TalentNet Privacy Policy

Welcome to TalentNet! 

This Privacy Policy and our Terms of Service help guide decisions TalentNet makes every day.  In order to create a more agile, open and awesome working world, helping protect and empower the flow of global talent is a top priority for us. 

For the purposes of this Privacy Policy, when we say ‘Users‘, ‘you‘ or ‘your‘ we mean any individuals about whom we process Personal Information, including anyone creating a profile on the TalentNet Platform or users of the TalentNet website (the “Website”) (collectively using the “Services”).

Important information about TalentNet

Words like ‘us‘, ‘we‘, ‘our‘, or ‘TalentNet‘ refer to TalentNet Inc. TalentNet provides a cloud-based Direct Source Talent platform (the “Platform”). The Platform enables Clients to leverage their brand, networks and digital assets to build and curate talent into a private ‘TalentNet Community’. When a Client collects your Personal Information (as defined below) and uses the TalentNet Platform to manage it, the Client will be responsible for the original collection of your Personal Information and will be your primary Data Controller. 

We also provide our services in jurisdictions where country-specific requirements may apply as set out in this Privacy Policy. As you use the Platform, we want you to be clear about how we collect and use your information, ways you can protect your information and how we help you in protecting your information. 

Your privacy matters to us.  We have developed our platform with two key principles – Security by Default and Privacy by Design – so whether you are new to the Platform or a long-term User, please take the time to get to know our practices by reading through this Privacy Policy. If you have any questions, please contact us. If you require a copy of this Privacy Policy in a particular form, let us know and we will provide it to you.

To find out more about TalentNet, visit www.TalentNet.com or by contact us here.

What is Personal Information

What information does TalentNet collect and when?

Information gathered when you complete our contact us form on the website (www.TalentNet.com): we collect that contact information to provide information, and sales opportunities for Clients to use our services to develop, and or grow their direct source strategy. Information gathered during profile registration: When you sign up for our Services, or register to use our Platform as a User, we collect and process certain Personal Information and data about you including:

1. TalentNet Community user information relating to your profile, photograph, curriculum vitae or resume (including industry, profession, specialities, work history, achievements, awards, languages, references, availability, job search status, right to work, education and qualifications), contact details (including your full name, address, phone number and email address), profile data (including password, username, log-ins and user preferences), diversity information (including gender, veteran status, disability, orientation and date of birth), work preferences (including salary, contract type, tax status, hours and location), technical data (including IP address, browser type, other technology on the device used and usage data (including the frequency and details of your use of our Platform and Website)), each as further detailed in this Privacy Policy. We collect marketing and communications data, including your preferences for receiving marketing and related communications. We also collect the data that our Clients attach to your profile, including their communications with you, details of your job applications, their assessment of you and interview and other notes.

2. TalentNet TalentBench user information relating to curation teams submitting a person for a job vacancy to a Client: we will collect data in order to provide our Services to you and your users, including your business or company name, contact details (including address, phone number and email address). 

Which ways can your data be gathered on the TalentNet Platform?

Profiles can be created via several ways including: 

• a job application with a potential employer (e.g. on a job board) or 
• registration directly joining a Talent Community powered by TalentNet (such as via the employer’s career page, through job boards and social logins or Open API integrations with other employment platforms. 

TalentNet will always seek your consent to process your data prior to progressing the application through our Platform. We may contact you via email or SMS where you create a TalentNet profile but have not consented.

Is there anything else?

Other information we collect to help us update, improve, or tailor the Platform for you and / or deliver a better experience. You do not have to provide any additional Personal Information and can opt out of any such request for information at any time from us by clicking ‘unsubscribe’ or using any of the opt-out measures included in communications from us or by emailing us at privacy@TalentNet.com. 

What about sensitive data?

TalentNet has a Diversity, Equity and Inclusion survey that is closely aligned with the Office of Federal Contract Compliance Programs (OFCCP) reporting requirements however this is strictly voluntary and separate from the main platform. We will not collect this data unless you choose to provide it. You do not have to provide this information to receive our Services. 

