PeopleFluent Privacy Policy

(Effective Date:  November 21, 2016)

The PeopleFluent companies (“PeopleFluent”) provide this privacy policy (“Privacy Policy”) to explain how we collect, use and disclose certain personal information online on www.PeopleFluent.com, our other websites, and our hosted Web-based application services or related support services that link to this policy (“Sites”). It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. By using the Sites, you are accepting the practices described in this Privacy Policy.

Information We Collect

PeopleFluent may collect information on its own behalf on the Sites as described in this Privacy Policy. PeopleFluent provides Web-based application services, software and related support services to help our customers manage information about and provide services to their employees, potential employees, contractors and others. 

The types of personal information we may collect about you through our sites include contact and identifying information (name, address, email address, phone and fax numbers, institution, title or job position), information about your interest in PeopleFluent products or services, information about your interest in newsletters, seminars, or other services that we provide (solely or jointly with others), information about any other transaction(s) between you or your organization and PeopleFluent and any other personal information that you may provide to us in an online form or through an email. Where we collect personal information through online forms, we will notify you of which fields are mandatory for the particular service or functionality you are requesting and which fields are optional. If you choose to provide information that is optional, we may use and disclose such information as described in this Privacy Policy.

A visitor to www.PeopleFluent.com who is not seeking employment and not expressing an interest in purchasing products or services is not required to reveal any individually identifiable information such as name, address or telephone number. 

Through the use of cookies PeopleFluent collects information about the device or browser you are using to access our website.  This includes your device’s IP address, cookie string data, and in the case of mobile devices, your device type and mobile device’s unique identifier.  Please see the “opt out” functions under the Display Advertising and Retargeting Efforts on Third-Party Websites and Applications section.

Our customers may use our hosted application services to process data about their candidates, employees, contractors and agents. Personal data that PeopleFluent may maintain on behalf of our customers includes, but is not limited to, names, contact information, CV or resume, data of birth, national insurance numbers, social security numbers, compensation information, and race and ethnic origin. PeopleFluent does not own or control any of the information it processes on behalf of its customers. Such information is owned and controlled by the customer, and PeopleFluent receives such information merely as a processor on the customer’s behalf. We use such data only as authorized in our subscription agreements with such customers and in accordance with applicable law. Customers are responsible for maintaining the security of their own user logins.

If you are a customer of one of our Customers and would no longer like to be contacted by one of our Customers that use our service, please contact the Customer that you interact with directly. We may transfer personal information to companies that help us provide our service.

Testimonials

PeopleFluent posts customer testimonials on its Web site which may contain personally identifiable information such as the customer’s name. PeopleFluent obtains the customer’s consent prior to posting the testimonial to post their name along with their testimonial. If you wish to remove your personal information that is being displayed on our public Web pages please send your request to Security@PeopleFluent.com.

Blog 

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at Security@PeopleFluent.com.  In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.


Social Media Widgets

Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.

Newsletters

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe by providing a functional unsubscribe mechanism in each email communication we send to users.

Financial Information

We may offer products or services and event or class registration for you to purchase online. To complete these online financial transactions, our sites may request personal information including contact information (https://secure.peopleclick.com and https://eeosource.peopleclick.com) and credit card billing information. Disclosure of this information is completely voluntary and you have a choice whether or not to disclose this information.

Surveys & Contests

From time-to-time our sites may request personal information from you in connection with surveys or contests. Participation in these surveys or contests is completely voluntary and you have a choice whether or not to disclose this information. Personal information requested may include contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used to notify the winners and award prizes, and may also be used to provide you with additional information about our products or services, or those of our selected business partners.

Tracking Technologies

PeopleFluent and our marketing partners, affiliates, or PeopleFluent-authorized service providers use cookies and similar technologies in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We track users’ use of our hosted Web-based application services to compile and analyze statistical and performance information about the application services and their use of the services. We use information about your use of the services for such purposes as making improvements to the services and communicating with you about new features or releases. Users can control the use of cookies at the individual browser level.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, ensure the checkbox for “Yes, I would like to be contacted with employment information” remains unchecked.

Log Files and Aggregate Information

PeopleFluent may record information that is not individually identifiable about how people access our Web sites and store it in log files. This information includes IP addresses (or the DNS name associated with it), the Web site from which you are visiting PeopleFluent and the Web software you are using. This information is used in the aggregate, without disclosure of any individually identifiable information, to administer our system and make improvements to our site and to report to our customers and prospects on our sites’ performance. We reserve the right to share aggregate and anonymous information with potential partners and other third parties without restriction.

Display Advertising and Retargeting Efforts on Third-Party Websites and Applications

PeopleFluent has implemented and uses Display Advertising across third party websites and applications opted into the Google Content Network. Certain PeopleFluent advertisements on third party websites and applications in the Google Content Network may be retargeted using Google Analytics. Retargeting means that third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on a user’s past visits to our website.

We also partner with other third parties to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests.  If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads.  You will continue to receive generic ads.

