Privacy Policy
Talent Plus Global Privacy Notice
As of September 6, 2023
- Interact with us on our websites or through marketing efforts.
- Use any of our product and services, including TalentBank, TalentMine, and associated consulting services (Services).
Navigating The Notice:
When & How We Collect Data
- Browsing the pages of our website
- Registering and applying for a job with us through our Career Center
- Contacting us through our Contact Us form
We collect personal data when you participate in our services through our contracts with corporate clients, when you:
- Engage with us on TalentBank and through our virtual and in-person services
- Participate in TalentBank Communities
- Interact with us for customer support
You provide Talent Plus with your personal data when:
- You participate through your company in Talent Plus services delivered through TalentBank
- You complete our Contact Us or other webforms
- You contact us through email or by phone
- You participate in TalentBank Communities
- You register and apply for a job with us through our Career Center
- You engage with us by participating in marketing events and activities
- You interact with us for client support
Types Of Data We Collect
Website – when you visit our website, unless you disable the functionality through our Cookie Preference Center, we collect information about your interactions with our website, including data that identifies you such as your IP address, login information, browser type and version, time zone setting, browser plug-in types, URL clickstreams (the path you take through our site), page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions. Some of this information is necessary to deliver services through the website, and for more information about cookies used on our website, please see our Cookie Notice.
When your register and apply for a job with us through our Career Center, Talent Plus will collect your contact information including an email and password to register, and the professional and education experience provided in your resume. Please see the Talent Plus Job Applicant Notice for more information. When you complete one of our webforms to contact us, we collect your name, company email, company phone, and company name.
Marketing – when we engage with you for sales and marketing activities, we collect your business contact information such as your name, organization, and work email, phone, and mailing address.
Services & TalentBank – under your company’s contract with Talent Plus, we may collect the following types of personal data when you participate in Talent Plus services and TalentBank. Our clients are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent – please contact your organization, the data controller, for more information about personal data processing activities and to exercise your rights.
- Contact details including your name and home and work contact information including: addresses, telephone numbers, email addresses.
- Educational, professional, and personal experience information including your role, industry, skills, job experiences, unique employee ids, current employer information, goals, action items, and reasons for considering new employment opportunities.
- Data that identifies you through technical identifiers such as your IP address, login information, browser type and version, time zone setting, browser plug-in types.
Sensitive Personal Data – as described in our Job Applicant Notice, Talent Plus may collect sensitive data during the job application process and conducts background checks as a condition of employment. We do not use this personal data for any other purpose. Sensitive personal data can include racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offenses or alleged offenses.
The websites, products and all services contracted through our corporate clients, including TalentBank, are not intended for or targeted at children under 16 and Talent Plus does not knowingly collect data from children under 13. If you believe that we have collected personal data about a child, please contact us using the methods posted in Section 10 Contact Us, so that we may delete the information.
How & Why We Use Data
Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. We will never sell your personal data to any third party. Here are the reasons for which we process your data:
- Delivering Services: Performing our contractual obligations to our corporate clients to provide Talent Plus services to you. Legal basis: Contract
- Customer Support: Responding to questions and solving issues via phone or email. Legal basis: Contract
- Marketing Purposes: Sending you emails and messages about new features, products and Services, and content; and to invite you to participate in marketing events and activities. Legal basis: Consent
- Research: Occasionally we will create statistical, aggregated data relating to our users and our services for analytical purposes. Aggregated data includes data derived from Personal Information and obtained by Talent Plus from other sources in aggregated, anonymous form and does not identify any individual (such data is referred to as “Aggregate Information”). Subject to applicable laws and regulations, we use Aggregate Information to understand our client needs and to develop, improve and/or market our Services. Legal basis: Legitimate Interests
- Running and Improving our Site and Services: Managing your requests, login, and authentication, remembering your settings, hosting, and back-end infrastructure, testing features, managing landing pages, debugging, and identifying fraud. Legal basis: Contract, Legitimate Interests
What does each legal basis mean?