What about Usage Data?

We may collect information about which Services you use and how you use them and/or the Platform. This usage data and information includes:

1. Device information: We also automatically collect your browser type and browser software version to optimize the presentation of the Platform and to maintain a record of your activity on the Platform. Please see our Cookie Policy for further information on how we collect and process browser type information and your rights to opt-out.

2. Location information: We collect this data to pre-fill forms for you, and to allow relevant suggestions of job opportunities, using google maps but minimized to city, state/ province and Country,

3. Local storage: We may collect and store information, including some Personal Information (First and Last name, work email), user and session ID’s locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches,

4. Cookies and anonymous identifiers: We use various technologies to collect and store information when you visit our Platform, including cookies. For more information about our use of cookies, please read our Cookie Policy. Third parties (including advertising networks and providers of external services) may also use cookies, over which we have no control. You should review the privacy policies of such third parties to understand how they use and protect your Personal Information. You always have the option of disabling cookies via your browser preferences. If you disable cookies on your browser, please note that some parts of our Platform may not function as effectively or may be slower.

What do we use your Personal Information for?

We use the Personal Information we collect from you for a range of purposes:

When you use the Website, the categories of data we obtain include data you provide us using the “contact” option or during the “Demo”  to deliver our Services. This data includes contact information, which we may contact you for marketing purposes such as seminars, conferences and sales leads. 

When you use our platform either as a TalentCommunity User or TalentBench User, we use your Personal Information to maintain, protect and improve the Services and our products offered to you, to operate our business and develop new services, and to help us protect you and the Platform; offer you specific and relevant information such as search results and work opportunities in connection with the provision of our Services to assist in pursuing potential employment opportunities with, or through, our Clients.

As required by law and when complying with our legal obligations and assisting governments, law enforcement agencies or regulators (after consultation with data controllers and our legal counsel) 

To support our internal business purposes (including administration, planning and product development).

We also require certain Personal Information to inform you about updates to the Platform and Services and provide information relating to information validation, verification and updates.

Above all we will only process your data in accordance with this Privacy Policy.

Types of Data	Examples	TalentNet uses it to	Origin of usage
Information that identifies you	For clients: Account owner name and contact information, your name, username and email address, or phone number, when you use this information to access or use our services.	Contact clients and schedule demonstrations of our services. Provide Services and communicate with a client/respond to requests for client support.	Website – www.talentnet.com
Contact information provided by you via the website	Your name, physical address, email address, phone number.	Respond to requests from you/send you communications/marketing materials unless you tell us not to.	Website – www.talentnet.com
Information that you provided us via registration for TalentNet Communities	Your contact info, your resume data, and other work preferences or experience.	To provide the service of matching you to job opportunities that best align to your profile. This includes sending alerts about possible job opportunities.	TalentNet Platform. (TalentCommunity, TalentBench)
Data collected through the use of cookies and pixels	Data collected from tools such as Google Analytics and Google Ads (All cookies are visible in the Cookie Preferences tool. You have control over what non-essential cookies you accept. For more information, see our Cookie Policy and the Cookie section below.)	Analyze how our Website is used so we can improve your experience. Allow you to do things like completing orders, sharing pages, and remembering settings. Evaluate the success of our marketing campaigns. Send you tailored TalentNet advertising when you are on other sites.(For more information on how TalentNet uses cookies, see our Cookie Policy.)	Website, TalentNet Platform (TalentCommunity, TalentBench)

Legal basis for using your Personal Information

EU / UK Individuals: We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do so. We will make sure that we only use your Personal Information for the purposes set out above. Contact us at Privacy@talentnet.com for more detailed information.

