Your privacy is important. This Privacy Notice (the “Privacy Notice,”) together with its addendums, and any other documents referred to in this Privacy Notice explains how we comply with applicable privacy requirements and sets out minimum standards for how we deal with all personal data that we collect from you, or that you provide to us including via this website and any other websites or applications of Talentuch LLC and its affiliates (collectively, the “Websites”).
If you want to contact Talentuch, please email at firstname.lastname@example.org.
This Privacy Notice sets out the basis on which we collect, store, use and disclose personal data we receive in writing, through our Websites, or through the recruitment services that we provide. It, therefore, applies to personal data that you provide to Talentuch telephonically, electronically (including video calls or emails), and in person.
This information may be updated from time to time and should be read in the context of any additional specific information such as that provided in privacy policies applicable to specific businesses or local areas as displayed on the relevant Website or distributed to you from time to time.
This Privacy Notice also informs you how we obtain and use information gained by us through your use of the Websites, including by using “cookies” and third-party vendors.
Please read the following carefully to understand our views and practices regarding your data, how we will treat it, and your rights. You can contact Talentuch’s Chief Privacy Officer (“CPO”) by emailing email@example.com.
This Privacy Notice applies to Talentuch globally. The first part of the policy is general and applies globally. The second of the Privacy Notice is comprised of country-specific addendums. Please be sure to check the addendums below to see if there is one that applies to your country. In the event of a conflict between the general part of this Privacy Notice and an addendum, the addendum prevails.
II. Who are we?
Talentuch is a professional full-service Human Resources (HR) Outsourcing, Advisory, and Recruiting organization built on best practices and strong operating procedures supporting IT or technology companies who are expanding or maintaining operations throughout Europe.
We specialize in recruitment for the Microsoft channel: MS Dynamics 365, MS Dynamics NAV, Microsoft Dynamics AX, Microsoft Dynamics CRM, Azure, and SharePoint.
Areas of HR expertise: recruitment; training and development; workforce planning and staffing; employee relations; employer branding and corporate identity; mentorship and coaching; policy and procedure development; and advisory services for the hire to the termination process.
III. Who does this Privacy Notice protect?
This Privacy Notice protects individuals throughout the world who access our Websites or receive recruitment services from us. In addition to candidates who are looking for a new or different job or career, this also includes individuals who are employed by an actual, former, or prospective Talentuch client. A Talentuch client is one of (a) a business that Talentuch has contracted with to provide recruitment services or is in the process of doing so, (b) a business that Talentuch may solicit to provide recruitment services or (c) a business to whom Talentuch may provide relevant IT market information.
IV. What information will we collect?
Some of the data that we collect and receive from you is personal data which means that it is information that could personally identify you (“Personal Data” or “PII”). The Personal Data that we may collect from all users of our Websites and users of our recruitment services may include any of the following:
- Contact details e.g. street address, email address, telephone number;
- Work Experience;
- Job Title;
- Professional Certifications;
- Education & Qualifications;
- Career History;
- Salary Range;
- Right to work status \ citizenship;
- Other information relevant to help us provide recruitment services;
- References from past employers; and
- IP address
For Contract Candidates Only (individuals who are employed by, consult with, and/or own an entity recruited by Talentuch to provide contract or temporary technical professional services to a Talentuch client (or a Talentuch client’s client)).
In addition to the Personal Data listed above, Talentuch may collect the following from you:
- Tax details and proof of payment and submission;
- Commercial insurance information;
- Bank and payment details.
While this information may relate to your company or your employer rather than being your Personal Data, we have listed this information for transparency.
If your provision of Personal Data to Talentuch is necessary to enter into a contract with your company or your employer, your failure to provide us with accurate Personal Data may result in Talentuch not being able to offer or render recruitment services to you, your company or your employer.
V. Why do we process your Personal Data?
Generally, we use your Personal Data for our business and activities, and in our efforts to expand and improve our business. Examples include:
All users of the Websites and/or our services
- To provide our recruitment services to you, your employer, or your company;
- To facilitate the recruitment process, including but not limited to:
- Qualifying and submitting candidates;
- For clients, negotiating Talentuch terms of business;
- Arranging interviews and obtaining feedback;
- Negotiating compensation packages; and
- Providing post-placement follow-up.
