If this Policy changes, we will post an updated version on our website at www.curasion.com and the associated domains (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways in our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Offerings after the Policy changed or notice of the change has been given, you will be deemed to have accepted such changes.
1 Information We Collect
A. Information From All Users
We collect the following types of information from all users of our Offerings:
(a) Account information: When you use our Offerings you will need to create an account with us. In order to create an account, you will need to provide us with login credentials (which include your user account name and password), your name, email address, and phone number and you may provide us with your company name and postal address.
(b) General usage data: When you use our Offerings we may collect technical properties of hardware and software utilized in conjunction with our Offerings. For example, we may collect the type and model/version of hardware and/or web browser you are using, referring or exit web pages, and the type and version of operating system you are using. When you use our Offerings we may also collect information about the number of visits you make to our Offerings, what pages you visit on our Offerings, and the length of your sessions using our Offerings.
(c) Quality assurance and customer service: Your customer service telephone calls and emails with us and our service providers, if any, may be recorded, logged, and/or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to our Offerings and customer service. As part of the recording and logging of the calls and emails, we will collect information like the identity of the caller or sender of email, the date and time of the call or email, and the subject and resolution of the issue.
B. Information from Companies
In addition to the information we collect from all users of our Offerings, when companies looking to hire contractors use our Offerings, we also collect the following types of information from our companies:
(a) Contract Job Requirements: We collect the title, description of job, start and end date of job, when the company needs the contractor, the location of the job, the ideal skills of the contractor, and the bill rate range the company is willing to pay the contractor.
(b) Talent Pool Needs: We collect information that defines a talent pool. This includes a title, description, location, and list of required skills a contractor must have to be in a talent pool.
(c) Location Information: In addition to collecting a company’s address and location of jobs, we also collect the IP addresses of company’s hardware to assist a company identify their location when filling out the location field in their profile.
C. Information From Contractors
In addition to the information we collect from all users of our Offerings, when contractors looking for work use our Offerings, we also collect the following types of information from our contractors:
(a) Engagement information: We collect past work experience, desired billing rate, preferred language, title, availability to work, where willing to work, overview of resume, resume itself, skills, years of experience, expertise level for each skill, and a picture of the contractor.
(b) Location Information: In addition to collecting a contractor’s address and location where willing to work, we also collect the IP addresses of our contractor’s hardware to assist a contractor identify their location when filling out the location field in his/her profile.
(c) Third party information: If necessary to fulfill our identified purposes and in accordance with applicable laws, we may combine the information you submit to us with information obtained from other sources or third party offerings. For example, we may receive personal information about you from third parties who do background checks, who provide training, and where you have an online profile about your work experience. We treat all such personal information in accordance with this Policy and the terms and conditions between us and such third parties, if any, may also apply. However, the third party's own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is one of our service providers.
D. Information From Staffing Agencies
In addition to the information we collect from all users of our Offerings, when staffing agencies interact with us, we also collect the following types of information from our staffing agencies:
(a) Talent Pool Needs: We collect information about your submissions to the talent pool, including without limitation, the number of contractors you submit to the talent pool, which contractors you submitted to the talent pool and their backgrounds, and whether the contractors you submitted to the talent pool were hired by companies.
Some of this information would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.
2 Our Use of Information We Collect
A. Information From All Users
We use the personal information we collect about all users of our Offerings:
(a) to understand and meet your needs and preferences, and/or to provide you with our Offerings, for example:
(i) for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, upgrade, or update of Offerings;
(ii) to ensure Offerings are technically functioning as intended and to help identify and troubleshoot issues;
(iii) to fulfill or enforce any agreements or notices we provide and are associated with a particular Offering (“Notices”);
(iv) to manage and/or respond to your inquiries;
(b) to develop new and enhance existing Offerings including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or notices of upgrades or updates of Offerings;
(c) to manage and develop our business and operations, for example;
(i) to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect our property;
(ii) to allow for business continuity and disaster recovery operations;
(iii) to enforce our legal rights;
(iv) for statistical purposes;
(d) to meet legal and regulatory requirements and to respond to emergency situations, for example:
(i) to respond to court orders, warrants or other lawful requests or legal processes;
(ii) to provide emergency assistance in situations that may threaten the life or
physical safety of you or others; or
(iii) for any other purposes for which you have consented, such as those that may be
set out in Notices, and other purposes as permitted or required by any applicable law.
