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NON-EU Privacy Policy

WILSONHCG - Non-EU PRIVACY POLICY

 

I. INTRODUCTION

Wilson Human Capital Group, Inc. (hereinafter referred to as “WilsonHCG” or “we” or “us” or “our”) and its subsidiaries respect the privacy of our users. This Privacy Policy applies to “you” our clients, business partners, candidates, anyone using our website (“users” or “consumers”), suppliers and any other third parties with whom we may work or to whom we supply our services, including recruitment.

We have a separate Privacy Policy for our employees, which is provided to the employee and accessible to them on our intranet.

As a whole, we strive to protect the Personal Information that we may collect about our users, under our control and take certain precautions to help maintain the security and accuracy of the data. This policy, in accordance with US law, defines “Personal Information” as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. When you use this website, you trust us with information about you. Subsequently, you may provide us with Personal Information. Because your privacy is important to us, we recommend you read this privacy policy (“Privacy Policy”) so that you understand our approach towards the use of your Personal Information and contact us if you have any questions.

All the terms and conditions in this privacy policy are generally applicable to the United States and Canada. In general, our privacy practices conform with local laws and regulations, including where applicable the provisions of the California Consumer Privacy Act (CCPA) and the Nevada Privacy Law (SB 220). However, where specifically identified, certain jurisdiction will have variations and differences about their jurisdictional privacy practices. Those differences are indicated in the following heading(s): CANADA’S POLICY.  

 

II. IMPORTANT INFORMATION ABOUT OUR GLOBAL WEBSITES

We are a global organization and we aim to comply with the legal requirements of each individual country. Therefore, we provide regionally specific privacy policies. Please read the privacy policy on our website applicable to you.

This Privacy Policy also describes how you can contact us about our privacy practices and to exercise your rights. 

Lastly, we use cookies on our website - please refer to “Section XVII. Cookie Policy” contained herein.

 

III. WHO ARE WE?

We provide recruitment processing outsourcing services, consulting, reporting, talent mapping, employment branding, analysis, fixed term contract services, executive search, perm search, and other recruitment related services.

Our company and our subsidiaries are:

United States 

Wilson Human Capital Group, Inc.  

Wilson Worldwide, LLC dba WilsonCTS 

Canada 

Wilson Contingent Talent Solutions, Inc.  

WilsonHCG Canada Inc. 

EMEA 

WilsonHCG EMEA Limited  

WilsonHCG Poland Sp.zo.o  

WilsonHCG Ireland Limited  

WilsonHCG France 

WilsonHCG Talent S.R.L.  

CPH Consulting LTD  

APAC 

WilsonHCG Hong Kong Limited 

WilsonHCG Talent Japan KK  

The Profile Group (HK) Limited

Profile Search & Selection (Singapore) Pte. Ltd

The Profile Group (Shanghai) Limited

 

IV. PERSONAL INFORMATION YOU PROVIDE TO US OR WE COLLECT

Our site does not automatically collect any individually identifiable information from visitors. The information collected depends on the nature of how you choose to interact with us and services you use. In most cases, we may obtain personally identifiable information about you only if you elect to give us that information. 

Under this policy, Personal Data is any data that identifies, or could reasonably be used to identify you and some of that Personal Data may be special category data (more sensitive data). We collect your Personal Data both directly and indirectly.

 

A. METHODS OF COLLECTING PERSONAL DATA

  1. Directly: when you contact us, choose to provide data to us (for example you complete and submit a website form), use our services or provide products and services to us, engage with us on social media or, as a candidate, submit your CV/resume, attend an industry event, interview or take part in any psychological or medical assessment. Consent or other legal basis will always be obtained in order to process the data from any of these sources.
  2. Indirectly: we may collect Personal Data from publicly available data relating to your job title, education and employment such as registration with professional bodies, qualifications and commercially available sources, for example from social media sites such as LinkedIn, public job boards, trade organizations, trade events, advertisements, B2B contact database, or other public sources.