Consent: You have given clear consent for you to process your personal data for a specific purpose. You can manage and choose to withdraw your consent at any time using the email unsubscribe link available in all marketing communications, by emailing the us at privacy@talentplus.com, or by contacting us through the phone or mailing address in the Contact Us section of this notice.
Contract: Processing your data is necessary for performing services under a contract Talent Plus has entered with our corporate clients, or because we have asked you to take specific steps before entering into that contract.
Legitimate Interests: Processing your data is in our legitimate interest, provided those interests are not outweighed by your rights and interests. These legitimate interests are:
- Gaining insights from your behavior on our website and within our services sites
- Delivering, developing, and improving Talent Plus services
- Enabling us to enhance, customize or modify our services and communications
- Determining whether marketing campaigns are effective
- Enhancing data security
In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests.
Your Privacy Choices
You have certain rights over your data. If you are part of a Talent Plus corporate clients, please contact your company, the data controller, directly. Please also see our CCPA Rights Notice and EU & UK GDPR Rights Notice for additional information on your rights and how to exercise them.
You may unsubscribe from our marketing communications through one of the following methods:
- By clicking on the "unsubscribe" link located on the bottom of our email
- By contacting us through one of the methods posted in Section 10 Contact Us
Please Note: clients cannot opt out of receiving transactional email related to their account with us or the use of our services, including TalentBank.
How We Share Your Data
Your data is shared only when strictly necessary, as required and managed by our contracts, and according to the safeguards and good practices detailed in this Privacy Notice. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt-out of having your personal information shared.
We may share your personal information with authorized service providers that perform services on our behalf, which may include marketing, billing, data analysis, background checks, technical support, and customer service. Unless we tell you otherwise, our service providers may only use data we share with them in in accordance with our instructions.
We do not share, sell, rent, or trade any of your personal information with third parties for their promotional purposes.
We may disclose your information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; in connection with a substantial corporate transaction, such as the possible sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or as otherwise required by law.
How We Secure the Data We Collect
The security of your personal information is important to us. We have physical, electronic, and managerial procedures to safeguard and secure the information we collect and that is submitted to us, both during transmission and after it is received.
Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. And please remember:
- You are responsible of your username and password: keep them secret and safe!
- If you have any questions about the security of your personal information, you can contact us at privacy@talentplus.com.
- If you believe your privacy has been breached, please contact us immediately: privacy@talentplus.com.
Where We Store Data
The personal data we collect is processed at our offices in the United States and in any data processing facilities operated by authorized service providers. By submitting your personal data, you agree to this transfer, storing or processing by us. Where your information is transferred, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, security, and data protections, and that it is treated securely and in accordance with this Privacy Notice.
We may transfer your personal information for the following reason, including but not limited to:
- In order to store it.
- In order to enable us to provide goods or services to you and fulfill our contract with you. This includes order fulfillment, processing of payment details, and the provision of services.
- Where we are legally required to do so.
- In order to facilitate the operation of our business, where it is in our legitimate interests, and we have concluded these are not overridden by your rights.
How Long We Keep the Data
Talent Plus will retain your information for as long as necessary for the purposes set out in this Notice; as required to fulfill the terms of our contracts; as needed to provide Services to you; as needed to fulfill research requirements; or to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements.
Privacy Notice Changes
We update this Privacy Notice from time to time and we encourage you to review it periodically.
Contact Us
If you have any questions about this Privacy Notice, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights under the GDPR, please contact us at:
Talent Plus
Attn: Privacy Team
One Talent Plus Way
Lincoln, Nebraska, U.S.A. 68506-5987
EU-U.S. Data Privacy Framework Principles
EU-U.S. Data Privacy Framework
Talent Plus complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Talent Plus has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom in reliance on the UK Extension to the EU-U.S. DPF. Talent Plus has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (collectively, the “DPF Principles”), the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/.
