Privacy Notice for California Residents

Privacy Notice for California Residents

Last Revised: August 4, 2020

This Privacy Notice for Residents of California ("CA Privacy Notice") supplements the information contained in our privacy policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this CA Privacy Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. With respect to users who are residents of California, this notice is incorporated and made a part of our Privacy Policy, and its terms shall control with respect to residents of California in the event of any inconsistency between the Privacy Policy and this CA Privacy Notice.

I. Information We Collect

Global Career Networks, Inc. and all of its associated websites (“GCN”, "Company", “we”, “us”, or “our”) provide job search related content and resources including career coaching and mentoring. GCN and its associated websites including https://www.ResumeScoring.com, https://www.ResumeCertified.orghttps://www.ResumeSending.com, https://www.JobAlerts.co, https://www.LifeGuru.me, https://www.DirectHRContacts.com, https://www.JobGrowing.com, https://www.JobAssist.io, https://www.JobSeekerNewsHubb.com, and https://www.globalcareernetworks.io including any other media form, media channel, mobile websites, or mobile application related or connected thereto (collectively, the “websites” or "Sites") may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (I.e. "personal information"). Our websites collect, or have collected during the last twelve (12) months, the following categories of personal information:

  1. Identifiers
    1. A real name, Internet Protocol address, email address, or other similar identifiers
  2. Only the following personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).
    1. A name, address, telephone number, education, employment, employment history, credit card number, or debit card number.
  3. Only the following protected classification characteristics under California or federal law.
    1. Gender
  4. Only the following Commercial information.
    1. Records of products or services purchased.
  5. NO Biometric information.
  6. Internet or other similar network activity.
    1. Browsing history, search history, information on a consumer's interaction with our websites.
  7. Geolocation data.
    1. Physical location.
  8. NO Sensory data.
  9. Professional or employment-related information.
    1. Current or past job history.
  10. NO Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  11. Inferences drawn from other personal information.
    1. Profile reflecting a person's preferences, characteristics, abilities, and aptitudes.

 

For the purposes of this CA Privacy Notice, personal information does not include:

      Publicly available information from government records.

      De-identified or aggregated consumer information.

We obtain the categories of personal information listed above from the following categories of sources:

      Directly from you. For example, from forms you complete or profiles you update on our websites or from the resumes, cover letters, or social media profiles you upload on our websites.

      Indirectly from you. For example, from observing your actions on our websites.

      Indirectly from Partners. For example, from forms or registrations on our partner or affiliate websites or the resumes you provide to such partners or affiliates.

The ways that we collect the foregoing information are set forth in greater detail in our Privacy Policy[1]  under the heading "How we collect personal information".

II. Use of Personal Information

We may use the categories of personal information we collect as set forth above for the following business purposes:

A. Identifiers.

      To fulfil or meet the reason you provided the information. For example, if you share your name and contact information by uploading a resume, cover letter, or social media profile, or when activating your account or purchasing a service on any of our sites, we retain that information on our system and we may provide it to third party service providers (as defined in our Privacy Policy). We may also save your information to facilitate future recommendations on products and/or career opportunities which you may be interested in or inform our partners of the same.

      To provide our services to customers and other users, including candidates who submit Resumes and related information, and customers of GCN and its associated websites. This includes providing resumes and cover letters including personal information, to those who search or otherwise request resumes through our services, as described under the heading "Sharing Personal Information" below.

      To enforce our rights and carry out our obligations under agreements with our customers, including providing Resumes, including personal information to users who search or otherwise request Resumes through our services, as described further under the heading "Sharing Personal Information" below.

      To notify you about aspects of our products and services and changes to our websites or policies.

      To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or to otherwise comply with legal obligations applicable to us.

These uses and purposes are described in greater detail in our Privacy Policy, under the headings "Collection of your information" and "Use of your information". We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

III. Sharing Personal Information

We may disclose your personal information to a third-party for a business purpose or sell your personal information as set forth in this, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights).

GCN and its associated websites may share your data, including personally identifying information, with employers, HR managers, and recruiters seeking candidates matching your profile or our partners as described in this notice and in the Privacy Policy. This sharing may either happen directly or indirectly through one of our portfolio of integrated industry partners. In the latter scenario the partner shall provide the ability to search GCN and its associated websites’ database through their own platform and accordingly your data may be stored and managed by that partner to facilitate their search and matching functions.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except fulfilling the contract.

A. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, GCN and its associated websites may have disclosed personal information in the following categories for the business purposes identified above:

  1. Identifiers
    1. A real name, Internet Protocol address, email address, address including zip code, or other similar identifiers
  2. Only the following personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).
    1. A name, address, telephone number, education, employment, employment history, credit card number, or debit card number.
  3. Protected classification characteristics under California or federal law.
    1. Although not required by GCN and its associated websites, any information (such as gender) provided by candidates in conjunction with other information subject to disclosure as described in this notice that falls within this category.
  4. Commercial information.
    1. Interest in additional products or services including resume reviews, job alerts, and jobseeker newsletters  based on products or services already purchased.
  5. NO Biometric information.
  6. Internet or other similar network activity.
    1. Internet Protocol address, interactions with our websites or adverts.
  7. Geolocation data.
    1. Approximate physical location (derived from an Internet Protocol address) – or candidate provided ZIP code.
  8. NO Sensory data.
  9. Professional or employment-related information.
    1. Education and employment history.
  10. NO Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  11. Inferences drawn from other personal information.
    1. Job Matching activity to infer which alerts may be required.
    2. Interest in related products or services.

B. Sales of Personal Information

In the preceding twelve (12) months, GCN and its associated websites may have disclosed the following categories (as further described in the chart above) of personal information in connection with a transaction potentially constituting a "sale" of personal information as defined under the CCPA:

  1. Identifiers
    1. Real name, postal address including Zip code, unique personal identifier, online identifier, session identifiers, Internet Protocol address, email address.
  2. Only the following personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).
    1. Your name, address, telephone number, education and employment history.
  3. Protected classification characteristics under California or federal law.
    1. Although not requested by GCN and its associated websites, any information provided by candidates in conjunction with other information subject to disclosure as described in this notice that falls within this category.
  4. Commercial information.
    1. Interest in additional products or services including resume reviews, job alerts, and jobseeker newsletters based on products or services already purchased.
  5. NO Biometric information.
  6. Internet or other similar network activity.
    1. Internet Protocol address, interactions with our websites or adverts.
  7. Geolocation data.
    1. Approximate physical location (derived from an Internet Protocol address) or candidate provided ZIP code.
  8. NO Sensory data.
  9. Professional or employment-related information.
    1. Education and employment history.
  10. NO Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
  11. Inferences drawn from other personal information.
    1. Job Matching activity to infer which alerts may be required.
    2. Interest in related products or services.

Where your information has been received by us from a third-party, before selling this information, we will either (1) contact the third-party that provided the personal information to confirm that the third-party provided a valid notice at collection to you informing you of the uses that would be applicable to your information and to obtain signed attestations from the third-party describing how the third-party gave the notice at point of collection and including an example of the notice, or (2) contact you directly to inform you about our potential sale of personal information and to provide you with a notice or right to opt-out of such sales. Attestations shall be retained by us for at least two years and made available to you upon request.

IV. Your Rights and Choices

The CCPA provides consumers (residents of California) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

      The categories of personal information we have collected about you.

      The categories of sources for the personal information we collected about you.

      Our business or commercial purpose for collecting or selling that personal information.

      The categories of third parties with whom we share that personal information.

      The specific pieces of personal information we collected about you (also called a data portability request).

      If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

      sales, identifying the personal information categories that each category of recipient purchased; and

      disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

To make a request to have your personal information disclosed you can make a request for the information by:

      Send us a message via our contact email.

      Writing us at our mailing address: 1858 Pleasantville Road, Suite 110, Briarcliff Manor, NY 10510

B. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

      Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

      Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

      Debug products to identify and repair errors that impair existing intended functionality.

      Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

      Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.)

      Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

      Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

      Comply with a legal obligation.

      Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Exercising Access, Data Portability, and Deletion Rights

 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us as follows:

      Send us a message via our contact email.

      Writing us at our mailing address: 1858 Pleasantville Road, Suite 110, Briarcliff Manor, NY 10510

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you wish to register a person to operate on your behalf, you must inform us by contacting our customer services team and validating your identity so that the identity of the authorized person may be recorded.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

      Provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

      Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it.

      We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

D. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within forty-five (45) days of receipt of your request. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

E. Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales, including but not limited to those between 13 and 16 years of age, may opt-out of future sales at any time as described herein.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by:

      Send us a message via our contact email.

      Writing us at our mailing address: 1858 Pleasantville Road, Suite 110, Briarcliff Manor, NY 10510

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to re-authorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting our websites and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

F. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

      Deny you goods or services.

      Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

      Provide you a different level or quality of goods or services.

      Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

G. California Shine the Light Law

California's "Shine the Light" law (Civil Code Section 1798.83) permits users of our Websites that are residents of California to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our websites or write us at our address listed on our webpage.

V. Changes to this Notice

We reserve the right to amend this CA Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our websites and update this notice's effective date. If as a business we intend to use your personal information for a purpose that was not previously disclosed in the privacy policy or in the notice at collection, we shall directly notify you of this new use and obtain explicit consent from the consumer to use it for this new purpose.

VI. Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described in the CA Privacy Notice and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:

      Send us a message via our contact email.

      Writing us at our mailing address: 1858 Pleasantville Road, Suite 110, Briarcliff Manor, NY 10510