subject to theCCPA, you may submit a Request to Know and/or a Request to Delete, as described above, by sending an email to privacy@florecruit.com.
Flo Recruit is required to provide certain information or to delete Personal information only in response to verifiable requests made by a California Resident or their legally authorized agent. We may need to request specific information from you or your agent to help us confirm your identify or your agent’s authorization to act on your behalf and ensure your right to access the requested information. Any information gathered as part of the verification process will be used for verification purposes only.
In order to verify Requests to Know and Requests to Delete, we require you to confirm your email address. We will send you an email at the address you provided.
If an authorized agent seeks to submit a Request to Know or a Request to Delete on behalf of a California Resident, the authorized agent may do so by the aforementioned methods, however, they must provide: (i) signed authorization from the California Resident authorizing them to act on the California Resident’s behalf, unless they can provide proof that the California Resident has granted them power of attorney pursuant to California Probate Code sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct business in California. We also require that the California Resident directly verify their own identity with us and directly confirm with us that they provided the authorized agent permission to submit the request.
We will deliver responses to verifiable consumer requests free of charge either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.
How to Exercise Your Opt-Out Right Under the CCPA. To the extent that we sell your Personal Information as the term “sell”is defined under the CCPA, you have the right to opt-out of the sale at anytime.
· How to Submit An Opt-Out Request. You may submit a Request to Opt-Out by sending an email to privacy@florecruit.com. Any information we collect as part of the opt-out process will be used for opt-out purposes only.
· Authorized Agents. If an authorized agent seeks to submit a Request to Opt-Out on behalf of a California Resident, the authorized agent may do so by the aforementioned methods, however, they must provide: (i) proof that they have been authorized by the California Resident to act on the California Resident’s behalf; and (ii) proof of their registration with the California Secretary of State to conduct business in California. Keep in mind that we are not required to comply with a Request to Opt-Out if we have a good-faith, reasonable belief that the Request is fraudulent
NEVADA RESIDENTS
Nevada law gives Nevada residents the right to opt-out of the “sale” of certainPersonal Information, provided certain requirements are met. Terms used in this section shall have the meaning ascribed to them in the Nevada Privacy Law. For purposes of this section only and with regard to Nevada residents only:
· PersonalInformation means any one or more of the following items of personally identifiable information about a consumer collected by an operator through an Internet website or online service and maintained by the operator in an accessible form: (i) first and last name; (ii) home or other physical address which includes the name of a street and the name of a city or town; (iii) electronic mail address; (iv) telephone number; (v) social security number; (vi) identifier that allows a specific person to be contacted either physically or online; or (vii) any other information concerning a person collected from the person through the Internet website or online service of Flo Recruit and maintained by Flo Recruit in combination with an identifier in a form that makes the information personally identifiable.
· “Sale” means the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons.
To exercise this right, please send an email to privacy@florecruit.comand including “Nevada Do Not Sell Request” in the subject line.
Last updated on November 15, 2020.