B. TYPES OF PERSONAL INFORMATION COLLECTED

  1. Contact Details: your name, employer name, address, telephone number and email address.
  2. Occupational Information: your job title, place of employment, experience, and/or skill set.
  3. Candidate Recruitment Information for Job Opportunities: your role, skill set, education, experience, work history and any other data required in the recruitment process.
  4. Submitted Job Application Information: your CV, resume, transcripts, and any supporting documentation attached to your resume such as copies of certificates and diplomas.
  5. Interview Related Information: obtained while conducting a phone interview, video interview, in-person interview, or interview through one of our third-party interview and recruitment service providers.
  6. Reference Check Information: such as a verification of your educational and professional background, and   other relevant information subject to WilsonHCG policies and applicable laws.
  7. Billing & Payment Information: when we obtain your payment information we may collect bank account numbers, tax information, deposits and/or other pre-approved financial transactions.
  8. Special Category Information: where appropriate and lawful, some of the Personal Information requested may be special category information, for example, which is Personal Information about an individual’s race; ethnic origin; politics; religion; trade union membership; health; sex life; sexual orientation; genetics and biometrics (where it is used for ID purposes). Should special category information be requested, expressed written consent shall be required and obtained prior to processing.

You can engage with us through social media websites, such as Facebook, LinkedIn, Twitter, Pinterest, Instagram, YouTube, Human Capital Connection blog, or through features at WilsonHCG.com that integrate with social media sites. If you use these websites, we will be able to access basic information from your social media profiles. Such information may include your name, email address, gender, pictures, geographic location or posts you write.

In addition to the information you provide, or accessed through social media websites, WilsonHCG may collect information from commercially available sources that it deems credible. Such information may include your name, address, email address, demographic information and occupation.

The above information may be stored in internal systems, such as client relationship management (CRM) and talent acquisition software (TAS) applications, on secure servers that are not accessible by third parties. These systems permit WilsonHCG employees to access and process such information solely for the purposes of customer fulfillment, business administration, business reporting, statistical analysis and marketing of WilsonHCG products and services.

We do not sell or rent our mailing lists to external organizations. We will not disclose your Personal Information to third parties, except with your consent or as required by law.

 

V. HOW WE USE PERSONAL INFORMATION

Our collection and/or use of Personal Information may include:

    1. Sharing within our internal teams and with our clients for recruitment purposes;
    2. Communicating with you, including to let you know about important  changes and or notifying you of content published by WilsonHCG which is likely to be relevant and useful to you;
    3. Assessing your ability and suitability for the employment position/s you are interested in if you are a candidate;
    4. Providing our services to you as and when you ask us to  fulfil our contractual obligations to you (for example, supplying candidate information to prospective employers);
    5. Fulfilling our contractual obligations to suppliers;
    6. Asking third parties to provide services to us including professional advisors, IT (including cloud providers), marketing, recruiting and interviewing software or services, and outsourced services to help run our business properly and efficiently;
    7. Marketing to you on industry specific content, provided that you consent to this;
    8. Complying with regulations and legislation;
    9. Resolving complaints and issues and establish and defend our  legal rights or manage insurance claims in which you are involved; 
    10. Managing our business properly and efficiently; and
    11. Providing you with information you request or indicate you may be interested in receiving.

To optimize our services, we may use your Personal Information for direct marketing. We take your privacy seriously and will only use your Personal Information when you are aware. If required by law, we will request your consent prior to using your Personal Information for direct marketing.

Additionally, if at any time you wish us to stop using your information for any or all of the above purposes, please CONTACT US as set out below. We will stop the use of your information for such purposes as soon as it is reasonably possible to do so.

Unless specifically stated in this Privacy Policy, we will not disclose any personally identifiable information without your permission unless we are legally entitled or required to do so (for example, if required to do so by legal process or for the purposes of prevention of fraud or other crime) or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and those of our users/customers or other individuals.

Please be assured that we will not use your Personal Information for any purposes other than indicated.

