Do Not Sell or Share Personal Information and Limit Use And Disclosure Of Sensitive Personal Information

1. A link to TRG’s “Do Not Sell Or Share My Personal Information and Limit the Use and Disclosure of Sensitive Personal Information” notice.

a) Please visit tenthrevolution.com/legal/do-not-sell-or-share-personal-info-or-sensitive-personal-info/.

2. A description of a consumer’s rights pursuant to the US Data Privacy Laws, including CCPA Section 1798.120:

a) Your Right to Opt-Out. If you’re a consumer residing in an applicable US State, including California, and we sell or share your information or disclosure your sensitive personal information to third parties, you can tell us at any time not to sell or share your personal information or limit our use and disclosure of your sensitive personal information. This right to opt-out applies if we do not know your age or if we know you are older than age 16.

b) Your Right to Opt-In. If we have actual knowledge that you are between ages 13 and 16 (e.g., based on information we collect, or because someone informed us), we will never sell or share your personal information or disclosure your sensitive personal information without your affirmative authorization. If we have actual knowledge that you are younger than 13, we will never sell or share your personal information or disclose your sensitive personal information without your parent or guardian’s affirmative authorization. This is your right to opt in.

c) Do We Sell or Share Your Personal Information or Use or Disclose Your Sensitive Personal Information? At this time, we may sell and share your personal information and we may use or disclose your sensitive personal information and you can opt out at any time. If you opt out, or for children 16 and younger, if you have not opted in, we will not sell or share your personal information or use or disclose your sensitive personal information to third parties unless you expressly authorize us to do so.

3. A description of a consumer’s rights pursuant to the US Data Privacy Laws, including CCPA Section 1798.110: Consumers have the right to request that we disclose to you:

a) The categories of personal information or sensitive personal information it has collected about you.

b) Personal information is information that identifies or relates to a particular consumer or household including name, postal address, email address, IP address, social security number, personal property records, purchasing histories, biometric information, internet activity such as browsing or search history, geolocation data, employment information, education information and inferences drawn from this information, in so far as it is not publicly available information. In addition to the above types of personal information that we may collect, TRG may collect the following kinds of personal information:

i) Name;

ii) Contact details e.g. street address, email address, telephone number;

iii) Work Experience;

iv) Job Title;

v) Professional Certifications;

vi) Education & Qualifications;

vii) Skills;

viii) Career History;

ix) Salary Range;

x) Right to work status \ citizenship;

xi) Other information relevant to help us provide recruitment services;

xii) References from past employers; and

xiii) IP address

c) “Sensitive personal information” means: nonpublic personal information that reveals:

i) A consumer’s social security, driver’s license, state identification card, or passport number;

ii) A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;

iii) A consumer’s precise geolocation;

iv) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;

v) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication;

vi) A consumer’s genetic data;

vii) The processing of biometric information for the purpose of uniquely identifying a consumer; and

viii) Personal information collected and analyzed concerning a consumer’s health; and

ix) Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

We do not collect, sell, share, use or disclose your sensitive personal data without your consent.

d) For Contract Candidates Only (consumers/individuals who are employed by, consult with and/or own an entity recruited by TRG to provide contract or temporary technical professional services to an TRG client (or an TRG client’s client))

i) In addition to the personal information or sensitive personal information listed above, TRG may collect the following from you:

1. Tax details and proof of payment and submission;

2. Commercial insurance information; and

ii) Bank and payment details.

1. While this information may relate to your company or your employer rather than being your personal information, we have listed this information for transparency.

2. If your provision of personal information or sensitive personal information to TRG is necessary to enter into a contract with your company or your employer, your failure to provide us with accurate personal information may result in TRG not being able to offer or render recruitment services to you, your company or your employer.

4. The categories of third parties with whom the business shares personal information or sensitive personal information.

a) All users of the websites and/or our services

i) To third parties where we have retained them to provide services that we or you have requested or that TRG clients have requested including references, qualifications and background reference checking services and to verify the details you have provided from third party sources.

ii) To third parties to provide data storage, CV/resume parsing, data cleansing and marketing (via email & SMS, standard SMS and text rates may apply) services to TRG where such third parties have agreed to maintain the confidentiality of, and to protect, your personal information in accordance with applicable law.

iii) To third parties to assist with credit control and payment management.

iv) To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, in connection with legal proceedings or other similar cause or circumstance.

v) To TRG affiliates, whose locations can be found at https://www.tenthrevolution.com/contact in order that they may process your personal information in accordance with the Privacy Addendum.

vi) In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets, or a controlling interest in the equity, of TRG (or any of its group companies) provided that such counterparty(ies) to any such transaction agrees to adhere to the terms of the Privacy Addendum (or a similar document) and applicable law.

b) Actual or Prospective Candidates

i) To TRG clients in order for them to determine if you (permanent hire candidate) or your company or employer (contract candidate) are or may be qualified to fill a vacancy.

c) Individuals who work for TRG clients (i.e. a client contact)

i) To candidates in the course of providing your company or employer with recruiting services and to further the recruitment process.

ii) To third parties where we have retained them to provide services that you have requested including candidate skill tests and other testing.

