Privacy Policy CAREERMINDS

Thank you for using Careerminds. We are committed to protecting your data and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the Careerminds services, including the outplacement services, coaching, career development or any other service provided by Careerminds Group Inc. (collectively, the “Services”). The Services are owned and operated by Careerminds Group Inc., a Delaware corporation, having its seat and registered address at 18 Germany Dr, Suite 2A, Wilmington, DE 19804, USA (“Careerminds”, “we”, “us” or “our”).

This Privacy Policy applies if you reside in a country in the European Economic Area (“EEA”: the countries of the European Union as well as Norway, Liechtenstein and Iceland), in Switzerland or in the United Kingdom. If you reside in the USA or Canada, please click here to learn more about your privacy rights.

This Privacy Policy applies to data we collect through the Services, as well as other data provided to us online or offline by third parties, when we associate that data with users of our Services. The Privacy Policy also applies to data collected from users of our website and web-based applications, and to data collected from recipients of marketing communications and job applicants, as we then determine the purpose and means of processing these individual’s personal data. This makes us the data controller within the meaning of the European General Data Protection Regulation (“EU GDPR”), or the equivalent laws of the United Kingdom and Switzerland (collectively, “Data Protection Laws”).

The Privacy Policy does not apply to data collected from our employees. It also does not apply to data that you ask us to share with third parties or is collected by Online Tool Providers (as further described below). You acknowledge and agree that Careerminds is not responsible for the data collection or use practices of any other Services user or third party utilized in providing the Services. You should always read the Privacy Policy of those third parties before using their services.

This Privacy Policy describes, among other things:

• Personal and other data we collect about you;
• How we use your data;
• How we may share your data with third parties; and
• Your choices regarding the personal data we collect about you.

To ask questions about our Privacy Policy, contact us at: marketing@careerminds.com.

1. COLLECTION OF YOUR PERSONAL DATA
Registering and using our Services
When you register for or use our Services, we collect your personal data. We may use your personal data as necessary to perform our contracts with you. We describe the contractual services for which this data processing is necessary in our Terms of Service. Without your personal data, it is not possible for us to perform the outplacement, the executive coaching and career development services. We need your personal data to, for example, facilitate account creation and logon process, to send administrative information to you, to send your marketing and promotional communications and to request feedback. For these purposes, we may process the following personal data:

• Names;
• Personal addresses;
• (Private or business) email addresses;
• (Private or business) phone numbers;
• Job title and company name;
• Personal payment card information;
• Account numbers and government-issued identification numbers;
• Resumes;
• Degrees, certifications and test results;
• Employee files; and
• Any other personal data provided in the context of our Services.

Our Services do not intend to collect special categories of personal data, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. However, we cannot fully guarantee that we will not collect such data if you provide it to us (for example, in your resume). We will not use it for purposes other than performing our Services and only with your explicit consent.

We will keep your personal data as long as it is necessary to perform our Services, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When there is/are an indication(s) of potential legal claim(s) or liability, the retention period will be extended accordingly.

Using our website or web-based applications

When you use our website, web-based applications and any other tool or product provided by us, we may process your personal data regarding that use. For example, to improve, develop and protect our Services and website(s), we collect how, when, and which parts of the Services or its features you use, which social media platforms you connect to the Services, and when, how, and what you post to the social media platforms through the Service app. Also, we may use your device’s unique identifier (UDID) or other unique identifiers to assist us in collecting and analysing this data. Moreover, we may process your personal data to handle your ‘requestion information’ on our website or to chat with you on our website.

We may also employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags”. A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. We refer to our cookie policy for more information on these cookies.

We process personal data of website users now that we have a legitimate interest in doing so. This interest is, for example, to respond to your information requests and to ensure a properly functioning website. For these purposes, we may process the following personal data:

• Names;
• (Private or business) email addresses;
• (Private or business) phone numbers;
• Job title and company name;
• Number of company employees;
• The Services someone is looking for;
• Data through Cookies; and
• Any other personal data provided in the context of our website.

We also automatically collect certain information when you visit, use or navigate through our Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily used to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes.

If you send us a message or contact us in any other way, we will retain your contact details for as long as necessary to comply with your request. After that, we will delete or anonymise your personal data. If we process your personal data on the basis of your consent, you may easily withdraw this consent at any time. You can submit your request using the e-mail address: marketing@careerminds.com.