- To assess data about you against vacancies that we judge may be suitable for you;
- To enable you to submit your CV/resume to Talentuch, apply online (including through the Websites) for jobs, or to subscribe to alerts about jobs we think may be of interest to you;
- To enable us to develop and market other products and services and where you have consented to be contacted for such purposes;
- To improve our customer service and to make our services more valuable to you (including tailoring the Websites when you log on to enrich your personal online experience);
- To send you electronically or by post surveys, reports, Talentuch event details, promotions, offers, networking and client events, and general information about relevant industry sectors which we think might be of interest to you, where you have consented to be contacted for such purposes (and we will provide you with an opportunity to opt-out);
- To identify you, respond to and process your requests for information and provide you with a product or service;
- To amend records to remove personal information;
- To use your information on an anonymized basis to monitor compliance with our equal opportunities policy, other Talentuch policies, and any legal or compliance requirements;
- To use your information on an anonymized basis to create marketing materials such as a salary survey; and
- To carry out our obligations arising from any contracts entered into between you and us, and for other everyday business purposes that involve the use of Personal Data.
Actual or Prospective Candidates
- To help find you or your company a job;
- To contact you (permanent hire candidates), your employer, or your company (contract candidates) about jobs that Talentuch is filling or may fill for Talentuch clients;
- To provide you or your company with information about the job market;
- To communicate with you (permanent hire candidates), your employer, or your company (contract candidates) after you or it has started a job to make sure all is going well or to remedy, or attempt to remedy, any problems;
- To answer any questions you have about a job or the job market;
- To fulfill any aspect of your employer’s or your company’s contract with Talentuch (for contract candidates only);
- To collect any money due, or allegedly due, to Talentuch or any Talentuch client (or Talentuch‘s client’s client);
- To obtain or inquire about any property (including computers and confidential business information) owned, or allegedly owned, by Talentuch or any Talentuch client (or Talentuch’s client’s client);
- To establish, exercise, or defend any legal claims; and
- To assist you (permanent hire candidates), your employer, or your company (contract candidates) if you are dissatisfied or dislike the job, or any aspect of it.
Individuals who work for Talentuch clients (i.e. a “client contact”)
- To fill an open vacancy at your company or employer;
- To contact you about candidates for jobs with whom Talentuch has a relationship;
- To provide you with information about the job market;
- To communicate with you after your company or employer has hired/retained Talentuch candidate to make sure all is going well and to remedy, or attempt to remedy, any problems;
- To negotiate and fulfill any aspect of your company’s or employer’s contract with Talentuch;
- To answer any questions you have about a job or a candidate or your company’s or employer’s contract with Talentuch;
- To resolve any issue with the issuance, payment, collection, or enforcement of Talentuch invoice;
- To collect any property owned by Talentuch or any Talentuch candidate;
- To establish, exercise, or defend any legal claims.
VI. Who do we send your Personal Data to?
All users of the Websites and/or our services
- To third parties where we have retained them to provide services that we or you have requested or that Talentuch clients have requested including references, qualifications, and background reference checking services, and to verify the details you have provided from third party sources.
- To third parties to provide data storage (there are BreezyHR data storage providers used by Talentuch), CV/resume parsing, data cleansing, and marketing (via email & SMS, standard SMS and text rates may apply) services to Talentuch where such third parties have agreed to maintain the confidentiality of, and to protect, your Personal Data per applicable law.
- To third parties, regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, to comply with any applicable law or order of a court of competent jurisdiction, in connection with legal proceedings or other similar cause or circumstance.
- To Talentuch affiliates, whose locations can be found at https://www.talentuch.com so that they may process your Data following this Privacy Notice.
- In the event of a sale, merger, liquidation, receivership, or transfer of all or substantially all of the assets, or a controlling interest in the equity, of Talentuch (or any of its group companies) provided that such counterparty(ies) to any such transaction agrees to adhere to the terms of this Privacy Notice (or a similar document) and applicable law.
Actual or Prospective Candidates
- To Talentuch clients for them to determine if you (permanent hire candidate) or your company or employer (contract candidate) are or may be qualified to fill a vacancy.