 

VI. YOUR PERSONAL INFORMATION RIGHTS

In addition to the right to receive information contained in this Privacy Policy, the law gives you certain rights in relation to your Personal Information

You may exercise these rights by emailing us at privacy@wilsonhcg.com by sending us a Verifiable Consumer Request. A “Verifiable Consumer Request” (“request”) is one that WilsonHCG can reasonably verify is, in fact, you requesting an action related to your personal information. The verification of these requests is an extremely important aspect of the law. After all, the purpose of the law is to prevent unauthorized disclosures of Personal Information. To verify that you are submitting the request, we will look to match the email from which you send your request to the one we have in our data systems as belonging to you. We will handle your Verifiable Consumer Request within 45 days of receiving it. If there is going to be a delay in dealing with your request or there is a reason why we can’t comply with your request, we will let you know and explain why within 45 days of receiving your request. 

A. YOU HAVE THE FOLLOWING RIGHT(S):

1. Right to Know

2. Right to Request/Access

3. Right to Opt-Out/Or Opt-In

4. Right to Request Deletion

5. Right to not be discriminated against

B. YOUR RIGHTS IN DETAIL:

1. RIGHT TO KNOW 

You have the right to know the categories of Personal Information WilsonHCG collects about you. Those categories are described in this policy under both: “IV. Information You Provide To Us Or We Collect”, and “V. How We Use That Information”. WilsonHCG will not collect additional categories of information or use Personal Information collected for additional purposes without providing you notice consistent with this policy. 

2. RIGHT TO REQUEST/ACCESS 

You have the right to request the categories of Personal Information WilsonHCG collects about you by emailing privacy@wilsonhcg.com. (Refer to XII: Section F: HOW WE RESPOND TO DO NOT TRACK SIGNALS (the “DNT Signal”)

3. RIGHT TO OPT-OUT (OR OPT-IN)

“Do Not Sell My Personal Information” and/or “opt-out” from “selling” of your Personal Information is your right as a candidate. You also have the right to opt-out from the subsequent selling of your Personal Information by a third party that received personal information after an initial “selling”. The third party shall not sell your Personal Information unless you have received “explicit notice” and you are provided an opportunity to opt-out. You understand that the opt-out can only stop the “selling” of Personal Information, and it does not impact other uses of their information. You can also opt-out by emailing us at privacy@wilsonhcg.com. Additionally, you do have the right to opt back in (opt-in) at your discretion. 

4. RIGHT TO REQUEST DELETION 

Once requested through the website and/or privacy@wilsonhcg.com email account, we will delete your Personal Information we have  collected about you, subject to certain exceptions.

5. RIGHT TO NOT BE DISCRIMINATED AGAINST

WilsonHCG will not discriminate against you for exercising any of the consumer’s rights under this policy.

 

VII. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

When you provide Personal Information to an individual at WilsonHCG (for example a recruiter) you are providing that information to our whole organization. In addition, we share your Personal Information with various third parties depending upon your relationship to our company.

You can obtain more information on any providers or suppliers we share your Personal Information with by request a copy of any agents at privacy@wilsonhcg.com

Where necessary, your Personal Information may be shared with various third parties including:

    1. Our third-party agents who provide services to us i.e. independent contractors 
    2. Service providers who perform functions on our behalf i.e. payroll, benefits, insurance, and other administrative services;
    3. Vendors, consultants, and other third party service providers to assist us in providing services on our behalf, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/C.V. information, interviewing, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training
    4. Third-party information storage providers who process information on our behalf i.e. email and storage provider, applicant tracking system
    5. Potential and active clients we provide recruitment services for, and to match the professional profile we have stored of our candidates in our database to any positions we have been asked to fulfill by any of our clients, and including any related administrative use such as invoicing 
    6. Public authorities who make a lawful request, including to meet national security or law enforcement requirements

VIII. SECURITY OF YOUR PERSONAL INFORMATION

We have implemented technology, security policies and measures to protect the Personal Information that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction and accidental loss. To find out more, see below.