Receiving our newsletter and other forms of marketing

We will not use electronic contact details for marketing purposes, unless you are using our Services, in which case we will provide information about new products and Services. Users of our Services can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send (this is also called ‘OPT OUT’). Even if you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.

For the processing of your personal data for marketing purposes, we may process your personal data on the basis of our legitimate interest, except when your interests or your fundamental rights and freedoms outweigh our interests.

If you are not using our Services, we will ask for your consent to send our newsletter of any other direct marketing messages (this is also called ‘OPT IN’). From these recipients, we may process the following personal data:

• Names;
• (Private or business) email addresses;
• Subscription to newsletter; and
• Interests and preferences.

We retain your data for marketing purposes for up to five years from the time the data were created or from the time of your consent. After that, we will delete or anonymise your personal data, unless we need certain personal data for a longer period for another purpose. If we process your personal data on the basis of your consent, you may easily withdraw this consent at any time. You can submit your request using the e-mail address: marketing@careerminds.com.

Applying for a job with us

If you apply for a job with us, we need personal data to assess your application and to contact you about the process. We may process your personal data on the basis of our legitimate interest and if we get further into the application process, your personal data will be necessary for us to draw up and perform the employment contract – during the pre-contractual phase. For these purposes, we may process the following personal data:

• Names;
• Email addresses;
• Phone numbers;
• Personal addresses;
• Motivation letter and resumes;
• Degrees, certifications and test results; and
• Any other personal data provided in the context of your job application.

If you have applied for a job with us, your personal data will be deleted when you ask us to do so, or four weeks following completion of the application process, unless you have consented to us retaining your personal data for a period of one year after completion of the application process. You can easily withdraw your consent at any time by contacting us.

2. MINORS

The Services are not intended for users under 18 years of age. We do not knowingly collect personal data from users under 18 years of age. We do not authorize users under 18 years of age to use the Services. If you believe that we inadvertently have collected personal data about your child, please contact us at marketing@careerminds.com and we will promptly delete or anonymise this information.

3. DATA COLLECTED FROM OTHER SOURCES

We and our affiliates generally share personal data with each other so that we can provide our services to you. We also may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties.

Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links). When you choose to, for example, obtain feedback on a resume through one of our third-party marketing partner sites, your contact information and resume will be sent to us.

4. DISCLOSURE OF YOUR PERSONAL DATA

We do not sell your personal data but we may disclose your personal data to third parties as described below.

Within our company

We may disclose personal data to provide the Services, or when you authorize or instruct us to do so, for example when you use the Services to submit content or share it with other users. This may include the disclosure of your personal data to our employees, affiliated companies, group companies and subsidiaries, if and to the extent that this is necessary for the purposes described in this Privacy Policy.

Service Providers

We may also disclose personal data to Service Providers. By “Service Providers” we mean companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, chat service providers, content optimization service providers and lead generation providers, marketing of our products and services, and conducting audits). When we use a Service Provider, we require that the Service Provider use and disclose the personal data received from us only to provide their services to us or as required by applicable law. Insofar as Service Providers process your personal data on our behalf and on the basis of our instructions, they do so as processors. In these cases, we will enter into a data processing agreement.

Online Tool Providers

We may also disclose personal data to Online Tool Providers. By “Online Tool Provider” we mean a licensor of software that we include in, or use with, the Services, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of personal data and/or non-personal data to the Online Tool Provider. Online Tool Providers may have the right to use personal data about you for their own business purposes. An Online Tool Provider may collect information automatically, in which case personal data it receives are subject to the Online Tool Provider’s Privacy Policy and not ours. Use and disclosure of personal data by an Online Tool Provider is described in its Privacy Policy. Some Online Tool Providers may allow you to opt out of certain collection and/or uses of your information.

Other third parties

We may also disclose your personal data to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.

Finally, we reserve the right to transfer information (including your personal data) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.

Lastly, we may also disclose non-personal data, aggregated with information about our users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

Third countries

If your personal data are transferred to ‘third countries’ – i.e., countries outside the EEA – we will only do so if the third country offers an adequate level of protection. In some countries outside the EEA, which as at the date of the last update of this policy include Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland , the United Kingdom under the GDPR and Directive (EU) 2016/680, the United States (commercial organisations participating in the EU-US Data Privacy Framework) and Uruguay (for more information and up to date list of the countries please, check here) – your personal data are sufficiently protected in accordance with European data protection laws and regulations. If this is not the case, we provide appropriate safeguards to ensure adequate data protection. For example, by using the most recent standard contractual clauses as approved by the European Commission and by implementing additional safeguards, of which a copy can be obtained by sending an e-mail to marketing@careerminds.com. If no appropriate safeguards are in place, we will only transfer your personal data if a legal exception applies. An example of a legal exception is explicit consent.

