ATTSPIRE Talent Advisory LLC and its affiliates and subsidiaries ("ATTSPIRE," "we," "us" or "our") recognize the importance of protecting the privacy of our customers and online visitors. This Privacy Policy explains how we collect, use, disclose, retain, and otherwise process information about you when you use our services and visit our websites and mobile applications that link to this Privacy Policy (collectively, the "Site").
For purposes of this Privacy Policy, "personal information" means information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual, as defined under applicable law.
This Privacy Policy applies to you if you are:
a Candidate using our services to search or apply for a job, or who might be interested in a future position with one of our employer clients ("Candidate"); or
a client using our services as an employer ("Employer").
By accessing or using the Site or our services, or by submitting information to or through the Site or services, you acknowledge that you have read this Privacy Policy and understand that we will collect, use, disclose, retain, and otherwise process your personal information as described here, as permitted by applicable law.
If required by applicable law (for example, in certain EU/UK jurisdictions), we will rely on your consent or another lawful basis before processing your personal information.
1. Information We Collect
We collect only the personal information that is adequate, relevant, and proportionate to the purposes set out in this Privacy Policy.
1.a. Personal Information
i. Candidates
If you are a Candidate, we may collect the following categories of personal information:
Identifiers: Name, alias, address, unique personal identifier (for example, social media identification or personal websites), online identifier, IP address, and email address.
Categories of Personal Information Listed in the California Customer Records Statute: Name, physical characteristics or description, address, telephone number, education, employment, employment history, and salary and income information.
Characteristics of Protected Classifications under Applicable Law (including sensitive personal information): Gender, race, disability, veteran status, and languages spoken, to the extent you choose to provide this information and as permitted by law.
Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, actions taken on the Site, approximate geographic location, and language preference.
Geolocation Data: Approximate geographic location.
Audio, Electronic, Visual, or Similar Information: Photographs; recordings of calls and virtual meetings, including video and voice recordings; call transcripts; meeting details; and other communications between you and us.
Professional or Employment-Related Information: Employment history, professional certifications, skills, references, resume, salary once you are placed with an Employer, and income or other information collected through interviews and evaluations.
Education Information: Degrees received and schools attended.
This information is collected and stored electronically when you visit the Site, sign up to join our network, apply to a job through our services, or contact us.
We may also receive similar data from:
our business partners, including our subsidiaries, affiliates, or other related companies;
third-party social media platforms (for example, LinkedIn), subject to your registration and privacy settings with such platforms;
Employers and our service providers; and
publicly available sources.
Where permitted by applicable law, we may combine your personal information with other information we have collected from you, from our business partners, and from publicly available sources.
We collect certain sensitive personal information (for example, race, disability, or veteran status) only where permitted by law and, where required, based on your explicit consent and/or for limited purposes such as equal opportunities monitoring and diversity initiatives.
ii. Employers
If you are an Employer, we may collect the following types of personal information about you or your representatives:
Identifiers: Name, unique personal identifier, online identifier, account username and password, IP address, and email address.
Categories of Personal Information Listed in the California Customer Records Statute: Name, physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or other financial information.
Commercial Information: Services purchased, obtained, or considered, and other purchasing histories or tendencies.
Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, actions taken on the Site, approximate geographic location (for example, country), and language preference.
Geolocation Data: Approximate geographic location (for example, country).
Audio, Electronic, Visual, or Similar Information: Photographs; recordings of calls and virtual meetings, including video and voice recordings; call transcripts; meeting details; and other communications between you and us.
Other Information: Responses to surveys and assessments about our services.
This information is collected and stored electronically when you visit the Site, purchase our services, register an account with us, or contact us. We may also receive similar data from our business partners, including our subsidiaries, affiliates, or other related companies, and our service providers.
1.b. Information Collected Automatically
When you use the Site, we automatically collect certain technical information about your device's hardware and software, which may include:
IP address
Operating system type
Browser type
Access times and dates
Device type
Actions taken on the Site
Approximate geographic location
Language preference
Other technical information such as protocol status and substatus, bytes sent and received, and server information.
We use this information for our business purposes, including to operate and improve the Site, for technical troubleshooting, to maintain the quality of the Site, to detect and prevent fraud, and to generate aggregate statistics regarding use of the Site.
1.c. Cookies and Similar Technologies
A cookie is a small file containing a string of characters that is sent to your device when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device and may store unique identifiers, user preferences, and other information.
We may use session cookies (temporary, which expire when you close your browser) and persistent cookies (which remain on your device for a set period or until you or your browser delete them).
The types of cookies we may use on the Site include:
Necessary Cookies: These cookies are necessary for you to browse the Site and use its features, such as accessing secure areas of the Site.
Personalization Cookies: These cookies collect information about how you have used the Site in the past and allow the Site to remember the choices you have made.
Analytics Cookies: These cookies collect information about how you use the Site, such as which pages you visit, how long you spend on the Site, which links you click, and any issues encountered.
Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device, and you may withdraw your consent at any time by changing your browser settings or using our cookie preferences tool.