5. The categories of sources from which the personal information or sensitive personal information is collected.

i) We collect personal information or sensitive personal information from you actively when you enter it into our services (e.g., your name, your CV/resume, etc.).

ii) We collect personal information passively when you access our services, to the extent your web browser provides this information to our servers (e.g., your operating system) and also based on your service usage (e.g., when and from what IP address you log on to our services).

iii) We collect personal information or sensitive personal information when it is provided to us by either yourself or a third party (for example, LinkedIn, Jobboard, CV databases, etc.).

6. The business or commercial purpose for collecting, selling, sharing personal information or disclosure of sensitive personal information.

a) Why do we process your personal information or sensitive personal information?

i) Generally, we use your personal information or sensitive personal information for our business and activities, and in our efforts to expand and improve our business. Examples include:

1. All users of the Websites and/or our services

a) To provide our recruitment services to you, your employer or your company;

b) To facilitate the recruitment process, including but not limited to:

i) Qualifying and submitting candidates;

ii) For clients, negotiating TRG terms of business;

iii) Arranging interviews and obtaining feedback;

iv) Negotiating compensation packages; and

v) Providing post placement follow up.

c) To assess data about you against vacancies which we judge may be suitable for you;

d) To third party vendors to assist us in hosting, managing and operating our websites;

e) To third party vendors who provide data analysis and data updating services to us;

i) To third party vendors who provide email and other communications related services to us

f) To enable you to submit your CV/resume to TRG, apply online (including through the Websites) for jobs or to subscribe to alerts about jobs we think may be of interest to you;

g) To enable us to develop and market other products and services and where you have consented to being contacted for such purposes;

h) To improve our customer service and to make our services more valuable to you (including tailoring the Websites when you log on to enrich your personal online experience);

i) To send you electronically or by post surveys, reports, TRG event details, promotions, offers, networking and client events and general information about relevant industry sectors which we think might be of interest to you, where you have consented to being contacted for such purposes (and we will provide you with an opportunity to opt out);

j) To identify you, and respond to and process your requests for information and provide you with a product or service;

k) To amend records to remove personal information;

l) To use your information on an anonymised basis to monitor compliance with our equal opportunities policy, other TRG policies and any legal or compliance requirements;

m) To use your information on an anonymised basis to create marketing materials such as a salary survey; and

n) To carry out our obligations arising from any contracts entered into between you and us, and for other everyday business purposes that involve use of personal information.

2. Actual or Prospective Candidates

a) To help find you or your company a job;

b) To contact you (permanent hire candidates), your employer or your company (contract candidates) about jobs that TRG is filling or may fill for TRG clients;

c) To provide you or your company with information about the job market;

d) To communicate with you (permanent hire candidates), your employer or your company (contract candidates) after you or it has started a job to make sure all is going well or to remedy, or attempt to remedy, any problems;

e) To answer any questions you have about a job or the job market;

f) To fulfill any aspect of your employer’s or your company’s contract with TRG (for contract candidates only);

1. To third party vendors who provide customer relationship management database services to us;

2. To third party vendors who provide data analysis and data updating services to us

3. To third party vendors who provide document execution, transmission and storage services to us

4. To third party vendors who provide email and other communications related services to us

g) To collect any money due, or allegedly due, to TRG or any TRG client (or TRG’s client’s client);

h) To obtain or inquire about any property (including computers and confidential business information) owned, or allegedly owned, by TRG or any TRG client (or TRG’s client’s client);

i) To establish, exercise or defend any legal claims; and

j) To assist you (permanent hire candidates), your employer or your company (contract candidates) if you are dissatisfied or dislike the job, or any aspect of it.

3. Individuals who work for TRG clients (i.e. a “client contact”)

a) To fill an open vacancy at your company or employer;

b) To contact you about candidates for jobs with whom TRG has a relationship;

c) To provide you with information about the job market;

1. To third party vendors who provide customer relationship management database services to us.

2. To third party vendors who provide data analysis and data updating services to us

3. To third party vendors who provide document execution, transmission and storage services to us

4. To third party vendors who provide email and other communications related services to us

d) To communicate with you after your company or employer has hired/retained an TRG candidate to make sure all is going well and to remedy, or attempt to remedy, any problems;

e) To negotiate and fulfil any aspect of your company’s or employer’s contract with TRG;

f) To answer any questions you have about a job or a candidate or your company’s or employer’s contract with TRG;

g) To resolve any issue with the issuance, payment, collection or enforcement of an TRG invoice;

h) To collect any property owned by TRG or any TRG candidate;

i) To establish, exercise or defend any legal claims.

7. The specific pieces of personal information or sensitive personal information it has collected about that consumer.

a) Please email us at privacy@tenthrevolution.com, use the interactive webform located here, or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 to request this information. Before we can respond to your request, we’ll need to verify your identity.