Scope
This Data Privacy Framework Policy (the “Policy”) sets forth the privacy principles that Talent Plus follows when processing Personal Data received from customers or prospective customers located in the European Economic Area (“EEA”), Switzerland, and the United Kingdom while providing services from the United States (“U.S.”). This Policy does not apply to information collected through other Talent Plus websites or to information collected during Talent Plus sponsored sales and marketing activities. This Policy also does not apply to Personal Data collected through Talent Plus’ recruiting process. For purposes of this Policy, Personal Data means data about an identified or identifiable individual that is received by Talent Plus in the United States from the EEA, Switzerland, or the United Kingdom, and recorded in any form, and is within the scope of Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”), the Swiss Federal Data Protection Act, or the UK Data Protection Act 2018, respectively.
Talent Plus’ Role as a Service Provider to its Customers and Prospective Customers
Talent Plus is the creator of certain software products, and in connection with these software products, Talent Plus provides product demonstrations, product development, product enhancements, cloud services, solution engineering services, professional technical services, data migration services, and product technical support services (collectively “Services”) for the benefit of its customers and prospective customers in the EEA, Switzerland, and the United Kingdom through employees who may be located in the U.S. These U.S.-based employees may process Personal Data to provide Services to customers and prospective customers located in the EEA, Switzerland, or the United Kingdom.
Customers using Talent Plus’ cloud solutions are responsible for managing the data that they store within Talent Plus’ cloud solutions. Customers determine the categories of Personal Data and other information that are stored by Talent Plus. Similarly, Talent Plus' customers and prospective customers who share data with Talent Plus in connection with any of its Services determine which categories of Personal Data will be shared and for what purposes. Consequently, Talent Plus does not generally know the categories of Personal Data to be processed or the purpose(s) of the processing unless and until Talent Plus receives this information from its customers or prospective customers.
When Talent Plus processes Personal Data, Talent Plus does so only for the purpose of providing Services.
The Customer’s and Prospective Customer’s Responsibilities with Respect to Personal Data
Talent Plus customers and prospective customers may choose to include Personal Data among the data stored within the Talent Plus cloud or otherwise shared with Talent Plus in connection with its provision of Services.
Talent Plus processes only the Personal Data that its customers or prospective customers have chosen to share with Talent Plus. Talent Plus has no direct or contractual relationship with the subject of such Personal Data (a "Data Subject"). As a result, when a customer or prospective customer shares Personal Data, the customer or prospective customer is solely responsible for satisfying all legal obligations owed directly to the Data Subject under applicable data protection laws.
It is the customer's or prospective customer's responsibility to ensure that Personal Data it collects can be legally collected in the country of origin. The customer or prospective customer is also responsible for providing to the Data Subject any notices required by applicable law and for responding appropriately to the Data Subject's request to exercise his or her rights with respect to Personal Data. In addition, the customer or prospective customer is responsible for ensuring that its use of Talent Plus’ cloud offerings or Services is consistent with any privacy policy the customer or prospective customer has established and any notices it has provided to Data Subjects.
Talent Plus is not responsible for its customers’ or prospective customers’ privacy policies or practices or for the customers’ or prospective customers’ compliance with such policies or practices. Talent Plus does not review, comment upon, or monitor its customers’ or prospective customers’ privacy policies or their compliance with such policies. Talent Plus also does not review instructions or authorizations provided to Talent Plus to determine whether the instructions or authorizations are in compliance with, or conflict with, the terms of a customer's or prospective customer's published privacy policy or of any notice provided to Data Subjects. Customers and prospective customers are responsible for providing instructions and authorizations that comply with their policies, notices, and applicable laws.
Talent Plus’ Compliance with the Data Privacy Framework Principles
Talent Plus employees located in the United States may provide Services for customers and prospective customers located in the EEA, Switzerland, or the United Kingdom. To provide such Services, Talent Plus may process Personal Data. Talent Plus will apply the following DPF Principles to Personal Data physically or remotely transferred from the EEA, Switzerland, or the United Kingdom to the United States.
Access
Data Subjects have the right to access the Personal Data an organization holds about them. If such Personal Data is inaccurate or processed in violation of the DPF Principles, a Data Subject may also request that Personal Data be corrected, amended, or deleted.