Direct marketing

We may use your Personal Information to send you direct marketing communications about the Services and the goods and services of our Clients and partners. Marketing materials may be sent in the form of emails, post, SMS, telephone or targeted online advertisements and may include information that we think may be of interest to you and information on upcoming changes or improvements. Where we send you marketing materials on behalf of our partners, we may receive a fee for this service. In most cases, our processing of your Personal Information for marketing purposes is based on our legitimate interests, although in some cases (such as where required by applicable laws or where we use or process any of your Personal Data) it may be based on your explicit consent. You may opt out of receiving marketing communications in any form at any time by following the opt-out instructions provided in the communication or otherwise contact us. You can also change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser. See further our ‘Cookies’ section above and our Cookie Policy.

Do you use Automated Decision-Making? 

TalentNet does not conduct any automated decision-making beyond automated processing to match and stack rank candidates to job profiles. A member of the curation team will always make a decision to contact or offer a job based on manual interactions directly with candidates. Our processes strip our Personal Information prior to processing in order to remain as unbiased as possible to determine the mix of candidates and their alignment to the job profile within a Client’s tenant.

What about security or privacy?

We may contact you to validate the information and you provided and to help assess if your account may be fraudulent, a spam account or suspect in any way. TalentNet acknowledges our duty to safeguard your Personal Information and uphold high standards of security. The TalentNet platform, designed and developed from the ground with our core principles of Security by Default and Privacy by Design, which are operated by us or external cloud service providers, are secure. The data is stored in secure servers located in locked data centers and is encrypted where feasible. However, due to the inherently insecure nature of internet communication, we cannot guarantee the complete security of your information transmitted to our Website.

We take reasonable measures to destroy or de-identify Personal Information when it is no longer necessary for the intended purpose or any legally permissible secondary use. We recommend that you create a strong password, keep it confidential, and change it periodically to protect your account from unauthorized access. As the security of information is dependent on the security of the device you use to communicate with us, we urge you to take appropriate measures to safeguard this information.

Our Platform uses industry-standard cryptographic protocols, such as SSL (Secure Sockets Layer) and TLS (Transport Layer Security), to protect your Personal Information. These protocols employ robust encryption algorithms such as AES and SHA, while also disabling insecure ciphers, thus ensuring that the information is reasonably secure against unauthorized interception both in transit and at rest.

We have established an Information Security Management System (ISMS) that comprises people, processes, and technological controls to protect Personal Information from misuse, interference, or loss, and from unauthorized access, modification, or disclosure. We require all employees and contractors to comply with our internal information security policies and standards, and we ensure that our practices are in compliance with all applicable legal, regulatory, and contractual requirements. Our employees are required to undergo mandatory information security training and awareness sessions, and we regularly review and monitor our security practices against industry best practices to ensure that they are up to date.

Can I Update my Personal Information?

You have access to your profile and can update your Personal Information at any time.

Can I delete my Personal Information?

A request to delete your Personal Information may be made at any time. We may ask you to verify your identity before we act on your request. There are some circumstances in which we are not required to give you access to your Personal Information. We may reject requests that are unlawful, require disproportionate technical effort (e.g. developing a new system or fundamentally changing existing practices). that we believe risk the privacy, health or safety of others, or would otherwise be extremely impractical (e.g. requests concerning information on our backup systems or unique ID data on Users). Where we provide information access and correction, we will do so for free, except where in our opinion it would require a disproportionate effort or cost for us to do so. Where you correct, update or otherwise provide Personal Information, you represent to us that the information you provide to us is, having regard to the circumstances, accurate, up to date and complete, having regard to the purposes of the disclosure, and not misleading or deceptive. We will respond to any requests to delete your Personal Information within a reasonable timeframe and will take all reasonable steps to ensure that the Personal Information we hold about you remains accurate, up-to-date and complete.

Depending on our relationship with you, or your relationship with our Client, we may need to refer your request to our Client; who will consider your request and respond to you directly.

What about my Data Subject Rights?

The Personal Data we are provided with is for contact purposes. Under the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), there are certain requests you can make related to Personal Data which we will respond to as much as we can under applicable laws. (See below for other legal rights you may have with respect to your Personal Data).