This includes:

A. Storing Personal Information in our internal systems (such as client relationship management (CRM) and talent acquisition software (TAS) applications) on secure servers that are not accessible by third parties

B. Adhering to the Privacy Shield Principles where Personal Information is transferred from the European Union to the United States – see our Transferring Personal Information Outside the EU section

C. Providing internal policies, procedures and training about data protection to our employees

D. Restricting access and requiring that all our employees and others who have access to or are   associated with processing of your personal information to sign company confidentiality agreements.  Failure to meet these obligations is dealt with under our disciplinary procedure and may result in termination of employment

E. Encrypting many of our services using Secure Sockets Layer (SSL)

F. Regular reviews of the way we process information in line with our data protection policies

IX. EXTERNAL WEBSITE LINKS AND SOCIAL MEDIA

On our website, we may have links to websites of affiliated entities of WilsonHCG; however,, you may be referred to our website through a link from another unaffiliated, third party website. Therefore, we cannot be responsible for the privacy policies and practices of unaffiliated, third party websites. Access to any other Internet site linked to this website is at the user's own risk. We are not responsible for the accuracy or reliability of any data, opinions, advice or statements made on those sites, which includes but is not limited to any disclosures registrants make and that content is subject to their terms of use and any additional guidelines and privacy data provided in relation to that use on their website. Additionally, we do not intend to imply sponsorship, affiliation or endorsement with third-party sites.

We recommend that you check the policy of each website you visit to better understand your rights and obligations, especially when you are submitting any type of content on those third-party websites. Please contact the owner or operator of such website if you have any questions/concerns.

 

X. COLLECTION OF NON-PERSONAL INFORMATION

We also collect information which does not identify you (non-Personal Information). This includes the type of internet browser you use or the website from which you linked to our website.

We may also aggregate information which you have submitted to us (for example, your age and the town where you live) which is anonymous - you cannot be identified from this information. We share this aggregate information with third parties (for example to provide salary averages) to help us provide an effective service on our website.

 

XI. THIS WEBSITE USES GOOGLE ADWORDS

Our website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. Find more information below.

Using Google AdWords means that we can advertise to previous visitors who have begun but not completed an action on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. 

Third-party sellers, including Google, use cookies to serve ads based on someone’s past visits to our website. Of course, any information collected will be used in accordance with  our own privacy policy and Google’s privacy policies (you can find Google’s Privacy policy here: 

www.google.co.uk/intl/en/policies/privacy/).

 

XII. COOKIE POLICY

A. WHAT IS A COOKIE?

Cookies are small data files that your browser places on your computer or device.  Cookies help your browser navigate a website and the cookies themselves cannot collect any information stored on your computer or your files.

When a server uses a web browser to read cookies, they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.

B. WHY DO WE USE COOKIES?

We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website.

Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in the comment forms.

Some of the cookies we use are session cookies and only last until you close your browser, others are persistent cookies which are stored on your computer for longer. 

C. HOW ARE THIRD PARTY COOKIES USED? 

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third-party websites for information regarding their use of cookies. For further details on the third-party cookies that we use, see the third party cookies section below.

D. HOW DO I REJECT AND DELETE COOKIES?

We will not use cookies to collect personal identifiable information about you. However, should you wish to do so, you can choose to reject, or block cookies set by us or the websites of any third party suppliers by changing your browser settings – see the Help function within your browser for further details.

Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies.

You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. For information on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual.

Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

E. THIRD PARTY ADVERTISING COOKIES OPT-OUT

WilsonHCG is dedicated to providing privacy on the Internet. In addition to developing our Privacy Policy, we have provided you the opportunity to opt out of future third party advertising cookies.

WilsonHCG allows third parties to place cookies on our site for advertising purposes. This Privacy Policy does not cover the collection methods or use of the information collected by these third parties. These  third parties have their own privacy policies and may be members of the Network Advertising Initiative ("NAI"). To remove yourself from some or all NAI member advertising programs, please visit the NAI Opt-Out Page and follow the relevant instructions. Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew your opt-out choice.

F. HOW WE RESPOND TO DO NOT TRACK SIGNALS (the “DNT Signal”)

 Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to the web sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT Signals, nor a common definition of “tracking”, we do not currently respond to DNT Signals on the WilsonHCG websites. WilsonHCG engages in so-called online behavioral advertising on third-party sites (also sometimes called “retargeting” or “tracking”), through which information collected about the pages you visit on WilsonHCG is used to display ads for WilsonHCG products or services on third-party websites. This information may uniquely identify a browser but is not personally identifiable.

