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Privacy and Data Policy

Privacy and Data Policy

Introduction

HireBrain, Corp. (“HireBrain”) respects the privacy of its customers, users, prospects, business partners, event attendees, employees, job applicants, and website and mobile application users (collectively, “you”), and we are committed to protecting it in accordance with applicable laws and using generally-accepted industry practices. This Privacy Policy explains who we are, how we collect, share, and use personal information about you, and how you can exercise your privacy rights.

For purposes of this Privacy Policy, “Personal Information” (or “Personal Data”) means any information that is available to HireBrain and that is protected explicitly by the European Union General Data Protection Regulation of 2016 (the “EU GDPR”); the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 (the “UK GDPR”); and the California Consumer Protection Act “CCPA”), to the extent applicable.

If you have any questions or concerns about HireBran’s collection and use of your Personal Information, please contact us using the details provided below under Contact Information. 

Scope Of Policy

HireBrain strives to collect and use Personal Information in a manner consistent with the laws of the countries in which it does business. In general, our privacy practices conform with local law and regulation, including where applicable the provisions of the European Union’s General Data Protection Regulation (GDPR). Accordingly, our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

This Policy does not reflect the privacy practices of HireBrain’s customers and HireBrain is not responsible for its customers’ privacy policies or practices. HireBrain does not review, comment upon or monitor its customers’ compliance with their respective privacy policies, nor does HireBrain review its customer instructions to determine whether they are in compliance with or conflict with the terms of a customer’s published privacy policy.

Personal Information We May Collect

Personal Information, or Personal Data, means any information about an individual from which that person can be identified. 

This includes any data received by HireBrain in any format, whether through its hosted software, online or in-person training and education (collectively, “Services”), or through feedback and performance enhancement channels, whether supplied directly by HireBrain customers or by candidates or others affiliated with HireBrain customers, whether provided for “live” production purposes or for research and development activities, anywhere in the world, including transfers from the European Economic Area (EEA) to the United States.

We may collect, use, store and transfer different kinds of Personal Data about you which may include:

  • Identity Data may include first name, last name, job title, company name.
  • Contact Data may include contact address, email address and telephone numbers.
  • Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
  • Usage Data may include information about how you use our websites, products and services, clickstream to, through and from our sites (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from a page.
  • Marketing and Communications Data includes your preferences in receiving marketing from us, and your communication preferences.

We may use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data through direct interactions which include, but are not limited to: completing an account profile, filling in an online form, or corresponding with us by mail, phone, email or otherwise. These direct interactions can happen in a variety of circumstances which include, but are not limited to: 

  • Using our Services in the scope of your employment with a Customer company;
  • Asking us to supply you with a product demonstration; 
  • Applying for a job with us; 
  • Requesting to be on our mailing list; 
  • or providing us with feedback.

Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this Personal Data by using cookies, server logs and other similar technologies. For further details, please refer to “Cookies and Use of Other Tracking Technology” below. 

Third parties or publicly available sources. We may receive Identity and Contact Data about you from public sources.

How Do We Use Your Data?

HireBrain will use Personal Information only in ways compatible with the purpose for which it was collected or subsequently authorized by our customers. HireBrain will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate and complete.

We may use information about you for various purposes, including to:

  • Provide, maintain and improve our Services;
  • Provide and deliver Services to Customers including requests,configurations, process transactions which may use Personal Data to send relevant notifications and confirmations;
  • Investigate system issues that impact our ability to provide Services to Users;
  • Send technical notices, updates, confirmations, security alerts and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate to Customers and Users about products, services, offers, promotions, rewards and events offered by HireBrain and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services and improve and personalize  Services;
  • Personalize and improve Services, content or features that match user profiles or interests;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; and
  • Connect you with other users in your Company.

How Do We Share Your Data?

We will not sell, rent, or share Personal Data with third parties outside of our company without your consent, except in the following ways:

LAW ENFORCEMENT AND INTERNAL OPERATIONS

Personal Data may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against HireBrain or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and debugging purposes; or (iv) to protect the rights, property or safety of HireBrain, its users or members of the general public. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third-party request to compel disclosure of your information.

BUSINESS TRANSFER

HireBrain may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Under such circumstances, HireBrain will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.

THIRD PARTIES

We sometimes contract with other companies and individuals to perform functions or services on our behalf, such as software maintenance, data hosting, sending email messages, etc. We necessarily have to share your Personal Data with such third parties as may be required to perform their functions.  If we disclose information of our Customers or Users to a third party that is acting as our agent or on our behalf, we will ensure that the third party has agreed to abide by the GDPR provisions or can otherwise assure adequate protection of such information.

Do You Have The Right To Withdraw Consent?

You always have the right to withdraw consent where such consent is required to share or use your Personal Data. You may also  request that we delete your Personal Data. 

If you receive communications from us and no longer wish to receive them, please follow the removal instructions in the email or change your account settings. 