• Access: You can request more information about the Personal Data we hold about you. You can request a copy of the Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, Talent Community users can log into their profile and update it at any time, alternatively you can contact us if you notice any inaccuracy or incompleteness.
• Objection: You can let us know that you object to the collection or use of your personal data for certain purposes.
• Opt Out of “Sales”: This is your right and we will comply with any request of this nature, however TalentNet does not sell our data to 3^rd parties for marketing purposes. 
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Right to File Complaint: You have the right to lodge a complaint about TalentNet’s practices with respect to your personal data with the supervisory authority of your country or EU Member State.

Sometimes we will not be able to fulfill your request: if it prevents us from complying with our regulatory obligations or impacts other legal matters, if we cannot verify your identity, or if it requires extraordinary cost or effort, we will tell you in a reasonable time and give you an explanation.

What if I want to make a complaint?

We regularly review our compliance with this Privacy Policy as well as under applicable privacy laws. If you have a complaint regarding this policy or any breach of applicable privacy laws, please contact us immediately to register your complaint and let us know what we can do to resolve it. If we do receive your formal written complaint, we will respond to your complaint within a reasonable time and do everything reasonably practicable to resolve the complaint. If you’ve already contacted us and feel that your complaint cannot be resolved between us, you can contact the relevant local data protection supervisory authority.  We will work with the appropriate regulatory and supervisory authorities to resolve any complaints regarding the transfer of Personal Information that we cannot resolve with you directly. Please note, you may choose to contact us in relation to a particular matter on an anonymous basis or using a pseudonym and, unless it is impracticable for us to do so or we will not be able to respond reasonably to your complaint, we will attempt to resolve your enquiry on such basis.

To make a request, please contact privacy@talentnet.com.

Additional Information About Specific Regulations

Residents of the State of California

If you reside in California, you may have legal rights with respect to your personal data, including those set forth under the CCPA. If you are a California resident, you can request information about both the categories and specific pieces of data we have collected about you in the previous twelve months, the reason we collected it, the category of entities with whom we have shared it and the reason for any disclosure. TalentNet is prohibited from discriminating against California consumers that choose to exercise their privacy-related rights under the CCPA.

Contact Us

If you have any privacy-related questions or comments related to this privacy policy, please send an email to privacy@talentnet.com.

Bribery and other Corrupt Behavior 

TalentNet is committed to conducting business in accordance with the highest ethical standards and prohibits all forms of bribery and corruption. Both employees and contractors of TalentNet must abide by all applicable Anti-Bribery laws, including the Corruption of Foreign Public Officials Act, the Foreign Corrupt Practices Act, and the local laws in every country in which we do business (for example, federal, regional, provincial, and state laws). Virtually every country in which we operate prohibits bribery. These laws generally prohibit both bribery of government officials and private sector (commercial) bribery. TalentNet and its employees are prohibited from giving, promising, offering, or authorizing payment of anything of value to any government official (whether Canadian, U.S. or international officials) to obtain or retain business, to secure some other improper advantage, or to improperly influence a government official’s actions.  Additionally, TalentNet employees must also avoid the appearance of improper interactions with government officials. 

Anti-Slavery and Human Trafficking Policy

TalentNet respects human rights and has a zero tolerance for slavery and human trafficking in all of its forms. 

TalentNet is opposed to all forms of human trafficking, slavery, servitude, forced or compulsory labour, and all other trafficking-related activities. We are committed to fully complying with all applicable international human rights standards, labour and employment laws, rules, and regulations, and to working to mitigate the risks of modern slavery and human trafficking in our business operations and supply chains. No one shall be held in slavery, and slavery and the slave trade in all their forms shall be prohibited. No one shall be held in servitude. No one shall be required to perform forced or compulsory labor.

TalentNet is committed to acting ethically and with integrity in the operation of its business, and TalentNet requires the same commitment from its employees, contractors, suppliers, associates and business partners (the “Parties”). TalentNet engages in an ongoing assessment of the parties it does business with to ensure that they act in accordance with applicable national and local laws at all times and refrain from engaging in human trafficking, slavery, and similar practices. 

TalentNet encourages openness and will support anyone who raises genuine concerns of slavery and human trafficking.