Last Updated: April 7, 2023
This Policy does not apply to information we process as a data processor or service provider on behalf of our employer clients. JobTarget does not control how our employer clients use information JobTarget processes on their behalf, and you should consult with the applicable employer client to understand how they use information they receive from JobTarget.
By accessing or using the Services or otherwise providing us with information, you acknowledge the applicability of this Policy. If you do not agree to this Policy, please do not access or use the Services or provide us with information.
Job Seekers: Individuals using the Services to look for work opportunities and/or use job search/career management tools.
Employers: Organizations, recruiters, individuals who work for those organizations, or any user using the Services to search for individuals to hire to employ and/or use JobTarget Recruitment Tools and/or JobTarget’s Recruitment Platform.
You, your, or users: Job Seekers, Employers, or any other user who accesses the Services.
We collect information about you as described below when you interact with us through our Services or otherwise. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain aspects of the Services.
a. Information You Provide Us Directly
We collect information that you provide directly to us through:
Information you provide directly to us may concern you and others and may include, but is not limited to:
You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.
b. Information from Affiliated and Non-Affiliated Parties
We may collect information about you or others through our affiliates or through non-affiliated parties. For example, we may receive information about you from job sites operated by unaffiliated parties. We may also collect information about you from other users. For example, users may provide us with information about colleagues or other prospective users of our Services. We may receive information from third-party partners or other third-party data sources. This may include information in the public domain, such as publicly-available information in social media profiles.
We may combine information that we collect from you through the Services with information that we obtain from such other parties and information derived from other products or Services we provide.
c. Information We Collect Automatically
Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods. You may learn more about the specific cookies JobTarget uses here. For more information, see https://www.allaboutcookies.org/.
Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address).
We use your information for business and commercial purposes, such as to:
If you are a Job Seeker, we may also use your information to:
We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated information for any purpose, including without limitation for research and marketing purposes and may also disclose such information to any other parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.
We may disclose the information we collect in the following circumstances:
Affiliates. We may disclose information to our corporate affiliates.
Vendors. We provide access to or disclose your information to select vendors who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.
Legal Requirements. We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
Business Transfers. We may share or disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Consent/At Your Direction. We may disclose your information to nonaffiliated third parties based on your consent to do so. For example, you may direct us to disclose information about you when you refer us or our Services to your colleagues or other acquaintances. If you register for an Account as a Job Seeker or apply for a job through the Services, we may share your information and Content with Employers or other entities managing the hiring of employees. Please review the Your Choices section for instructions on how to revoke such consent. If you are an Employer who uses the Services to post a job posting to a third-party job listing site, we may share your contact information with the operator of that site.
We may use third-party web analytics services on the Services, such as those of Google Analytics. These vendors use the sort of technology described in the “Information We Collect Automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by such technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
b. Tailored Advertising
We may also allow third-party advertising networks to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our Website and other sites and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our Website. We also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share or disclose to a vendor in hashed, non-human-readable form.
If you are interested in more information about tailored advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link, the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link, and/or the European Interactive Digital Advertising Alliance to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content may not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit these opt-out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective.
a. Rights and Choices
You have certain rights and choices with respect to your information such as:
Your local law may provide you certain rights with respect to your information. Depending on your jurisdiction, you may request that we:
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. If your information has been disclosed to an unaffiliated party at your direction, such as a job application submitted to an Employer, such information cannot be deleted or amended.
IMPORTANT: Any information by which you can be personally identified, such as your name, physical address, e-mail address and/or phone number and/or other content that you voluntarily disclose to our Services may become available to the public and may be accessed, used and stored by others. You should not post sensitive personal information or any other information that you would not want made public.
We may request you provide us with information necessary to confirm your identity before responding to your request. To exercise any of these rights, please contact us as described in the “Contact Us” section below.
b. Regional Privacy Disclosures and Rights
Additional disclosures for residents of the European Economic Area, United Kingdom, Nevada, California, and Virginia are set forth below in Additional Regional Disclosures.
JobTarget implements technical, administrative, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, we do not promise and cannot guarantee the security of your information or communications.
We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our services are global and your information may be stored and processed in the United States and other countries outside the United States that may have data protection laws that differ from the laws in your country. For example, our employees and contractors may access your information from the United States or the Philippines. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.
European Union-United States and Swiss-United States Privacy Shield: JobTarget has certified with the E.U.-U.S. and Swiss-U.S. Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of “personal data” (as defined under the Privacy Shield principles) from applicable European countries. We have certified that we adhere to the Privacy Shield Principles of notice, choice, purpose limitation, onward transfer, security, data integrity, access, recourse, liability, and enforcement for such personal data. To learn more about the Privacy Shield Framework, visit the Department of Commerce’s Privacy Shield list by clicking here. We recognize that the Court of Justice of the European Union ruled in July 2020 that a certification under the EU-U.S. Privacy Shield Framework no longer can serve as the basis by which entities subject to the GDPR export personal data to jurisdictions outside the European Economic Area, and that the Swiss Data Protection Authority similarly held the Swiss-US Privacy Shield inadequate. We will continue to honor our obligation to comply with the Privacy Shield Principles with respect to data that was transferred pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Framework.
As required under the principles, when JobTarget receives personal data under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield; and (ii) JobTarget is responsible for the event giving rise to the damage.
Some international users (including those whose information we collect under the Privacy Shield) of our Services have certain legal rights. Please see the Your Choices section above for more information.