8. A description of a consumer’s rights pursuant to US Data Privacy Laws, including CCPA Section 1798.115:

a) If we sell your personal information or disclose it for a business purpose, you have the right to know:

i) The categories of personal information or sensitive personal information that the business collected about the consumer.

1. See Section VI 4) above (e.g., web log data, registration data, resume/CV data, etc.).

ii) The categories of personal information or sensitive personal information that the business sold, shared, used or disclosed about the consumer and the categories of third parties to whom the personal information or sensitive personal information was sold, shared, used or disclosed, by category or categories of personal information or sensitive personal information for each third party to whom the personal information or sensitive personal information was sold, shared, used or disclosed-to.

1. See Sections VI 4), VI 5) and VI 6) above.

iii) The categories of personal information or sensitive personal information that the business used or disclosed about the consumer for a business purpose.

1. See Section VI 6) above.

b) If we sell or share your personal information or disclose it for a business purpose, you have the right to request that we disclose to you (1) the categories of personal information or sensitive personal information that we collected about you, (2) the categories of personal information or sensitive personal information we sold, shared, used or disclosed about you and the categories of third parties to whom we sold, shared, used or disclosed it, by category of personal information or sensitive personal information for each third party to whom we sold, shared, used or disclosed your personal information or sensitive personal information and (3) the categories of personal information or sensitive personal information that the business sold, shared, used or disclosed about the consumer for a business purpose. We are required to verify your identity before providing you with this information if the information would constitute your personal information or sensitive personal information. To exercise these important rights, please: mail us at privacy@tenthrevolution.com or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 to request this information. Before we can respond to your request, we’ll need to verify your identity.

c) If we sell or share your personal information or use or disclose your sensitive personal information to a third party or disclose it for a business purpose, we are required to disclose:

i) The category or categories of consumers’ personal information or sensitive personal information we sold, shared, used or disclosed, or if we have not sold your personal information or sensitive personal information, we shall disclose that fact.

1. If we sell or share your personal information or sensitive personal information, it will be in the form of your CV/resume, anonymized or pseudonymized.

ii) The category or categories of consumers’ personal information or sensitive personal information it has used or disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information or sensitive personal data for a business purpose, it shall disclose that fact.

1. We rely on vendors to operate our infrastructure, and accordingly for each category of personal information or sensitive personal information that we disclosed above as a category that we collect, we disclose it to one of our third-party vendors for a business purpose (i.e. to develop, market, provide and support our business services). Those categories are: web log data, registration data, payment data, service usage data, customer content, consumer content and marketing data.

d) If we sell or share your personal information or use or disclose your sensitive personal information to a third party, it is not allowed to resell it unless we notified you explicitly and provided you with a chance to opt out.

1. We do not allow third parties to whom we sell your personal information to resell the personal information or sensitive personal information, so no opt-out choices apply. See tenthrevolution.com/privacy-notice for details. We do allow third parties to whom we share your personal information or use or disclose your sensitive personal information to reshare the personal information or reuse or redisclose sensitive personal information for business purposes (we do not allow resharing or redisclosure for non-business purposes), and you have the right to opt-out. See tenthrevolution.com/privacy-notice for details.

9. A description of a consumer’s rights pursuant to the US Data Privacy Laws, including CCPA Section 1798.125:

a) Businesses, including us, may not discriminate against you because you exercised any of your consumer privacy rights such as by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including via discounts or other benefits or penalties; (3) providing you a different level or quality of goods or services or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Businesses may however discriminate where any difference is reasonably related to the value provided to you by your data.

b) Businesses, including us, may offer you financial incentives, including payments as compensation, for the collection, sharing, sale or deletion of your personal information or use or disclosure of your sensitive personal information. If we offer any incentives we will (1) notify you about them in our privacy policy and any applicable US-state (including California)-specific descriptions of consumer privacy rights we post and (2) only enroll you in them with your opt-in consent after disclosing all material incentive program terms to you. Incentive programs may never be unjust, unreasonable, coercive, or usurious.

i) We do not currently offer any financial incentives.

10. A description of a consumer’s rights pursuant to the US Data Privacy Laws (including CCPA Section 1798.105):

a) You have the right to request that we delete any personal information or sensitive personal information about you that we have collected. Before we delete any information, we’ll need to verify your identity. If we delete your information, we’ll also instruct our vendors (aka service providers) to delete it. The US Data Privacy Laws (including the CCPA) does not obligate us to delete information under all circumstances, including where we need the information to provide our services to you, to detect security incidents, to identify errors in our services, or to comply with legal obligations. If you request that we delete information, we’ll let you know if we are deleting it or if we are not deleting it based on exemptions provided by the US Data Privacy Laws (including the CCPA).

11. One or more designated methods for submitting requests (at minimum, a toll-free telephone number):

a) You may submit any consumer privacy requests by emailing us at privacy@tenthrevolution.com, use the interactive webform located here, or by calling us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and entering Service Code 717. Before we can respond to your request, we’ll need to verify your identity.