When Talent Plus receives Personal Data, it does so on its customer's or prospective customer's behalf. To request access to, or correction, amendment, or deletion of, Personal Data, Data Subjects should contact the Talent Plus customer or prospective customer that collected their Personal Data. Talent Plus will cooperate with its customers' and prospective customers' reasonable requests to assist Data Subjects to exercise their rights under the DPF.
Choice
Data subjects have the right to opt out of:
(a) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and
(b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized.
Talent Plus’ customers and prospective customers are responsible for informing Data Subjects when they have the right to opt out of such uses or disclosures.
Data Subjects who wish to limit the use or disclosure of their Personal Data should submit that request to Talent Plus’ customer or prospective customer that controls the use and disclosure of their Personal Data. Talent Plus will cooperate with its customers’ and prospective customers’ instructions regarding Data Subjects’ choices.
Security
Talent Plus is committed to safeguarding the Personal Data that it receives. While Talent Plus cannot guarantee the security of Personal Data, Talent Plus takes reasonable and appropriate measures to protect Personal Data in Talent Plus’ possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Talent Plus utilizes a combination of security technologies, procedures, and organizational measures to help safeguard Personal Data. For example, facility security is designed to prevent unauthorized access to Talent Plus computers. Electronic security measures — including, for example, network access controls, passwords, and access logging — provide protection from hacking and other unauthorized access. Talent Plus also protects Personal Data through the use of firewalls, role-based restrictions and, where appropriate, encryption technology. Talent Plus limits access to Personal Data to employees, subcontractors, and third-party agents that have a specific business reason for accessing such Personal Data. Individuals granted access to Personal Data are aware of their responsibilities to protect such information and are provided appropriate training and instruction.
Data Integrity & Purpose Limitation
Talent Plus' customers and prospective customers are responsible for limiting their collection of Personal Data to that which is necessary to accomplish the purposes disclosed to Data Subjects and compatible purposes. They also are responsible for providing Talent Plus with instructions or authorization for the processing of Personal Data consistent with such purposes.
Talent Plus’ customers and prospective customers also are responsible for ensuring that:
(a) Personal Data they collect is accurate, complete, current, and reliable for its intended uses; and
(b) Personal Data is retained only for as long as is necessary to accomplish the customer's or prospective customer's legitimate business purposes disclosed to the Data Subject and for compatible purposes.
Talent Plus will cooperate with customers' and prospective customers' reasonable requests for assistance in meeting these obligations.
In the performance of Services, Talent Plus will request only the minimum amount of information required to perform the applicable Services and will retain such information only for as long as necessary to provide the Services or for compatible purposes, such as to provide additional Services, to comply with legal requirements, or to preserve or defend Talent Plus’ legal rights
Onward Transfers
Talent Plus may disclose Personal Data to subcontractors and third-party agents who assist Talent Plus in providing Services to its customers and prospective customers. Before disclosing Personal Data to a subcontractor or third-party agent, Talent Plus will obtain assurances from the recipient that it will:
(a) use the Personal Data only to assist Talent Plus in providing the Services;
(b) provide at least the same level of protection for Personal Data as required by the DPF Principles; and
(c) notify Talent Plus if the recipient is no longer able to provide the required protections.
Upon notice, Talent Plus will act promptly to stop and remediate unauthorized processing of Personal Date by a recipient. Talent Plus will remain liable for onward transfers to its subcontractors and third-party agents.
Talent Plus may also be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. To the extent permitted, Talent Plus will inform its relevant customer or prospective customer before making such disclosure and provide it with a reasonable opportunity to object to such disclosure.
Talent Plus will not otherwise disclose Personal Data to third parties.
Recourse, Enforcement & Liability
In compliance with the EU-U.S. DPF Principles, including the UK Extension of the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, Talent Plus commits to resolve complaints about your privacy and Talent Plus’ collection or use of Personal Data transferred to the United States pursuant to this Policy.
European Union, Swiss, and United Kingdom individuals with DPF inquiries or complaints should first contact Talent Plus’ Data Protection & Privacy Department by emailing privacy@talentplus.com or by calling 1-800-VARSITY (1-800-827-7489).