Individuals who work for FRG clients (i.e. a client contact)
- To candidates in the course of providing your company or employer with recruiting services and to further the recruitment process.
- To third parties where we have retained them to provide services that you have requested including candidate skill tests and another testing.
VII. What will Talentuch do if my Personal Data is breached?
Talentuch has put in place reasonable technical, administrative, and physical safeguards intended to prevent a breach of your Personal Data. That being said, Talentuch cannot guarantee that your Data will not be breached.
A breach can take many forms, including, without limitation, the loss of your Personal Data or the unauthorized access to, disclosure, modification, copying, and transfer of your Personal Data.
Once Talentuch becomes aware of the breach, Talentuch will take reasonable steps to isolate the breach, stop the breach, determine the root cause, determine the Personal Data breached, fix the root cause, and determine if notice to you and/or the appropriate government agency(ies) is required. Talentuch will comply with all applicable laws in reacting to, and dealing with, a breach of Personal Data.
If you believe, for any reason, that your Personal Data has been breached while in Talentuch’s care, custody or control, please email Talentuch immediately at firstname.lastname@example.org.
VIII. Will my Personal Data be transferred to another country?
Yes, Talentuch may transfer your Personal Data to the categories of third parties described in this Privacy Notice, some of whom are located outside of the country in which you provided your Personal Data to Talentuch or the country of collection.
If so, Talentuch will take reasonable steps to ensure that your Personal Data is protected and treated following this Privacy Notice and local applicable law. The countries where Talentuch may transfer your Personal Data will have varying levels of data security practices and laws, some of which may be less stringent or protective than your country. Talentuch will use all reasonable efforts to require that any of its suppliers and vendors who receive your Personal Data are contractually bound to (a) keep your Personal Data confidential and (b) take, at a minimum, reasonable efforts to maintain the privacy and security of your Personal Data.
Under certain circumstances, Talentuch may share your Data with one or more of its group companies who may be located in a country other than yours or other than the country in which Talentuch collected your Personal Data. In such cases, Talentuch will comply with applicable laws and its Intercompany Data Processing Agreements (“DPAs”). The DPAs are incorporated by reference into this Privacy Notice.
IX. How long will Talentuch store my Personal Data?
We are required by the applicable law to store your Data for 24 months to comply with our legal, regulatory, and contractual obligations. After this time we should get your consent one more time to continue the storage.
In addition, Talentuch will keep your Data for the identified purposes until it reasonably believes that it no longer needs it, that there is no reasonable chance that you, your employer, or your company will do business with Talentuch, and there is no reason to believe that we will need the Personal Data for any special circumstances such as the issuance or defense of legal proceedings, audit, investigation or collections.
X. Sending Talentuch Personal Data over the internet
Your Personal Data is held on servers hosted by us, our internet services providers, or third-party vendors with whom Talentuch has a contract. The transmission of information via the internet is not completely secure. Although we will take the efforts outlined in the Privacy Notice to protect your Personal Data, we cannot guarantee the security of any data transmitted through or to our Websites. Any transmission of data by you to us over the internet is at your own risk.
XI. How we collect and aggregate information about visitors to our Websites
We also collect information about the way job seekers and visitors use the Websites to improve our services, understand our users better, and determine aggregate trends, most popular pages, etc. By using the Websites, you agree that we may share de-identified aggregate data with selected third parties to assist with these purposes. We may also undertake marketing profiling to help us identify candidates, clients, or jobs that may be of interest to you. We may process Personal Data that you submit to us through the Websites under one or more of the permissible bases for processing Personal Data outlined in the Privacy Notice.
XII. Technology and Tools
Like many companies, we use technology and tools that tell us when a computer or device has visited or accessed our content. Those tools include services from search engines and other companies that help us to tailor our products and services to better suit our customers and potential customers. Search engines provide facilities to allow you to indicate your preferences about the use of those tools in connection with computers and other devices controlled or used by you.
XIII. Links to other websites
Please note that clicking on links and banner advertisements and RSS (Rich Site Summary) feeds may result in your transfer to another website, where data privacy practices may be different than described in this Privacy Notice. It is your responsibility to check other website privacy notices and policies to ensure that you are happy for your personal information, including Personal Data, to be used by those third parties’ privacy notices and policies. We accept no responsibility for, and have no control over, third-party websites, links, adverts or RSS feeds or information that is submitted to or collected by third parties.