To exercise any of these rights at any time, you can email admin@www.hirebrain.com to let us know your request. . We will make reasonable efforts to complete your request in a reasonable timeframe.

Please be advised that deleting Personal Data does not mean that all of it will be removed. 

We may be required by law to retain it, or to exercise or defend legal claims, or contractual obligations with our customers (which may include your employer)  to retain some information in connection with our obligation to provide the Services. We also may de-identify and anonymize some data for purposes of retaining it.

Are You Obligated To Provide Personal Data?

In general: the provision of your Personal Data is voluntary. 

You are neither legally nor contractually obliged to do so. We do not contractually oblige you to provide us with Personal Data. Please note, however, that if you refuse to provide Personal Data, you may not be able to use all of our Services.

Do We Retain Your Data?

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which we collected it.

Do We Use Your Data For Marketing?

We may process your data when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our products and services where these are deemed to be relevant to you and your organization, and in accordance with your rights under applicable law.

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:

  • We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
  • You may receive marketing communications from us if you have been referred to us by a third party (with your prior consent), you have requested information from us or purchased services from us or if you have provided us with your details only if, in each case, you have not opted out of receiving that marketing.

How Do We Secure Your Data?

HireBrain is committed to ensuring the security of the information it processes. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. HireBrain strives to protect the privacy of the information we process, and inadvertent disclosure is extremely unlikely. In the event of such an inadvertent disclosure, HireBrain will take all commercially reasonable steps to limit and remedy the disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those procedures or use your personal information for improper purposes. No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Cookies And Use Of Other Tracking Technology

When you visit our public website (www.hirebrain.com) or any of our hosted software (https://learn.hirebrain.com/) used in the provision of Services (collectively “Sites”), as is true of most websites, we gather certain data automatically. This data may include Internet protocol (“IP”) addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

We use cookies or similar technologies to analyze trends, administer our Sites, track users’ movements around the website, and to gather demographic data about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. 

HireBrain uses Google Analytics and Hotjar to collect and process this data. Both are self-certified under the US-EU Privacy Shield and the Swiss-U.S. Privacy Shield framework to process data in the United States and data is only shared subject to a Data Protection Addendum. 

You can opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: https://tools.google.com/dlpage/gaoptout?hl=en  

To make a Do Not Track request to Hotjar, you can enable your browser settings accordingly using the Do Not Track instructions provided by Hotjar: https://www.hotjar.com/policies/do-not-track/

For more information, please refer to Privacy Policies for Google Analytics and Hotjar. 

International Transfer

HireBrain may collect, use, process, store and disclose your Personal Data outside of your home jurisdiction, including in the U.S.  The U.S. may have data protection and privacy laws that are different than the laws of your home country. HireBrain only transfers Personal Data to another country in accordance with applicable data protection and privacy laws, provided there are legally adequate protections in place for the Personal Data. 

Specifically, our primary offices are located in the US, and our third-party service hosting providers are located in the US.

If you require further information about our international transfers of Personal Data, please contact us by using the contact details under Contact Information below.

Notice To European, Swiss And Uk Users

If you are a resident of the EEA, the UK, or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the context in which we collect it. However, we will normally collect and/or process your Personal Data pursuant to one or more of the following legal bases:

  • The processing is in our legitimate interests which do not override your data protection interests or fundamental rights and freedoms.
  • The processing is necessary to perform a contract with you.
  • The processing is necessary to comply with our legal obligations.
  • We may also seek your consent to process or retain your Personal Data in certain, limited circumstances that we clearly identify to you.
  • In some limited cases, we may need the Personal Data to protect your vital interests or those of another person; for example, we may need to share your Personal Data with third parties for security reasons (when we believe in good faith that disclosure is necessary to protect our rights, protect your or others’ safety, to investigate fraud, or respond to a related government request).

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your Personal Data is mandatory or not (as well as the possible consequences if you do not provide it). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of a third party) that are not listed above, we will make clear to you at the relevant time what those legitimate interests are. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided in the “Contact Information” section below.

EU/Swiss/UK Data Transfers

With respect to transfers of data from the EEA, Switzerland, or the UK, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Policy, and we will only transfer Personal Information to recipients that provide an adequate level of data protection or as permitted by applicable data protection laws by implementing appropriate safeguards, including but not limited to relevant data transfer agreements based on the Standard Contractual Clauses, when necessary. The Standard Contractual Clauses shall apply to any transfers of Personal Information from the EEA and/or its member states, Switzerland, and the United Kingdom to countries which do not ensure an adequate level of data protection within the meaning of applicable laws of the foregoing territories.

Data Protection Rights

As an EEA, Swiss, or UK data subject, you have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us at admin@www.hirebrain.com.
  • You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us at admin@www.hirebrain.com.
  • Similarly, if we collect and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of our website is directed to children under the age of 13. We will take steps to delete it if we learn we have inadvertently collected it.

Updates To This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

Contact Information

If you have any comments or questions about our Privacy Policy, or to exercise your rights, feel free to contact us at admin@hirebrain.com.

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