B. Information From Companies
In addition to the uses of personal information we collect from all users of our Offerings, we use the personal information we collect from companies:
(a) to understand and communicate with you regarding job opportunities so we can find contractors to fill the jobs and bill companies when we fill jobs; and
(b) to understand and communicate with companies to understand their talent pool requirements.
C. Information From Contractors
In addition to the uses of personal information we collect from all users of our Offerings, we use the personal information we collect from contractors:
(a) to identify job opportunities that meet contractor’s criteria and to communicate with contractors regarding such jobs.
D. Information From Staffing Agencies
In addition to the uses of personal information we collect from all users of our Offerings, we use the personal information we collect from staffing agencies:
(a) to communicate with staffing agencies regarding (i) the talent pool requirements of companies; and (ii) contractors who may meet the talent pool requirements.
(b) To track which contractors submitted by a staffing agency have been hired by a company.
Notwithstanding, anything to the contrary contained in this Policy, we may remove personal identifiers from information we collect from all users of our Offerings and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de- identified and/or aggregated information. We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.
You may update your communication preferences anytime by editing your account within the Offerings.
3 To whom we Disclose your Personal Information
In accordance with this Policy, we may share the personal information of all users of our Offerings:
(a) within Curasion and/or with our service providers such as a cloud service provider in Canada, the United States, and the European Economic Area for data storage;
(b) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
(c) if we have your consent;
(d) with other users of our Offerings which may include: (i) notifying contractors of job opportunities; (ii) notifying staffing agencies of talent pools in which companies are looking for contractors; and (iii) notifying companies of contractors that meet the hiring criteria;
(e) with third parties involved in providing our Offerings to you which may include agency management systems and agencies of record
(f) and any and all information about your use of the Offerings with your company if your company has provided you with access to the Offerings;
(g) as necessary to complete any transactions while using our Offerings;
(h) respond to a subpoena, order, legal process, or government request;
(i) protect, establish or exercise our legal rights or defend against legal claims;
(j) investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;
(k) as otherwise required by law; or
(l) if we are to be sold, merged, or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
4 Your Decisions About Your Personal Information
At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information by writing to us at firstname.lastname@example.org or Curasion Inc., 77 Adelaide St. West, Suite 350, Toronto, Ontario, Canada, M5X 1C1. You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us.
If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws.
Generally, you may withdraw at any time your consent for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your personal information as may be required to provide you with our Offerings, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Offerings.
When you visit the Website, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Website), and embedded scripts (programming code that is designed to collect information about your interactions with the Website, such as the links you click on, and which is active only when you are accessing the Website).
The information we collect in this manner may include details about the computer, mobile phone, or other device used to access the Website (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.
We may use third-party web analytics services to help us analyze how visitors use the Website. We may permit these third parties to operate directly on the Website, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.
When you visit our Website, we may allow some third parties (such as advertising networks and data analytics companies) to collect information about your online activities over time and across different websites. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
In some instances, we may also combine information we receive about you from third parties with information we collect through the Website.
We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, that we cannot guarantee that the measures we maintain will guarantee the security of the information.
We limit access to your personal information within Curasion to individuals with a need to know.
Your personal information may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, by using our Offerings, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of us.
7 Links to Other Sites
8 Children’s Online Privacy Protection
The Website and Offerings are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.
9 California Residents – Your California Privacy Rights
If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request by email to email@example.com or write to us at Curasion Inc., 777 Adelaide St. West, Suite 350, Toronto, ON M5X 1C1. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Questions or Comments
If you have any questions or comments or wish to make a complaint about this Policy, please contact us at firstname.lastname@example.org, or by delivery in person, by courier or by the mail, to us at Curasion Inc., 777 Adelaide St. West, Suite 350, Toronto, Ontario, Canada, M5X 1C1. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, wemay refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
Effective Date: Mar 1, 2020