 

XIII. PERSONAL INFORMATION RETENTION

Unless you specifically ask us not to, we will only keep your Personal Information for as long as it is:

A. Necessary for the purposes for which the Personal Information are processed
B. To enable us to comply with our legal obligations, for example for tax purposes

Please refer to our Personal Information retention policy and timelines, which are dependent on the nature of our relationship with you. You can request the policy for your region at privacy@wilsonhcg.com.

 

Data Subject

How long Personal Information is kept

Potential Clients

We will retain Personal Data for the length of time you have consented to, i.e. 2 years from the date of the last contact with us.

Clients

We will retain Personal Information for 7 years from the date that you ceased to be a client or based upon the legal requirements of your region as specified in the retention policy, whichever is longer.

Potential Candidates who are not placed in employment using our services

We will retain Personal Information for 2 years from the date of the last consent or based upon consented duration if otherwise.

Candidates placed in employment using our services

We will retain Personal Information for 7 years from the date that you ceased to be an employee, or the legal requirements of your region as specified in the retention policy, whichever is longer.

Potential Suppliers

We will retain Personal Information for 6 months from the date of the last contact or as provided in the consent form if otherwise.

Suppliers

We will retain Personal Information for 7 years from the date that you ceased to be a supplier or based upon the legal requirements of your region as specified in the retention policy, whichever is longer.

 

 

XIV. CHILDREN’S POLICY 

We do not collect information from children under 13. If we learn we have collected Personal Information of a child under 13, or equivalent minimum age of jurisdiction outside the above circumstances, we will take the proper steps to remove this information. 

If you believe, at any time, that we have collected information from a child under 13, or you are a parent or guardian needs to access, correct, or delete their child’s Personal Information, please reach out to privacy@wilsonhcg.com.

 

CANADA POLICY

The following policies are Canadian jurisdictional privacy practices, which vary from our general privacy practices, and are applicable to only to consumers within Canada.

We strive to comply with PIPEDA (Personal Information Protection and Electronic Documents Act) as well as applicable provincial privacy legislation.

A. PRIVACY PRINCIPLES 

WilsonHCG follows principles when collecting, using, disclosing and protecting your personal information, which include:

1. Accountability: we have an appointed PIPEDA Compliance monitor.


2. Identifying Purposes: under this policy we state the reason for collecting your Personal Information.


3. Consent: we obtain your consent before collecting, using or disclosing your information.


4. Limiting Collection: the Personal Information we collect is only used, disclosed or retained for its original purpose, unless we have your consent, or the information is required to meet legal requirements.


5. Limiting Use, Disclosure, and Retention: we limit the Personal Information we collect to what is necessary for us to conduct business and to serve you to the best of our ability.


6. Accuracy: we strive to ensure that the information we have is accurate and up to date.


7. Safeguards: we safeguard the privacy of your Personal Information through security measures.


8. Openness: we are open with you about our policies and practices related to managing your Personal Information.


9. Individual Access: upon request, we can provide you with access to your Personal Information. You can ask how your information is used, ensure your records are accurate and complete, and update information as necessary.


10. Challenging Compliance: we address your concerns. If you have concerns or questions regarding your privacy, we have steps you can follow to make sure your questions are answered to your satisfaction.


XVI. CHANGES TO THIS POLICY

From time to time we may make changes to this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we use your Personal Information we will post these changes on this page. Please check our Privacy Policy on a regular basis. 

 

XVII. CONTACT US

Your information is ultimately controlled by Wilson Human Capital Group, Inc., a company registered in Delaware, USA with registered number 5370276 whose registered office is at: 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.

We value your opinions and feedback. If you have any questions, comments or concerns regarding our Privacy Policy or data protection, please send them to privacy@wilsonhcg.com or write to us at our corporate office located at 400 North Ashley Dr., Suite 3000, Tampa, Florida 33602.