How Can I Opt Out of Google Analytics for Display Network or Retargeting?

If you would like to be removed or blocked from Google Analytics For Display Network or from retargeting efforts there are several options:

Links

PeopleFluent’s Web site may contain links to other Web sites. PeopleFluent is not responsible for the privacy practices or the content of such Web sites, and this Privacy Policy does not apply to such sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information.

Disclosure

We will share your personal information with third parties only in the ways that are described in this privacy policy.

We may disclose personal information including information collected for our clients, as necessary or appropriate in connection with any of the purposes for which we use personal information, including to subcontractors or service providers that help host or support the sites or otherwise provide technical assistance, fulfillment companies that help us to provide requested products or services and business partners that help conduct seminars or otherwise provide requested products, services or information. We may use third party service providers to provide credit card processing on our site. We will share your credit card information as necessary for the third party to provide such processing services. Transfers to subsequent third parties are covered by the service agreements with our clients. We reserve the right to disclose personal information in connection with the sale or transfer of all or part of the business. In situations where we transfer personal information to these types of third parties, we require that such third parties must not use or disclose the information for any purposes other than those specified in this Privacy Policy, and that such third parties must maintain commercially reasonable security measures to protect the personal information. In situations involving the sale or transfer of all or part of the business, we will seek to notify users of the ownership change by way of a prominent notice posted on our Web site. We also reserve the right to disclose your personally identifiable information as required by law and or in the good faith belief that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, bankruptcy or similar legal process. PeopleFluent does not share, sell, rent, or trade personal information with third parties for their promotional purposes.

Security

To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of personal information, PeopleFluent has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Data maintained by PeopleFluent is protected by computer security mechanisms including firewalls, encryption, monitoring software, data and network segmentation, and passwords. When you enter sensitive information (such as a credit card number and your login information) on our order forms or application sites, we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If, during their employment, PeopleFluent employees acquire confidential or proprietary information belonging to PeopleFluent or its customers, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. PeopleFluent employees are also responsible for the internal security of such information. PeopleFluent provides information and training to all employees who have access to data maintained on behalf of PeopleFluent customers. Employees who violate PeopleFluent security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination. If you have any questions about our security practices, you can email us at Security@PeopleFluent.com.

EU-U.S. Privacy Shield

PeopleFluent, Inc. and its subsidiary company (PeopleFluent LTD) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  PeopleFluent is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]

PeopleFluent is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  PeopleFluent complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, PeopleFluent is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, PeopleFluent may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.  

PeopleFluent has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.    
Under certain conditions, more fully described on the Privacy Shield website [
https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

U.S. - Swiss Safe Harbor Framework

Peoplefluent complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. [Participant] has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view [Participant’s] certification, please visit  https://safeharbor.export.gov/swisslist.aspx.

To Unsubscribe or Modify Information

Upon request Peoplefluent will provide you with information about whether we hold any of your personal information. If you receive marketing or similar e-mail messages from us and you wish to opt out of receiving such messages, you may follow the opt-out procedure specified in the e-mail message or you may contact Security@PeopleFluent.com. PeopleFluent intends to protect the quality and integrity of your personal information. If you wish to review, modify, correct and delete the information submitted to us directly, you should contact Security@PeopleFluent.com.

PeopleFluent acknowledges that you have the right to access your personal information. If you are an applicant, employee or are otherwise affiliated with a PeopleFluent customer and wish to review or modify information provided to PeopleFluent via a PeopleFluent hosted service application, you should first contact the PeopleFluent customer to whom you submitted such information, or who has otherwise provided the information to PeopleFluent for processing. If such company is unable or unwilling to assist you, you should contact PeopleFluent at Security@PeopleFluent.com or to PeopleFluent Security at the contact information set out below.

Within 30 days of your request, PeopleFluent will grant individuals reasonable access to personal information that it holds about them and take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

We will retain your information and the information we process on behalf of our clients for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to this Web Site Privacy Policy

PeopleFluent reserves the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will re-post the revised policy here or at another location that is accessible from our home page so that you are aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use personal information in a manner that is substantially different from that stated at the time we collected it, we will seek to notify users by way of an email, and provide users with a choice as to whether or not we use their information in this different manner prior to the change becoming effective.

Oversight/Enforcement

PeopleFluent’s Information Security Officer is responsible for PeopleFluent’s compliance with and enforcement of this Privacy Policy; the Information Security Officer may be reached at Security@PeopleFluent.com. The United States Federal Trade Commission is the statutory body that has jurisdiction to hear any claims against the organization regarding possible unfair or deceptive practices and violations of laws or regulations governing privacy.

Contact Information

If you have any questions or suggestions regarding our privacy practices or this Privacy Policy, please contact us at:

PeopleFluent

434 Fayetteville Street, 9th Floor

Attention: Security Team

Raleigh, North Carolina 27601

United States

Phone: 1.877.820.4400

Fax: 1.919.645.2801

Email: Security@PeopleFluent.com

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