Talent Plus has further committed to refer unresolved privacy complaints under the DFP Principles to an independent recourse mechanism, American Arbitration Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit ICDR-AAA DPF IRM Service | ICDR.org (adr.org) for more information and to file a complaint. This service is provided free of charge to you.
If your DFP complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not otherwise resolved by other redress mechanisms. For more information about binding arbitration, visit https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.
The Federal Trade Commission has jurisdiction over Talent Plus’ compliance with the DPF.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Talent Plus commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.
GDPR Notice
CCPA Notice
As of July 5, 2023
EU & UK General Data Protection Regulation (GDPR) Rights Notice
In addition to the specific information about our data collection and processing practices posted in the Talent Plus Global Privacy Notice, Talent Plus (Company, We, Our) wants you to understand your rights and choices under the EU and UK General Data Protection Regulation (GDPR) regarding how we may process your personal information.
For our corporate clients, you can exercise your rights by submitting your request to your organization, the Data Controller.
If you have not engaged with or participated in Talent Plus services through your company, you can exercise your rights by sending us an email at privacy@talentplus.com or using the information provided in the Contact Us section below.
Your Rights under the UK & EU GDPR
Please note that we are required to verify your identity before we are able to process any of the requests described in this Section; and at our discretion, deny your request if we are unable to verify your identity.
Right of Access – You have the right to obtain confirmation whether your personal data is being processed, obtain a copy of your personal data, and know:
- The categories of data we’re processing
- The purposes of data processing
- The categories of third parties to whom the data may be disclosed
- How long the data will be stored (or the criteria used to determine that period)
- Your other rights regarding our use of your data
Right to Erasure (Right to be Forgotten) – You have the right to request we erase your personal data except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Talent Plus.
Right to Rectification (Correction) – You have the right to correct inaccurate personal data and the right to have incomplete personal data completed.
Right to Data Portability – You have the right to request the transfer of your personal data directly to you or to another organization in a structured, commonly used, and machine-readable format but we will not do so to the extent that this involves disclosing data about any other individual.
Right to Restriction of Processing – You have the right to restrict the processing of your personal data.
Right to Object – You have the right to object to the processing of your personal data. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
Right to Lodge a Complaint Regarding our Use of Your Data –You can file a complaint directly with Talent Plus by emailing us at privacy@talentplus.com or through our phone or mailing address in the Contact Us section.
If your request or concern is not satisfactorily resolved, you may approach your local data protection authority:
EU- https://ec.europa.eu/info/law/law-topic/data-protection_en
UK - https://ico.org.uk/
Contact Us
If you have any questions or comments about your rights under the GDPR; the Talent Plus Privacy Notice; the ways in which we collect and use your personal information, your choices, and rights regarding such use; or wish to exercise your rights under the GDPR, please contact us at:
Phone: 1-800-VARSITY
Email: privacy@talentplus.com
Postal Address: Talent Plus
Attn: Privacy Team
One Talent Plus Way Lincoln, Nebraska, U.S.A. 68506-5987
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Talent Plus has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
- By using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- By writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) - UK Representative
Pursuant to Article 27 of the UK GDPR, Talent Plus has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- By using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
- By writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
As of July 5, 2023
California Consumer Privacy Act (CCPA) Rights Notice
In addition to the specific information about our data collection and processing practices posted in the Talent Plus Global Privacy Notice, Talent Plus (Company, We, Our) wants you to understand your rights and choices under the California Consumer Privacy Act (CCPA) regarding how we may process your personal information.
In the preceding twelve (12) months, Talent Plus has not sold or shared any personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights under the CCPA and explains how to exercise those rights.
Please note that we are required to verify your identity before we can process any of the requests described in this Section; and at our discretion, deny your request if we are unable to verify your identity.
Non-Discrimination – We will not discriminate against you for exercising any of your CCPA rights.