2. How Information Is Used
We may use the information we collect for any of the following purposes, to the extent permitted by applicable law:
to provide and maintain the Site and services;
to send marketing and promotional materials, including information relating to our services (where permitted by law or with your consent);
to personalize the Site and services we offer;
for security purposes, to detect and prevent fraud or illegal activities, and for archival and backup purposes;
to respond to your inquiries and communicate with you;
to generate aggregated or de-identified statistics and reports;
for other business purposes, such as data analytics, accounting, auditing and reporting, and improving the Site and services;
as we believe necessary or appropriate under applicable law, to comply with legal process, or to respond to requests from public and government authorities; and
for other purposes to which you consent.
We do not use automated decision-making or profiling that produces legal or similarly significant effects on you without providing the notices and rights required by applicable law.
For Candidates: We may use Candidate information to contact you about employment opportunities, enable you to apply to a position, conduct pre-employment assessments, and allow an Employer to evaluate your qualifications.
For Employers: We may use Employer information to fulfill your requests, create and manage your account, enable you to search for Candidates, and provide customer service and support.
3. Disclosure of Information
We may disclose your personal information as described below and as otherwise described in this Privacy Policy, in each case to the extent permitted by applicable law.
With Third-Party Service Providers: We share personal information with service providers that perform services for us or on our behalf, such as hosting the Site, providing website analytics, sending email communications, and processing payments.
With Our Subsidiaries and Affiliates: We may share your information with our subsidiaries, affiliates, or other related companies for internal business purposes.
For Legal and Compliance Purposes: We may share personal information as needed to enforce our rights, respond to subpoenas, court orders, or legal process, and respond to lawful requests from public or government authorities.
Changes of Control: We may transfer personal information in connection with a corporate transaction such as a merger, consolidation, asset sale, or insolvency proceeding.
For Candidates: We may share your information with Employers and with other companies that may have an interest in candidates with your qualifications, as permitted by law and consistent with your preferences.
For Employers: We may share your contact information with Candidates who are interested in applying for a position with your company.
3.a. Cross-Border Transfers
All personal information we collect is currently processed in the United States. When we transfer personal information from the EEA, UK, or Switzerland, we will use appropriate safeguards such as Standard Contractual Clauses.
4. Links to External Websites and Online Services
Our Site may contain links to third-party websites and online services. Any access to and use of such websites and services is not governed by this Privacy Policy, but by the privacy policies of those third parties.
5. Social Media
Some aspects of the Site may allow you to interface with social media platforms such as LinkedIn. By using these features, you may allow us to access information about you from those services in accordance with your privacy settings on those platforms.
6. Your Rights and Choices
6.a. Accessing, Correcting, and Deleting Your Personal Information
If you have an account with us, you can review and update certain personal information by logging into your account and visiting your profile page.
You may also request access to, correction of, or deletion of your personal information by using our Contact Form.
6.b. Marketing Communications
You may opt out of receiving our marketing emails by following the unsubscribe instructions included in such emails or by contacting us through our Contact Form.
6.c. Cookie Preferences
Where required by applicable law, you may manage your cookie preferences at any time using our cookie preferences tool or by adjusting your browser settings.
7. Data Security and Retention
We use reasonable technical and organizational security measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with legal, accounting, or reporting obligations, and to resolve disputes and enforce our agreements.
8. Do Not Track Signals
Our Site does not currently respond to browser "Do Not Track" signals.
9. Children
We do not knowingly collect or maintain personal information from any person under the age of 18, and no parts of our Site are directed to or designed to attract anyone under the age of 18.
Depending on where you reside, you may have additional rights under applicable local law. The sections below describe rights available to residents of specific jurisdictions.
10. Nevada Residents
Under Nevada law, ATTSPIRE does not sell your personal information. Nevada residents may submit a request by contacting us through our Contact Form.
11. California Residents
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"), provides California residents with specific rights regarding their personal information.
11.a. CCPA Rights
Right to Know: You have the right to request that we disclose the personal information we collect, use, disclose, sell, or share about you.
Right to Delete: You have the right to request that we delete personal information that we collected from you, subject to certain exceptions.
Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.
Right to Opt Out of Sale or Sharing: You have the right to direct us not to "sell" or "share" your personal information as defined under the CCPA. To exercise this right, please visit our "Do Not Sell or Share My Personal Information" web page.
Right to Limit Use of Sensitive Personal Information: We only use sensitive personal information for purposes permitted under the CCPA.
No Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
11.b. How to Submit a Request
To exercise the rights described above, you must submit a verifiable consumer request by using our Contact Form.
We will take steps to verify your identity or the authority of your designated agent before fulfilling your request. You may designate an authorized agent to submit a request on your behalf by providing the agent with signed written permission.
12. EU/UK/Switzerland Residents
For purposes of EU/UK/Switzerland data protection laws, ATTSPIRE acts as the "controller" for personal information described in this Privacy Policy.
We process personal information under the following legal bases: Performance of a Contract, Legitimate Interests, Consent, and Legal Obligations.
Subject to applicable law, you may have the following rights: Right of Access; Right to Rectification; Right to Erasure; Right to Restrict Processing; Right to Object; Right to Data Portability; Right to Withdraw Consent; and Right to Lodge a Complaint with a supervisory authority.
You may exercise these rights by using our Contact Form.
13. Questions / Contact Us
If you have any questions or concerns regarding this Privacy Policy or our privacy practices, or if you wish to exercise your rights, please contact us at:
ATTSPIRE Talent Advisory LLC
ATTN: Privacy Officer
Use our Contact Form.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Effective Date" at the top of this Privacy Policy and, where required by law, notify you or obtain your consent before the changes take effect.
