Business Talent Group Privacy Policy

Last Updated: September 17, 2018

 

This privacy policy (“Policy”) describes Business Talent Group, LLC’s (“BTG”) practices with respect to personal information it collects from users of our services (including clients and talent) and users of the websites available at businesstalentgroup.com (collectively, the “Site”).

 

BTG is committed to respecting the privacy of our clients, consultants, and Site visitors. This Policy applies when you use our services or share information with us. We offer our users choices about the data we collect, use and share as described in this Privacy Policy.

 

The types of personal data we collect, the processing we carry out on it, and the legal basis for that processing depends on the nature of your relationship to BTG. We describe data collection and processing activities that are specific to each type of relationship in the section below, and then describe BTG’s general personal data processing activities.

General Public

 

Personal Data We Collect

 

How We Use Personal Data

 

EU Legal Basis

If you are based in the EU, and do not fall into any of the specific categories of users described below, we will seek your consent to these processing activities. You have certain rights in your data as described here.

Clients

 

Personal Data We Collect

BTG collects data from people working at our client companies to operate effectively and provide clients with the best possible services experience. If you are a representative of a client of BTG, we may gather your contact details, information about your responsibilities and business interests, and engagements with our brand. We collect some of this information directly from you, and some of it by recording how you interact with our products through cookie technology. You can get more information on how we use cookies and how to control their use in the Cookies section below. We also collect information from third parties such as social networking sites.

 

How We Use Personal Data

BTG uses the personal data of personnel of our clients to market and provide our services. We use this data to contact actual or potential users of our services, to assess which services may be of interest to you, and to serve you more relevant marketing communications and ads.

 

EU Legal Basis

If you are a representative of a prospective BTG client and are based in the EU, we will collect and process your personal data based on your consent.

 

If you are a representative of a BTG client that has an active contractual relationship with BTG and are based in the EU, we process your personal data to the extent necessary for BTG’s legitimate interests in marketing and providing services to your company as a vendor. You may object to this processing by notifying us via this form.

 

You have certain rights in your data as described here.

Talent

 

BTG offers a service to independent professionals to match them with projects to our clients that we believe may be a fit and of interest to them, negotiate and execute a contract for such projects, and administer payments, tax and compliance requirements for fulfilling the project.

 

Personal Data We Collect

We will collect your name, address, telephone number, email address, social media profiles which you link to your account, and any other information you voluntarily provide. If you apply to join our talent network, we will collect your name, address, telephone number, email address, social media profiles which you link to your account, and any other information you voluntarily provide. We may also collect, your nationality, work history, educational background, and other demographic information such as gender, and add it to your profile (“Profile”). The information that you provide in your Profile will be visible to others. You may edit the information in your Profile by visiting your Account’s settings page. We also collect information from third parties such as social networking sites.

 

We collect some of this information directly from you, and some of it by recording how you interact with our products through cookie technology. You can get more information on how we use cookies and how to control their use in the Cookies section below. We also collect information from third parties such as social networking sites.

 

How We Use Personal Data

We use this personal data to identify projects we believe may be of interest to you, solicit prospective projects from clients, contact you about those projects, and ultimately execute a contract with you or your legal entity for services on those projects. We may also use this personal data to contact you with information or third party services we think may be of interest.

 

If you are or have been engaged on a project with BTG, we will process personal data to administer the project, remit payment to you, and meet our regulatory and contractual recordkeeping and reporting obligations.

 

EU Legal Basis

If you are based in the EU and register in our talent network, you are holding yourself out as potentially interested in entering a contract with us for a project that is a mutual fit. Accordingly, we will process your personal information to identify projects that may be a fit with your skills at your request prior to entering to such a contract.

 

If you are based in the EU and execute a contract with us to perform a project, we will process your personal data as necessary for the performance of that contract. We may also process your personal data as necessary to comply with our legal obligations to regulatory bodies and the client on the project.

 

If you are based in the EU and register in our talent network, we may seek your consent to contact you with information or third party services we think may be of interest to you.

 

You have certain rights in your data as described here.
 

Personal Data We Collect

 

In addition to the specific activities described above, BTG may collect personal data through the Site and other technologies and through our interactions with you:

 

When you create an account on our Site (an “Account”), we will collect your name, address, telephone number, email address, social media profiles which you link to your account, and any other information you voluntarily provide. You may delete your Account at any time by accessing your Account’s settings page and following the directions therein.

 

You may be able to upload documents and other files to the Site and add it to your Account. We will share such documents and files with other users of the Site in accordance with your elections.

 

The Site may enable you to use a private messenger feature to enable you to send messages to other users of the Site. If you use this feature, we will collect the content of your messages so that we can share them with the intended recipient.

 

BTG may also collect personal information from you when you correspond with us (for example by e-mail or telephone).

 

We may also collect certain information automatically, such as your IP address, referring and exit web pages, date and time stamp information, and web browser information.  We use this information to analyze trends, administer the Site, track users’ movements around the Site and better tailor our Site to users’ needs.
 

How We Use Personal Data

 

BTG uses your information to respond to your requests for information, distribute relevant communications, process requests to participate in events and webinars, evaluate applications to our talent network, to operate, maintain and improve our Site and services, and for other purposes as you may request. We may also use the information you submit in order to contact you and respond to your requests. BTG may use your personally-identifiable information for other uses with your consent.

 

BTG may also create anonymous information from the information we collect, by excluding information (such as your name) that makes the data personally identifiable to you. BTG reserves the right to use anonymous information for any purpose and to disclose anonymous information to third parties in our discretion.