Dispute Resolution for European Economic Area, United Kingdom, and Swiss Residents: If you are a resident of the European Economic Area Union, United Kingdom, or Switzerland and are dissatisfied with the manner in which we have addressed your concerns for personal data covered by the Privacy Shield, you may seek further assistance, at no cost to you, from our designated Privacy Shield independent recourse mechanism, Privacy Trust, which you can learn more about by visiting here. Residents of the European Economic Area, United Kingdom, or Switzerland may elect to arbitrate unresolved complaints but prior to initiating such arbitration, you must: (1) afford us the opportunity to resolve the issue; (2) seek assistance via JobTarget’s recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual. JobTarget is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.
a. Residents of the European Economic Area and United Kingdom
JobTarget is considered the “data controller” of the “personal data” (as defined under the General Data Protection Regulation (“GDPR”)) we handle under this Policy. In other words, JobTarget is responsible for deciding how to collect, use and disclose this data as specified in this Policy, subject to applicable law. The laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your personal data. To the extent those laws apply, our legal grounds are as follows:
Where JobTarget acts as a “processor” of the “personal data” (as defined under the GDPR), JobTarget retains such personal data until the controller instructs JobTarget to delete it. In addition to the rights described herein, you have the right to submit a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
b. Residents of Nevada
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to unaffiliated parties. You can exercise this right by contacting us as described in the “Contact Us” section below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address. We do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
c. Residents of California
The following information applies to California residents regarding “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). This information and the rights discussed below do not apply to information collected about employees, former employees, candidates, or independent contractors. In this section, where we use a term in “quotes,” we refer to the meaning of that term in the CCPA.
i. Categories of personal information we collect, use and disclose
Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from you and other users (as described above) and discuss how we use and disclose such information.
We may collect the following categories of personal information about you:
We also collect “sensitive personal information,” as that term is defined in the CCPA. The categories of “sensitive personal information” we collect are:
We process the categories of personal information identified above for the purposes described in the How We Use the Information We Collect section above.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services or other interactions with us; and (3) other parties such as other users (including Employers and Job Seekers), operators of other sites and services, and data brokers.
We describe our information disclosure practices above in When We Disclose the Information We Collect.
ii. “Sale” and “sharing” of personal information
The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information.
We may disclose your personal information to third parties for purposes of analytics and advertising. We provide information to analytics providers to better understand how consumers use the Services so we can improve the Services and create new products and services. We may also provide personal information to third-party advertising providers for targeted advertising purposes, so we can provide you with more relevant and tailored ads regarding our services. Under the CCPA, disclosing personal information to these third parties may be considered a “sale” of personal information or the “sharing” of personal information for purposes of “cross-context behavioral advertising.”
In providing the Services, we may disclose certain personal information, such as to connect Job Seekers and Employers. Under the CCPA, in some contexts, this may be considered a “sale” of personal information.
The following chart lists the categories of personal information we have sold or shared over the last 12 months, and the categories of third parties to whom we have sold or shared such personal information.
|Category of Personal Information||Categories of Third Parties to Which We Have “Sold” this Personal Information||Categories of Third Parties to Which We Have “Shared” this Personal Information|
|Identifiers||Ad networks and advertising providers
|Ad networks and advertising providers|
|Commercial Information||Ad networks and advertising providers
|Ad networks and advertising providers|
|Internet network and device activity data||Ad networks and advertising providers
|Ad networks and advertising providers|
|Protected classification information||Employers||We do not “share”|
|Education and employment information||Employers||We do not “share”|
We do not knowingly “sell” or “share” the personal information of children under 16.
You can opt out of our “sales” or “sharing” of your personal information by following the instructions below.
iii. Your CCPA Rights
If you are a California resident, the CCPA may permit you to request that we:
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.
Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services. To exercise these rights, you will be required to verify your identity, and we may request additional information from you to verify your identity. To exercise your rights, please submit your request here or you may also call us at 1-888-868-8652.
You also have the right to opt out of “sales” and “sharing” of personal information. Please submit your request here: Do Not Sell or Share My Personal Information.
Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your “sensitive personal information” is used for certain purposes. Please note that we do not use or disclose “sensitive personal information” other than for purposes for which you cannot opt out under the CCPA.
You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
iv. Retention of Your Personal Information
Please see the section above on Data Retention.
We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control browser choice referenced above.
vi. Shine the Light
Under California’s “Shine the Light” law, California residents may request certain information regarding our disclosure of your information to third parties for their direct marketing purposes. JobTarget does not disclose your information to third parties for their direct marketing purposes.
d. Residents of Virginia
If you are a Virginia consumer (as that term is defined under the Virginia Consumer Data Protection Act (“VCDPA”)), you may have certain rights. Virginia law may permit you to request that we:
Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.:
To exercise these rights, you will be required to verify your identity, and we may request additional information from you to verify your identity. To exercise your rights, please submit your request here or you may also call us at 1-888-868-8652.
To opt out of our use of your personal information to send you targeted advertising (as that term is defined in the VCDPA), please submit your request here: Do Not Sell or Share My Personal Information.
If we deny your request to exercise any of the rights above, you may appeal that denial by emailing us at email@example.com.
We may change this Policy to reflect changes in the law, our information practices or the features of the Services. We will indicate the date of the most recent update in this Policy. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.
You may contact us by email at firstname.lastname@example.org. You can also contact us by mail at JobTarget, LLC, ATTN: Legal Affairs, 600 Summer Street, 5th Floor, Stamford, CT 06901