Right To Know & Data Portability – You may request that we disclose to you what personal information we have collected, used, or shared, and why we collected, used, shared, or sold that information. Specifically, you may request that we disclose:
- The categories of personal information collected
- Specific pieces of personal information collected
- The categories of sources from which we collected personal information
- The purposes for which we use the personal information
- The categories of third parties with whom we share the personal information
- The categories of information that we disclose to third parties
You may also request we provide you a copy of your information in a readily portable format.
Right to Delete – You have the right to request we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete, and direct our Service Providers to delete, your personal information from our/their records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
- Complete the transaction for which we collected the personal information, provide a requested good or Service, take actions reasonably anticipated within the context of our ongoing business relationship, or otherwise perform our contract.
- 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 individual 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 seq.).
- Enable solely internal uses that are reasonably aligned with individuals’ 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.
Right to Correct – You may ask Talent Plus to correct inaccurate information that we have about you.
Right to Opt-out of Sale or Sharing – Talent Plus does not share or sell your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information – Talent Plus may collect sensitive personal information as part of the job application process and does conduct background checks as a condition of employment. Disclosure is limited to the background check Service Provider.
Exercising Your Rights
To exercise the rights described above, please submit a verifiable request using the options provided in the Contact Us section below.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may only make a request twice within a 12-month period and you should describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Making a verifiable request does not require you to create an account with us, and we will only use personal information provided in a request to verify the requestor's identity and/or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable request. 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.
We do not charge a fee to process or respond to your 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.
Contact Us
If you have any questions or comments about this Notice and/or our Global Privacy Notice; the ways in which we collect and use your personal information; your choices and rights; or if you wish to exercise your rights under California law, please contact us at:
Phone: 1-800-VARSITY
Email: privacy@talentplus.com
Postal Address: Talent Plus
Attn: Privacy Team
One Talent Plus Way Lincoln, Nebraska, U.S.A. 68506-5987
Cookie Notice
As of July 5, 2023
When you use the Talent Plus, Inc. (our, we) website, we may store cookies on your web browser. This Cookie Notice explains what a cookie is, how you can manage your cookies, and what kind of cookies may be on our sites.
1. WHAT IS A COOKIE & WHY DO WE USE THEM?
Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in.
Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
First-party & Third-party Cookies
First-party Cookies are cookies that belong to the Company and that we place on your device; and Third-party Cookies are cookies that another party places on your device through our Site.
Session Cookie
Session Cookies are temporary cookies that are used to remember you during the course of your visit to the website, and they expire when you close the web browser. Once you close the browser, all Session Cookies are deleted.
Persistent Cookies
A Persistent Cookie is a cookie that is stored by the web browser on your device until it expires, or you delete it. Persistent Cookies are used to remember your preferences within the website and remain on your desktop or mobile device even after you close your browser or restart your computer. We use these cookies to analyze user behavior to establish visit patterns so that we can improve our website functionality for you and others who visit our website(s). These cookies also allow us to serve you with targeted advertising and measure the effectiveness of our site functionality and advertising.
2. HOW DO I MANAGE COOKIES?
Most web browsers let you choose whether to accept cookies. Most also let you delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu. You may also consult the browser’s “help” menu. For example:
Cookie settings in Internet Explorer
There are online tools available for clearing all cookies left behind by the websites you have visited, such as https://www.allaboutcookies.org; and for users in the EEA & UK, https://www.youronlinechoices.eu/.
Most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
Cookie preferences specific to the Talent Plus, Inc. website can be managed by visiting the Talent Plus Cookie Preference Center.
3. WHAT KIND OF COOKIES DO WE USE?
The Site may use Strictly Necessary Cookies, Performance Cookies, Functional Cookies, Targeting Cookies, and Social Media Cookies. Any of these may be first-party cookies or third-party cookies, persistent or session. Your cookie consent and preferences can be viewed and managed through Talent Plus’ Consent Center.
- Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
- Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
- Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
- Advertising/Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
- Social Media Cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
4. UPDATES TO THIS COOKIE NOTICE
We may update this Cookie Notice from time to time with changes to the cookies we use or for other operational, legal, or regulatory reasons. Please revisit the Notice regularly to stay informed about our use of cookies and related technologies.
5. CONTACTING US
If you have any questions about our use of cookies or other technologies, please email us at: privacy@talentplus.com.