XIV. Changes to our Privacy Notice
Any changes to this Privacy Notice or any of its addendums will be posted on this Website so you are always aware of what information we collect, how we use it, and under what circumstances if any, we disclose it. We encourage you to check this Website frequently for updates. Your continued use of this Website or any Talentuch services shall constitute your acceptance of the revised Privacy Notice.
Talentuch will interpret and enforce this Privacy Notice by all applicable laws.
This Privacy Notice was last updated on June 29, 2022.
XV. How do we lawfully process your data?
To process your Data lawfully Talentuch must have a legal basis to do so. Talentuch relies on three main legal bases for processing your Personal Data:
1) where we obtain your affirmative consent to use your Data in this way;
2) where we have a legitimate interest in processing your Personal Data, which we have balanced against your rights and freedoms and concluded that our processing is justifiable; or
3) where our handling of your Personal Data is necessary for us to perform the obligations under your company’s or employer’s contract with Talentuch (inapplicable to candidates for permanent hire).
We may rely on one or more legal bases to process your Personal Data.
All users of the Websites and/or our services
Legitimate Interests: Talentuch uses Personal Data that we collect for the following general purposes in the performance of our legitimate interests as a business: to provide the services to our candidates and clients; to enhance their experience, to improve our services, and to contact candidates and clients.
Actual or Prospective Candidates
Consent: If you, whether on your behalf (permanent hire candidate) or on behalf of your company or your employer (contract hire a candidate), would like to receive general marketing and other communications from us, you will have the option to affirmatively check a box consenting to Talentuch processing your Personal Data for this purpose. Talentuch may also ask you via email or telephone for your affirmative consent to receive marketing and other communications from us.
Legitimate interest: Talentuch has a legitimate interest in processing your Data to fill a job, to provide you (permanent hire candidate) or your company or your employer (contract hire a candidate) with other products and services to help you in your career and to market its products and services to you to grow our business, to demonstrate our knowledge of the marketplace and relevant technologies and to enhance the standing and recognition of our brands. Talentuch also has a legitimate interest to process your Data if you apply for, or seek further information about, a job posted on one of the Websites or a job advertised by Talentuch on a job board, social media site, or another forum.
Necessary for the performance of a contract: Talentuch can process your Data in the performance of its contract with your company or employer.
Individuals who work for Talentuch clients (i.e. a client contact)
Consent: If you would like to receive general marketing and other communications from us, you will have the option to affirmatively check a box consenting to Talentuch processing your Personal Data for this purpose. Talentuch may also ask you via email or telephone for your affirmative consent to receive marketing and other communications from us.
Legitimate Interest: Talentuch has a legitimate interest in processing your Data to fill a vacancy at your company or employer, provide you with other products and services relevant to your company or employer, and market its products and services to you to grow our business, to demonstrate our knowledge of the marketplace and relevant technologies and to enhance the standing and recognition of our brands. Talentuch also has a legitimate interest to process your Data if you seek or obtain further information about Talentuch or Talentuch candidate.
Necessary for the performance of a contract: Talentuch can process your Data in the performance of its contract with your company or employer.
Concerning actual or prospective client contacts and candidates, if Talentuch obtains your Personal Data from someone other than you, Talentuch shall inform you of the identity and contact details of the person or entity from whom Talentuch obtained your Personal Data, whether Talentuch obtained your Personal Data from publicly available sources, the categories of Personal Data that Talentuch obtained and, if Talentuch is processing your Personal Data based on its legitimate interest (see Section III below), the nature of Talentuch’s legitimate interest. Talentuch shall provide you with the information listed in this paragraph by the earlier of (1) one month after Talentuch obtains your Personal Data or (2) if Talentuch uses your Personal Data to communicate with you, the first time that Talentuch communicates with you.
Talentuch shall not provide you with the information described in the paragraph immediately above if you already possess this information, providing you with such information is against applicable law, is subject to an obligation of professional secrecy, proves impossible, would involve a disproportionate effort or would render impossible or seriously impair the achievement of the objectives of the processing, in which case, Talentuch shall take appropriate measures to protect your rights, freedoms and legitimate interests.
XVI. Your Special Rights under Data Protection Laws
Do I have a right to be erased (forgotten)?
Yes. You have the right to request that Talentuch deletes or removes your Personal Data where there is no compelling reason for us to continue to process it. You can exercise this right, free of charge, by sending an email to Talentuch at email@example.com.
Please note that your right to erasure is not absolute. Talentuch will remove your Data when:
(1) the Personal Data is no longer necessary about the purpose for which Talentuch originally collected and/or processed it;
(2) if Talentuch is processing your Data based on your consent and you withdraw consent;
(3) you object to the processing of your data and there is no overriding legitimate interest for us to continue to process it;
(4) the Personal Data was unlawfully processed; and
(5) the Personal Data must be erased to comply with a legal obligation.
Talentuch can refuse to comply with an erasure request in the following limited circumstances:
(a) to exercise Talentuch’s right to freedom of expression and information;
(b) to comply with a legal obligation or for the performance of a public interest task;
© for archiving purposes in the public interest, scientific research, historical research, or statistical purposes; or
(d) for the establishment, exercise, or defense of legal claims.
If we remove your Personal Data per your erasure request, then we will confirm this with you.
If we have disclosed any of your Personal Data to a third party and you submit an erasure request to us, then we will inform (1) you about the recipients and (2) any such third parties of your erasure request unless doing so is impossible or involves disproportionate efforts.
We will respond to your erasure request without undue delay. Please note that, for your and Talentuch’s protection, we cannot respond to an erasure request until we have verified the identity of the person making the request. This verification process may extend the response timeframes outlined in this paragraph.
Do I have a right of access to a copy of my Personal Data?
Yes. You have the right to:
- obtain confirmation that your Data is being processed;
- a copy of your Personal Data being processed;
- the purposes of the processing;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom Talentuch has disclosed your Personal Data; and
- the criteria Talentuch uses to determine how long it will store your Personal Data.
You can exercise this right by sending an email to Talentuch at firstname.lastname@example.org.
This right is in place to ensure that you are aware of and can verify the lawfulness of the processing. In most cases, we will provide you with a copy of your Personal Data free of charge. However, we may charge you a reasonable fee if your request is manifestly unfounded, excessive, or repetitive. Concerning unfounded, excessive, or repetitive requests, in rare cases, Talentuch may refuse to respond to your request but will explain the reason(s) for its refusal to you without undue delay and within one month of its receipt of your request. If Talentuch so refuses, you have the right to file a complaint and to seek a judicial remedy.
If you submit your access request to Talentuch electronically, Talentuch will provide you with its response, and a copy of your Personal Data (if applicable) via email or another commonly used electronic form.
If Talentuch did not collect your Data from you, Talentuch will inform you about the source from which it obtained your Personal Data. Your right of access does not adversely affect your right of erasure (forgotten) and right of rectification, both of which are described in this Privacy Notice.
Generally, Talentuch will provide you with a copy of your Personal Data without undue delay and within one month of its receipt of your request, provided that Talentuch may extend this period for up to two additional months if your request is complex or numerous. If Talentuch exercises this extension of time, Talentuch will inform you of its decision to exercise the extension within one month of its receipt of your request and will explain the reason(s) for the extension. If your request is large or complex, Talentuch may ask you to specify the particular information or category of information you seek.
Please note that, for your and Talentuch’s protection, Talentuch cannot respond to an access request until it verifies the identity of the person requesting your Personal Data. This verification process may extend the response timeframes outlined in the paragraph above.
Do I have a right to object to the processing of my Personal Data, including the processing of my Personal Data by Talentuch for direct marketing?
Yes, you have a right to object to the processing of your Personal Data where:
- Talentuch’s processing is based on its legitimate interest; or
- where Talentuch is using your Personal Data to directly market to you.
You can exercise this right, free of charge, by sending an email to Talentuch at email@example.com.
If Talentuch receives an objection request from you for reasons unrelated to direct marketing, Talentuch will stop processing your Personal Data unless we can show compelling legitimate ground(s) for the processing which overrides your interests, rights, and freedoms or for the establishment, exercise or defense of any legal claims.
If Talentuch receives an objection request from you for reasons related to direct marketing, we will stop processing your Personal Data.
If you receive direct marketing communication from Talentuch and you do not wish to receive future direct marketing communications from Talentuch, you may request to unsubscribe from future marketing communications by sending Talentuchan an email at firstname.lastname@example.org.
Do I have a right to restrict the processing of my Personal Data?
Yes, you have a right to restrict, the processing of your Personal Data. You can exercise this right, free of charge, by sending an email to Talentuch at email@example.com. When you exercise this right, Talentuch may continue to store your Data but cannot further process it. Talentuch will cease processing your Data in the following circumstances:
(1) when you file a rectification request with Talentuch (see the “Do I have a right to have any inaccurate or incomplete Personal Data rectified?” section below) by this Privacy Notice and applicable law. The restriction shall remain in place until Talentuch has verified the accuracy of the Personal Data that is the subject of your rectification request;
(2) where Talentuch is processing your Personal Data based on its legitimate interest and you file a notice with Talentuch objecting to the processing of your Personal Data (see the “Do I have a right to object to the processing of my Personal Data?” section above) by this Privacy Notice and applicable law, Talentuch will cease processing your Personal Data until Talentuch has decided as to whether its legitimate grounds for continued processing override your reasons for objecting to the processing;
(3) when the processing is unlawful and you do not seek or want erasure and you file a restriction request with Talentuch by this Privacy Notice and applicable law instead; and
(4) if Talentuch no longer needs the Personal Data and you require the data to establish, exercise, or defend a legal claim.
While the processing of your Personal Data is restricted, Talentuch may continue to process such data by storing it, processing it with your consent, or processing it for the establishment, exercise, or defense of legal claims.
Talentuch will inform you if it decides to lift a restriction on processing.
If Talentuch has disclosed any of your Personal Data to a third party and you submit a request to restrict processing, Talentuch will inform (1) you about the recipients if you so request and (2) any such third parties of your restriction request unless doing so is impossible or involves disproportionate efforts.
Talentuch will act on your restriction request following this Privacy Notice without undue delay. Please note that, for your and Talentuch’s protection, Talentuch cannot act on a restriction request until it verifies the identity of the person making the request. This verification process may extend the timeframe in which Talentuch acts on your restriction request.
Do I have a right to Personal Data portability?
Yes. You can exercise this right, free of charge, by sending an email to Talentuch at firstname.lastname@example.org. This right exists to allow you to obtain and use your Data for your purposes across different services. Under this right, you can move, copy or transfer your Data from Talentuch to another data controller.
This right applies where Talentuch is processing your Personal Data with your consent or for the performance of a contract. It also applies if we process your Personal Data by automated means. If your portability request concerns someone other than you, Talentuch will have to consider whether providing or porting the Personal Data would prejudice the other person’s or people’s rights.
Generally, Talentuch will respond to your portability request without undue delay and within one month of its receipt of your request, provided that Talentuch may extend this period for up to two additional months if your request is complex or numerous. If Talentuch exercises this extension of time, Talentuch will inform you of its decision to exercise the extension within one month of its receipt of your request and will explain the reason(s) for the extension. Where technically feasible, you may request that Talentuch transmit your Data to another data controller.
Do I have a right to object to the decision being taken by automated means?
If Talentuch uses automated (i.e. non-human) methods to process your Personal Data to make decisions that could potentially have a damaging legal or similarly significant effect on you (each, an “Automated Decision”), you have the right not to be subject to the Automated Decision. This right is inapplicable to any Automated Decision made by Talentuch that is necessary for entering into or the performance of a contract between you and Talentuch, is authorized by law, or is based on your explicit consent.
If Talentuch makes any Automated Decisions to which this right applies, Talentuch will ensure that you can obtain human intervention, express your point of view and obtain an explanation of the decision and challenge it.
If Talentuch engages in “profiling” by automated means, Talentuch will ensure that appropriate safeguards are in place including (1) ensuring that the processing is fair and transparent by providing you with meaningful information about the logic involved and the significance and consequences of the outcome of the decision, (2) using appropriate mathematical or statistical procedures for the profiling, (3) implementing appropriate technical and organizational measures to enable inaccuracies to be corrected and minimize the risk of errors and (4) securing the Personal Data in a way that is proportionate to the risk to your interests and rights and prevents discriminatory effects.
Do I have a right to have any inaccurate or incomplete Personal Data rectified?
Yes. You can exercise this right, free of charge, by sending an email to Talentuch at email@example.com.
Generally, Talentuch will respond to your rectification request within one month of its receipt of your request, provided that Talentuch may extend this period for up to two additional months if your request is complex. In rare cases, Talentuch may refuse to respond to your request but will explain the reason(s) for its refusal to you within one month of its receipt of your request. If Talentuch so refuses, you have the right to file a complaint and to seek a judicial remedy.
If Talentuch has disclosed any of your Personal Data to a third party and you submit a rectification request to Talentuch that Talentuch is going to honor, Talentuch will inform (1) you about the recipients and (2) any such third parties of your rectification request as well as any corrected Personal Data, unless doing so is impossible or involves disproportionate efforts.
We will use reasonable endeavors to ensure that your Personal Data is maintained and up to date.
IV. What are my rights if the Security of my Personal Data is breached?
A breach of Personal Data (a “Breach”) means a breach of security leading to the destruction, loss, alteration, or unauthorized disclosure of, or access to, your Personal Data for which we are responsible under applicable law.
If the Breach is likely to have a significant detrimental effect on your rights and freedoms (such as resulting in discrimination, damage to reputation, or financial loss), Talentuch will notify the ICO without undue delay, and if feasible, within 72 hours of Talentuch’s becoming aware of the Breach. Talentuch will assess the determination of “significant detrimental effect” on a case-by-case basis.
If the breach is likely to result in a “high risk” to your rights and freedoms, Talentuch will notify you without undue delay. To be clear, the threshold requiring Talentuch to notify you of a Breach is higher than the threshold requiring Talentuch to notify the ICO of a Breach so Talentuch may notify the ICO of a Breach but not you. Talentuch will assess the determination of “high risk” on a case-by-case basis.
Any Breach notice issued by Talentuch will contain, where possible, (1) the categories and the approximate number of individuals and Personal Data records affected by the Breach, (2) the name and contact details of Talentuch contact representative, (3) a description of the likely consequences of the Breach, (4) a description of the measures that Talentuch has taken, and may take, to stop the Breach and, where appropriate, to mitigate the adverse effects of the Breach and (5) recommendations on actions you can take to protect yourself in light of the Breach.
V. Will my Personal Data be transferred outside the EEA/UK?
Talentuch may transfer your Data to third parties described in this Privacy Notice who are located outside of the EEA/UK. If so, Talentuch will take reasonable steps to ensure that your Personal Data is protected and treated by this Privacy Notice and local applicable law. Some of the countries outside the EEA/UK where your Personal Data may be transferred will be on the EU Commission’s list of countries that it has deemed to have adequate security controls in place.
Under certain circumstances, Talentuch may share your data with one or more of its group companies who may be located in another country, including outside of the EEA/UK In such cases, Talentuch will comply with its DPAs. The DPAs are incorporated by reference into this Addendum.
VI. How long will Talentuch store my Personal Data?
We are required by law to store your Data for as long as is necessary to comply with our legal, regulatory, and contractual obligations.
Concerning GDPR (and similar laws), we will store and process your Personal Data that we obtain via (i) your consent until the earlier of (a) the purpose for which we obtained such information has been fully accomplished or (b) you inform us that you have withdrawn your consent, (ii) our legitimate interest until the earlier of (a) the purpose for which we obtained such information has been fully accomplished or (b) Talentuch concludes that your rights and freedoms outweigh our right to process your Personal Data and (iii) our necessity for the performance of a contract, until the termination or expiration of the contract including the termination or expiration of Talentuch’s and your employer’s or company’s duties or obligations that survive any such termination or expiration.
Furthermore, we will store your Data in special circumstances related to the issuance or defense of legal proceedings, outstanding invoices, or in connection with any investigation by or of a government authority.
What Protections do I have if Talentuch transfers my Personal Data to the U.S.?
In short, you have the protections of the Privacy Shield Framework. Talentuch Limited is the primary affiliate and operating company in the United State (“Talentuch US”). Talentuch US complies with the requirements of the EU-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce concerning Personal Data that is transferred from the EEA and Switzerland to the United States.
Talentuch US’s Privacy Shield certifications cover Personal Data regarding:
(1) current, former, and prospective employees in connection with the employment relationship which is covered by a separate, employee only, Privacy Notice that has been made available to Talentuch employees;
(2) Personal Data regarding client contacts and candidates (temp and perm), such as the sale and delivery of recruitment services and the administration of the client and candidate relationship; and
(3) Personal Data regarding third parties (such as service providers and independent contractors) and their personnel and employees, in connection with recruitment services and the provision and performance of technical professional services to clients and, where applicable, their end customers and the management and administration of the business relationships with such third parties.
Our certifications do not cover any disclosure of an individual’s Personal Data to a third party who processes the Personal Data for its purposes when the disclosure is made at the request of the individual.
Talentuch US discloses Personal Data to third-party service providers in connection with the operation of its business, including our provision of services to clients and candidates. Talentuch US ascertains that these third-party service providers provide at least the same level of privacy protection as is required by the Privacy Shield Principles. Talentuch US may be liable if both (a) third parties fail to meet these obligations and (b) Talentuch US is responsible for the event giving rise to the damage.
Talentuch US is subject to the investigatory and enforcement powers of the United States Federal Trade Commission. Talentuch US may be required to disclose Personal Data to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.
Any questions or complaints concerning Talentuch US’s Privacy Shield compliance or requests to access, correct, amend, delete, or limit the use or disclosure of Personal Data (opt-out) may be directed to firstname.lastname@example.org. If FRG US has not been able to satisfactorily resolve the issue, then you may raise it with (1) your data protection authority (see the paragraph immediately below) or (2) the International Centre for Dispute Resolution/American Arbitration Association (“ICDR/AAA“) for non-HR related recourse, which can be contacted at http://go.adr.org/privacyshield.html. Under certain conditions, individuals may have the possibility to engage in binding arbitration through the Privacy Shield Panel. To find out more about individual binding arbitration, please visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
EU/EEA residents should your complaint relate to Talentuch US’s failure to comply with its Privacy Shield commitments and remain unresolved and you reside in the EU/EEA, then you should contact the EU Data Protection Authorities (the “DPAs”) who act as an independent recourse mechanism to settle all such disputes. Such complaints can be directed either to the EU DPAs panel secretariat or individual EU DPAs.
The contact information for the submission of the standard complaint form is Commission Européenne, Directorate General Justice, Directorate C (Fundamental Rights and Union Citizenship) of the European Commission, Data Protection Panel, B-1049 Brussels, Belgium, Telephone: (32-2) 299 11 11, Fax: (32-2) 298.80.94, email: email@example.com.
The contact information for individual EU DPAs can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.html
UNITED STATES OF AMERICA ADDENDUM
If you would like a copy of Talentuch’s US comprehensive information security program, please email Talentuch’s CPO at firstname.lastname@example.org.
If Talentuch receives a “Do Not Track” signal or request from a web browser, Talentuch will not honor such request or signal. Talentuch has taken this position in part to provide you with a personalized and efficient experience on the Websites.
As discussed in this Privacy Notice, there are third parties who conduct tracking on the Websites.
For information on Talentuch’s compliance with the EU-U.S. Privacy Shield Frameworks, see the section entitled “What Protections do I have if Talentuch transfers my Personal Data to the U.S.?” of the European Economic Area/United Kingdom Addendum above.
You may wish to contact us to request access to your Personal Information, to seek to correct it or to make a privacy complaint. Our contact details are set out below:
Address: 7127 S 86th Ave, Unit 2
Justice, IL, USA, 60458
We will respond to your request for access to Personal Information we hold about you as soon as we reasonably can, including if we are unable to provide you with access (such as when we no longer hold the information).
We do not impose any charge for an access request, but we may charge you a reasonable fee for our costs associated with providing you with access and retrieval costs.
For complaints about privacy, we will establish in consultation with you a reasonable process, including timeframes, for seeking to resolve your complaint.