5. THIRD PARTY WEBSITES

Please note that the Services may link or integrate with third party sites, services or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share and protect your information.

6. INFORMATION SECURITY

We utilize reasonable information security measures to safeguard your personal data against unauthorized access, modification, or destruction. For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. We restrict access to personal data in our possession to our employees, Service Providers, and Online Tool Providers who need to know that information in order to operate, develop, improve or support our Services.

Although we will do our best to protect your personal data taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing. You should only access our Services within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at marketing@careerminds.com.

7. PRIVACY RIGHTS
You have the following rights under the applicable Data Protection Laws:

• Right to request access to your personal data. You are entitled to ask information about whether we process your personal data and receive copies of the set of personal data. However, there are certain exemptions, meaning that data subjects may not always receive all of the information we process.
• Right to erasure. You generally have a right to request your personal data or part of it to be erased (e.g., when the personal data are no longer necessary for the stated purposes, the personal data have been unlawfully processed, etc.); however, we may not always erase your personal data because sometimes the processing is still necessary: for example, for complying with statutory obligations or for lodging, exercising or substantiating legal claims. Therefore, we will weigh your interest in having your personal data erased against the necessity of maintaining the personal data for other legitimate interests. Please be aware that if you request us to delete your personal data, you may not be able to continue to use the Services.
• Right to request rectification. Without prejudice to your right to review or change the information in your account to make sure it is accurate and up-to-date, you also have the right to request rectification of any other of your personal data, provided to us if you consider it to be inaccurate or incomplete.
• Right to restriction of processing. Under certain circumstances, you may have us restrict the processing of your personal data. For example, if the accuracy of your personal data is contested, the processing is unlawful or personal data is no longer needed for purposes of the processing. However, we can still use restricted data in certain circumstances (e.g., personal data needed for legal claims or to protect another data subject’s rights).
• Notification of rectification, deletion or restriction. Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about rectification, deletion or restriction of processing.
• Right to data portability.Under certain circumstances, you may request us to transfer your personal data, provided by you, to another controller. Also, you have the right to receive your personal data, which have been provided by you, in a structured, commonly used and machine-readable format and to transmit those data to another controller.
• Right of objection. Furthermore, under certain circumstances you may object to the processing of your personal data by us or third parties engaged by us. We will consider several factors when assessing an objection to our processing in furtherance of our legitimate interests, including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. Your objection will be upheld, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.
• Right to withdraw Consent. If we have requested your consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the processing based on consent prior to the withdrawal.
• No automated decision-making or profiling, without human intervention. Sometimes, we use automated decision-making or profiling when processing your personal data. We only engage in automated decision-making or profiling when consistent with the applicable Data Protection Laws.
• Right of Complaint. If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at marketing@careerminds.com. We will always try to find a solution together. Should this not be possible, you have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the EEA, please contact your local data protection authority in the EEA. For contact details of your local Data Protection Authority, please see here.

You can submit your request(s) for exercising these rights to us at marketing@careerminds.com, please provide your name, telephone number, and type of request. To protect your privacy and security, we will take reasonable steps to verify your identity before responding to your request(s). Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal data. For example, if you make a request, we will ask you to confirm your name, email address, and/or other information we in our records to verify your identity. This is a security measure to ensure that personal data are not disclosed to someone who has no right to receive it.

We will respond to your request as soon as possible, and no later than one month from receipt of your request. In doing so, we will also assess whether, and if so to what extent, we can or must comply with your request under the law. If a longer period of up to two months is needed, we will inform you within one month of receipt of the request. The submission and processing of your request is free of charge, unless your request is manifestly unfounded or excessive, in particular because of a repetitive character.

8. CHANGES TO THIS POLICY

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our website prior to the changes becoming effective. We encourage you to check this Privacy Policy from time to time.

9. QUESTIONS AND COMPLAINTS

To ask questions about our Privacy Policy or to lodge a complaint, contact us at:

Careerminds Group Inc.
2800 Lancaster Avenue
Suite 9
Wilmington, DE 19805
Email: marketing@careerminds.com