Job Applicant and Candidate Privacy Notice
As of August 31, 2023
Talent Plus (“Company”, “we”, “us” or “our”) respects the privacy of its job applicants and individuals interested in potential employment opportunities with us (“you”), and we are committed to protecting personal data.
To that end, we have put together this Job Applicant & Candidate Privacy Notice (“Privacy Notice”) to give you a better understanding of who we are and our practices with respect to the collection, use, disclosure, and retention of personal data obtained in connection with applying for a job at Talent Plus and of our recruitment process.
This Privacy Notice describes the types of personal data we may collect during the application and recruitment process, how we may use this information, when and to with whom we may disclose this information, and how to access and update this information.
Please also see our Global Privacy Notice for additional information about our data collection and protection practices when you engage with us through our digital properties.
1. Types of Personal Data We Collect
We collect personal data from you in connection with your job application with Talent Plus and through the recruitment process, including the following but not limited to:
- Name, address, email address, telephone number, and other contact information.
- Resume, CV, cover letter, previous work experience, professional licenses and certifications, job skills and qualifications, and education information.
- Reference information, employer feedback, and information received from background checks.
- Talent Assessment results.
- Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards, or professional memberships).
2. How We Collect Your Personal Data
We may collect this information in a variety of ways, including from application forms, CVs or résumés, identity documents, third parties (such as for references or background checks, or from recruiters), or through interviews or other forms of assessment.
If we ask you to provide personal data that we consider to be mandatory for us to manage your job application and candidate relationship with us, we will let you know at the time we’re collecting it. However, if you do not provide the information, we may not be able to process your application properly or at all.
If we ask you to provide any other personal data not described above, we will let you know why we are asking for it at the time we collect it and will also update this Privacy Notice accordingly.
3. How We Use Candidate Data
We will use your personal data only for the purposes of carrying out its job application and recruitment process, and we do not sell or share (as defined in applicable data protection and privacy laws) your personal data (and will not sell or share it without providing any required notices and/or opt-in/opt-out rights).
Uses include but are not limited to:
- Assessing your skills, qualifications, and interests against our career opportunities and determining your suitability for employment.
- Contacting you if we need more information related to your application or respond to questions from you.
- Scheduling and/or conducting an interview with you.
- Deciding whether to offer you a job.
- Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job.
- Communicating with you about the recruitment process and/or your job application(s), including, in appropriate cases, informing you of other potential career opportunities.
- Maintaining appropriate record-keeping related to recruitment and hiring practices and processes.
- Detecting and protecting against security incidents and malicious, deceptive, fraudulent, or illegal activity, or violations of our policies or the law; for fraud and crime prevention; and for information protection and cybersecurity.
- Complying with our disaster recovery, business continuity, and record keeping obligations.
- Complying with applicable laws, regulations, legal processes, or governmental requests.
If you are offered and accept employment with us, the personal data collected during the job application and recruitment process may become part of your employment record.
If we need to process your personal data for an incompatible purpose not discussed in this Privacy Notice, we will provide notice to you and, if required by law, seek your consent.
4. Legal Basis for Processing Personal Data
If you are a resident of the EEA or the UK, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the context in which we collect it. However, we will normally collect and/or process your personal data pursuant to one or more of the following legal bases:
- Legitimate Interests: The processing is necessary in connection with our legitimate interests in recruitment and hiring candidates and which do not override your data protection interests or fundamental rights and freedoms.
- Contract: The processing is necessary to take steps, at your request, relating to potentially entering into an employment contract with you.
- Legal Obligations: The processing is necessary to comply with our legal obligations, such as retaining records relating to the recruitment process for periods required under applicable laws or regulations.
We may also seek your consent to process or retain your personal data in certain, limited circumstances that we clearly identify to you.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in the “Contact Us” section below.
5. When We Disclose Your Personal Data
Talent Plus takes care to allow your personal data to be accessed only by those who need such access to perform their tasks and duties, and to service providers who have a legitimate purpose for processing or accessing it. As noted above, we do not sell or share (as defined in applicable data protection and privacy laws) your personal data.