 

BTG applies marketing automation techniques to some of the information we collect to power relevant brand experiences with each user. This technology helps us serve you communications that we think you are more likely to be interested in.
 

Use of Cookies

 

The Site uses technology called “cookies.” A cookie is a piece of information that the Site sends to your computer when you access it. Cookies provide additional functionality to our site, help us analyze its usage, and let us know if you visited related websites. You can inspect, delete, or block any cookies used by the Site by selecting the appropriate settings in your web browser.

 

For more information about how we use cookies on our platforms, visit our Cookie Policy.

Use of Remarketing Pixels

 

BTG has contracted with third parties including Google and Facebook to track our users’ use of the Site and provide remarketing services. BTG uses those services to show you ads about BTG on other websites.

How We Share Your Information

 

BTG may share your information as described below and as described elsewhere in this Policy:

 

Third Party Vendors. BTG may share your personal information with third party vendors engaged by BTG to provide services related to the Site and our services, but only under agreements to maintain the confidentiality and security of the information. See “Subprocessors” below for more information.

 

Compelled Disclosures. BTG may share your personal information, regardless of the choices you make, if BTG believes in good faith that such disclosure is necessary (a) to respond to or comply with a court order or legal requirement; (b) in connection with a legal investigation; (c) to protect or defend the rights or property of BTG or users of the Site; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Policy or our Terms of Use.

 

Corporate Restructuring. BTG may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of BTG’s business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires BTG, its business or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

International Transfer of Personal Data

 

Your personal data may be collected, processed and/or otherwise transferred outside the European Economic Area (EEA) and may be processed not only in the country in which it was collected but also in other countries, including the United States, where data protection and privacy laws and regulations may not offer the same level of protection as in other parts of the world. By providing your personal data to BTG, you consent to such transfer, collection and/or processing in the United States of your personal data, which includes the use of cookies as described in this Policy. BTG’s transfers of EEA personal data to third parties outside the EEA are based either on a finding of adequacy of the third party’s privacy safeguards (generally through the delegated authority of the U.S. Department of Commerce Privacy Shield program) or the use of standard contractual clauses.

Subprocessors

 

BTG uses certain third-party providers to support our operations, who may process your personal data on our behalf. Currently, BTG’s subprocessors are as follows:

 

Entity Name Entity Location
Amazon Web Services United States
Auth0 United States
Box United States
Click2Apply
Data.com United States
DocuSign United States
Google Analytics United States
HireRight United Kingdom and United States
iHance United States
Intercom United States
Jungle Disk United States
LaunchDarkly United States
LinkedIn United States
Marketo United States
Mixpanel United States
Microsoft United States
On24 United States
Papertrail United States
Paychex United States
Quickbooks United States
RingCentral United States
Salesforce United States
Sentry United States
Slack United States
Zoominfo United States
LeapFILE United States
The GDR Group United States
Register.com United States

Links to Third-Party Sites

 

As a convenience to our visitors, the Site currently contains links to a number of websites that we believe may offer useful information. Such links do not constitute an endorsement by BTG, and the policies and procedures described here do not apply to those sites.
 

Data Subject Individual Rights

 

BTG offers choices about the collection, use, and sharing of your data. For personal data we have about you, you have the right to:

  • Change or correct data: You can edit or update some of your personal data through your Account. You can also ask us to correct inaccurate data.
  • Object to or limit use of data: You can object to our collection or processing of your data if we have no legal right to keep using it, and you can ask us to limit our use of it.
  • Delete data: You can ask us to erase the data we have about you unless we have an overriding legal basis for keeping it (for example, if we have remitted payment to you and must keep some of your personal data as tax records.)
  • Access and take your data: You can ask us for a copy of your personal data in machine readable form.

 

You can exercise these rights either by following instructions on the page on which you have provided such information, subscribed, or registered, or by contacting us through this form.

 

If BTG does not resolve your complaint, you may submit your complaint free of charge to the American Arbitration Association’s International Centre for Dispute Resolution Independent Recourse Mechanism through this link.

Retention

 

BTG will retain the data you provide to us as long as we believe we have a reasonable business need for it and a lawful basis for doing so. In some cases, this will be determined by contractual or other legal obligations of BTG.

Children

 

The Site is not designed for or directed at individuals under the age of 18. We do not collect personally identifiable information from any person we actually know is an individual under the age of 18.

Security

 

BTG has implemented generally accepted standards of technical and organizational security to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. Only authorized BTG personnel and third-party vendors are provided access to personally identifiable information. Despite these precautions, however, BTG cannot guarantee that unauthorized persons will not obtain access to your personally-identifiable information.

Privacy Shield

 

Business Talent Group complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Business Talent Group has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

Dispute Resolution – Privacy Shield

 

In compliance with the Privacy Shield Principles, Business Talent Group commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Business Talent Group in one of the following ways:

 

 

Business Talent Group has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.adr.org/Support for more information or to file a complaint.  The services of American Arbitration Association are provided at no cost to you.

 

Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. Business Talent Group is subject to the investigatory and enforcement powers of the Federal Trade Commission.

 

If we share personal data transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party’s processing in violation of the Privacy Shield Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

Changes

 

BTG reserves the right to change this Privacy Policy at any time. You will be alerted to changes by an update of this page.

Contact

 

If you have a question, comment, complaint or request regarding this Privacy Policy or BTG’s data collection and processing you can contact us:

 

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