As such, we may share your personal data as described in this Privacy Notice to the following categories of recipients:
- Team members to establish, manage, or terminate your employment with Talent Plus.
- Vendors, service providers and contractors we use to assist in providing services to us or assist us in administering the recruitment process, including background check providers that verify information about you as part of your application. We require all our vendors, service providers and contractors, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us.
- Third parties with your authorization – for example, to conduct a reference check.
- Law enforcement agencies, courts, supervisory authorities, regulatory bodies and certain other third parties, to the extent that we are permitted or required to do so by applicable law, or to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.
- To third parties, in connection with a change of corporate control or other investment, such as a restructuring, merger, transfer, or sale of some or all of our assets.
6. Data Subject Rights
Job applicants and candidates are provided with privacy rights under applicable data protection or privacy law, subject to identity verification and certain exceptions and limitations, including:
- Right of Access – You have the right to obtain confirmation whether your personal data is being processed, obtain a copy of your personal data, and know:
- The categories of data we’re processing
- The purposes of data processing
- The categories of third parties to whom the data may be disclosed
- How long the data will be stored (or the criteria used to determine that period)
- Your other rights regarding our use of your data
- Right to Erasure (Right to be Forgotten) – You have the right to request we erase your personal data except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Talent Plus
- Right to Rectification (Correction) – You have the right to correct inaccurate personal data and the right to have incomplete personal data completed.
- Right to Data Portability – You have the right to request the transfer of your personal data directly to you or to another organization in a structured, commonly used, and machine-readable format but we will not do so to the extent that this involves disclosing data about any other individual.
- Right to Restriction of Processing – You have the right to restrict the processing of your personal data.
- Right to Object – You have the right to object to the processing of your personal data. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
- The right to withdraw consent for data you’ve provided to us on a consensual basis.
Under specific circumstance, these rights may be limited. For example, if fulfilling your request would reveal personal data about another individual, or if you ask us to delete personal data which we are required by law to keep or which we need to defend claims against us. If there is an exception to fulfilling your request, we will communicate clearly and fully with you about the reason.
Right to Complain to a Supervisory Authority: While we hope we can resolve any dispute between us, you have the right to lodge a complaint with the supervisory authority in the country where you work or where you consider any data protection rules to have been breached.
To exercise any of these rights, please contact us by using the contact details under the “Contact Us” section below.
We will respond to such requests in accordance with the requirements of applicable data protection laws. Please also see our Global Privacy Notice for additional information about our data collection and protection practices when you engage with us through our digital properties.
7. International Transfers
The personal data we collect is processed at our offices in the United States and in any data processing facilities operated by authorized service providers. By submitting your personal data, you agree to this transfer, storing or processing by us. Where your information is transferred, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, security, and data protections, and that it is treated securely and in accordance with this Privacy Notice.
8. Security & Retention
Talent Plus maintains appropriate technical and organizational measures, including, but not limited to, reasonably designed administrative, physical, and technical safeguards, designed to protect the personal data obtained as discussed in this Privacy Notice from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and access.
Unless a longer retention period is required by law and as documented in our corporate data retention schedule, we will retain your personal data for only as long as is needed to fulfill the purposes outlined in this Employee Privacy Notice. When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it.
As noted above, if you are offered and accept employment with us, the personal data collected during the job application and recruitment process may become part of your employment record.
9. Changes to this Privacy Notice
We will update this Notice from time to time. We will post the revised Notice with an updated revision date on the Company website.
10. Contact Us
If you have any questions about this Notice or the ways in which we collect and use your personal information, your choices, and rights regarding such use; or wish to exercise your rights, please contact us at:
Phone: 1-800-VARSITY
Email: privacy@talentplus.com
Postal Address: Talent Plus
Attn: Privacy Team
One Talent Plus Way
Lincoln, Nebraska, U.S.A. 68506-5987
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Talent Plus has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
- By using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- By writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) - UK Representative
Pursuant to Article 27 of the UK GDPR, Talent Plus has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- By using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
- By writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom