Last Updated:  November 5, 2018

Career Group Inc. (“Career Group”, the “Company”, “we”, “us” or “our”) provides this notice (this “Privacy Notice”) to help you make informed decisions when using our services (the “Services”) and when visiting our website (https://careergroupcompanies.com/) (our “Website”).  This Privacy Notice describes how and why we collect, use, store, share, transfer or otherwise process any personal data that we collect and describes your rights in respect of our processing of personal data.

Career Group Companies®, Career Group®, Fourth Floor™, Syndicatebleu®, Avenue Pacific®, Lifestyle Talent Partners™ and Event Team™ are all dbas of Career Group Inc.

WHEN WE COLLECT PERSONAL DATA

We collect and process personal data by expressly obtaining it from you, including in the following instances: (i) when you register for the Company’s Services through the Website, (ii) when you elect to contact us electronically to apply for a job, ask a question or for other reasons, and (iii) when you “opt in” for certain services or features of the Website.

With respect to the personal data we collect and process, we will typically be the data controller.  In some cases, we may be a data processor.

WHAT TYPES OF PERSONAL DATA DO WE COLLECT?

WHAT INFORMATION DOES THE COMPANY COLLECT FROM YOU?

We may collect certain personal data, as described below.

Visitors Who Apply For a Job – If you apply for a job through the Website, you will need to provide us with the following personal data: full name, phone number(s), e-mail address, city location and information you include on your resume (including work history and certain additional personal information).

Visitors Who Register For Services – If you elect to register for the Company’s Services through the Website, you will need to provide us with some or all of the following personal data: full name, address, phone number(s), e-mail address, website address, social media account information, work history and certain additional personal information.

Discretionary Contact With Us – The Website allows you to contact us electronically through e-mail. Whenever you make such contact, you will be providing us with some or all of the following personal data: your name, email address, phone number and any information you choose to include in the text of your message.

In addition, depending on how you use the Website, we may collect the following data:

    • information about your use of Website features and how frequently you use them; and
    • customer service information about you as a Website user.

You can remove your information at your convenience as described below under the heading “Data Retention and Modifications“.  However, if you do not provide personal data to us when requested, we may not be able to provide Services to you.  We may also not be able to perform any contract we have (or are trying to enter into) with you.

WHAT TYPES OF TECHNICAL DATA DO WE COLLECT?

The Website uses commonly-used automated information gathering tools. While you are using our Website (even if you do not register for any of the Company’s Services), we automatically log your Internet Protocol (IP) address (a number assigned to your computer when you use the Internet), general data (including your domain name and the name of the web page from which you entered our Website) and your activity while accessing and using our Website.

Additionally, in order to personalize and enhance your experience, we may also collect information through “cookies.” Cookies are small strings of text that are sent by our Website to your browser and then stored by your browser on your computer’s hard drive. We use cookies to help diagnose problems with our servers and to administer our Website. We also use cookies to gather broad demographic information and to help identify you (by certain personally identifiable information) in respect to visits to our Website, so that we may improve your user experience, and to determine whether you visited our Website from a particular Internet link or advertisement.

We may also use small bits of code called “one-pixel gifs,” “clear gifs,” or “web beacons” embedded in web pages to gather certain web site information. Information may also be collected passively in the form of log files that record website activity, including how many “hits” a particular web page is getting (a.k.a., “click-through data”). For example, log file entries are generated every time a user visits a particular page or clicks an image on our website. These entries enable us to track a particular user’s visits to a web page, assess overall Website activity, track user interest in portions of our Website, troubleshoot technical concerns, and identify the type of browser you are using. We may also use the log file entries for our internal marketing and demographic studies, so we can constantly improve our Website.

By visiting our Website, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Notice. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies.  If you disable cookies, some features of our Website may become disabled, and some aspects of our Website may not function properly.  Deleting cookies does not necessarily delete Flash objects. You can learn more about Flash objects – including how to control and disable them – through the Adobe interface.  If you choose to delete Flash objects from our Website, then you may not be able to access and use all or part of our Website or benefit from the information and services offered.

HOW WE USE YOUR PERSONAL DATA AND TECHNICAL DATA

We process personal data to operate our business, to provide Services, and to operate our Website.  Specific purposes for processing personal data include:

    • to provide you with our Services, including arranging an interview and helping obtain a job;
    • to provide the Services offered by the Company;
    • to correspond with you regarding the Company or matters arising under our agreements with you;
    • to inform you of developments about the Company or with our Services that we believe may be of interest to you;
    • to personalize your use of our Services and the Website;
    • to conduct research and development for the improvement of our Website to provide you and other users with a better experience and drive user growth and engagement;
    • to monitor Website usage and other activity;
    • for our internal operations, including troubleshooting and diagnosing problems with our computer servers;
    • for identification and security purposes;
    • to comply with applicable laws, regulations and legal processes;
    • to enforce our agreements with you; and
    • to protect the rights, property, or safety of ourselves, our users and others.

PARTIES WITH WHOM WE MAY SHARE PERSONAL DATA AND TECHNICAL DATA

Your trust is important to us, which is why we do not sell or rent your personal data to third parties solely for marketing purposes.

We share your personal data with our clients who are using our Website to post job openings or otherwise work with us to fill positions. We may also share information with contractors providing services on our behalf and otherwise to help us operate the Website. In addition, we may from time to time share information with our affiliated companies for use in connection with their businesses. We require our clients and those providing services on our behalf and affiliates to limit their use and disclosure of your information to uses and disclosures that are consistent with this Privacy Notice.  However, we cannot guarantee their compliance.

We may also share personal data about you with others if:

    • we have received your permission;
    • we have given you notice, such as by telling you about it in this Privacy Notice;
    • we have removed your name or any other personally identifying information from it; or
    • it is necessary to carry out your instructions or in order to provide the features and functionality of our Website.

In addition, we use third party service providers (our “Service Providers”) to assist us in operating our business.  Service Providers provide a wide range of services to us, including legal and compliance, accountancy, investment banking, marketing, data analytics, telecommunications (including telephone and video conferencing), website administration, information technology, courier, human resources and security services.

From time to time, we may share your personal data with our affiliates and our Service Providers, and those affiliates and Service Providers may process your personal data on our behalf and at our direction.  The types of personal data we may share with our affiliates and our Service Providers include:

    • your name;
    • your contact data (including email address and telephone numbers);
    • technical data, including IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device identifiers, geolocation information, and other technology on the devices you use to access our Website;
    • information about how you use our Website and our Services; and
    • your preferences in receiving marketing from us and from third parties, as well as your communication preferences.

We may also share anonymous / aggregated information with third parties, including our Service Providers, to facilitate our business operations.

Additionally, we may share your personal data for the following purposes:

    • to protect and defend our rights, property, or safety or those of our users, or others;
    • to enforce the terms that govern this Website or our provision of the Services;
    • to issue requests for employment verification or references to those to whom you have directed us;
    • when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities (such as for potential fraud or infringement);
    • when required to do so by law or regulation, or in response to legal process (for example, a court order, search warrant or subpoena) or a request from a law enforcement or governmental agency or authority, and in other circumstances in which we have a good faith belief that a crime has been or is being committed by you or another user or that an emergency exists; and
    • with our affiliates and third parties providing services on our behalf. We require our affiliates and third parties providing services on our behalf, and our users, to limit their use and disclosure of your information to uses and disclosures that are consistent with this Privacy Notice, however, we cannot guarantee their compliance. We may, however, also share, in aggregate, statistical form, non-personal information regarding traffic patterns, and Site usage with our partners or affiliates.

“DO NOT TRACK” SIGNALS

We do not collect personal data about your online activities over time and across third party websites or online services. Accordingly, we do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personal data about your online activities over time and across third party websites.

DATA RETENTION

We retain your personal data while your account is in existence, or as needed to provide Services to you. We may also retain your personal data even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between us and any third party, resolve any disputes between users, prevent fraud and abuse, or enforce this Privacy Notice or our agreements with you, and for as long as is necessary to provide support-related reporting and trend analysis.

We generally delete or de-personalize closed account data if personal information is no longer needed. We may also retain personal data if requested by law enforcement or as required under applicable law, regulation or legal process.

We strive to maintain the accuracy of any personal data that may be collected from you, and will use our reasonable efforts to update our database when you tell us the information in our database is not accurate. It is your responsibility to ensure that such information is accurate, complete and up-to-date.

Any removed information may persist in our backup files but will not be generally available to users.  We will not endeavor to delete information contained in our backup files.

EMAIL LISTS

Anyone may choose to subscribe (at no charge) to our email mailing list. Additionally, when you apply for a job or register for services through the Website, we may periodically send to you updates and other information regarding the Website and our services, unless you opt-out of receiving such information as noted below under the caption “Opt-Out.”

OPT OUT

You may opt out of receiving communications from us and our affiliates at registration or, thereafter, by following the opt-out link provided in any email received from us or by emailing us at marketing@careergroupcompanies.com.

CHILDREN

We do not intend for children under 13 years of age (or age 16 within the European Economic Area) to use our Website or our Services.  The Company does not knowingly collect or solicit personal information from anyone under the age of 13 (or age 16 within the European Economic Area) or knowingly allow such persons to register. However, in any event, if you are under 18, please do not attempt to register for this Website or send any information about yourself to us, including your name, address, telephone number, or email address. By using our Website, you represent that you are at least 18 years of age.

THIRD PARTY WEBSITES, ADVERTISERS AND APPLICATIONS

Career Group may reference or include links to third party websites.  Career Group does not control and is not responsible for the third-party websites or for the privacy policies or information practices of third parties or their websites. You should review the privacy policies applicable to such third party services, applications, websites and advertisers. Moreover, Career Group does not have access to or control of the cookies that may be placed on your computer by such third parties.

PROTECTING YOUR PERSONAL DATA

Because security is important to both you and us, we will use reasonable efforts to ensure the security of our systems. The Company employs physical, electronic and administrative safeguards to protect the information we receive from you from unauthorized disclosure. This includes our requirement for user names and passwords to access certain information and data and our use of industry-standard SSL encryption to protect data transmissions. Users should not share their user names or passwords with anyone. In addition, if you suspect unauthorized access to your information, it is your responsibility to contact us immediately at marketing@careergroupcompanies.com.

The Company’s personnel will never ask you to divulge your password in written or electronic communications. If at all, we will only ask you for your password when you contact us by phone and only in cases where you request customer service to correct a service problem which requires your password.

Please be aware that Internet data transmission is not always secure and we cannot warrant that information you transmit utilizing this Website is secure.

BUSINESS TRANSFERS OF PERSONAL DATA

We may, in the future, sell or otherwise transfer some or all of our assets to a third party. Your personal data and technical information may be disclosed to any potential or actual third party purchasers of such assets and/or may be among those assets transferred.  We may also share or transfer personal data and technical information in connection with a merger, divestiture, reorganization or other disposition (whether of assets, stock or otherwise), or in the event of our bankruptcy or other insolvency proceeding.

CALIFORNIA “SHINE THE LIGHT” LAW

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our Users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

USERS IN THE EUROPEAN ECONOMIC AREA

This section applies only to individuals in the European Economic Area.

Under the General Data Protection Regulation (the “GDPR”), individuals in the European Economic Area (“EEA Individuals”) have certain rights in relation to their personal data, which are summarized below.  These rights are subject to your exercising them in good faith and are subject to our legitimate interests or other valid basis to continue processing your personal data, in accordance with our policies and applicable law.

Our lawful basis for processing your personal data for the purposes described under the headings “How We Use Your Personal Data and Technical Data” and “Parties With Whom We May Share Personal Data and Technical Data” in this Privacy Notice are: (i) performance of any contract we are about to enter into or have entered into with you, (ii) it is necessary for our legitimate interests, (iii) we must comply with applicable legal or regulatory obligations, or (iv) we have received your consent.

EEA Individuals who wish to exercise any of the rights they have under the GDPR should contact us in writing by email.  Our email address is shown at the end of this Privacy Notice.  We may need to request specific information to help us confirm your identity, so that your personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request.

Generally, EEA Individuals will not have to pay a fee to exercise the rights described below.  However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with the request in such circumstances.

EEA Individuals may lodge a complaint with the appropriate regulatory body or supervisory authority in the country where they reside, where they work, or in the place of the alleged infringement of the law.

  • Access

If asked by an EEA Individual, and if we are obligated to do so under applicable law, we will inform that individual about whether we are processing his/her personal data.  If we are processing such EEA Individual’s personal data, we will provide access to the personal data that we have about that individual.  If you request additional copies of your personal data, we may charge you a reasonable fee.

  • Rectification (e., Correction)

If the personal data we hold about an EEA Individual is inaccurate or incomplete, that individual may ask us to have it corrected.

  • Erasure

EEA Individuals may request that we erase (i.e., delete or remove) their personal data in certain circumstances.  If you are legally entitled to erasure, and if we have shared such personal data with third parties, we will take reasonable steps (taking into account available technology and the cost of implementation) to inform such third parties of your request, to the extent we are required to do so by applicable law.

  • Restriction of Processing

EEA Individuals have the right to restrict the processing of their personal data in certain circumstances, such as if they contest the accuracy of that personal data, if the processing of the personal data is unlawful, or if we no longer need the personal data for our business purposes.  If you are legally entitled to restriction, and if we have shared your personal data with others, we will use reasonable efforts to inform such third parties of your request, if we are required to do so.

  • Data Portability

EEA Individuals may ask to receive their personal data from us, where the legal basis of our processing is their consent, and where we carry out the processing of their personal data by automated means.  If EEA Individuals so request, we may transmit their personal information directly to another organization if it would be technically feasible to do so.

  • Objection to Processing

EEA Individuals may object to the processing of their personal data where we are relying on a legitimate interest (or those of a third party).  As noted above, you also have the right to object (i.e., opt out of) our processing of your personal data for direct marketing purposes.

  • Automated Decision-Making and Profiling

EEA Individuals have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

We do not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.

  • Processing of Special Categories of Personal Data and of Personal Data Relating to Criminal Convictions and Offenses

There are certain types of personal data that require a higher level of protection, known as “special categories” of personal data under the GDPR.  We do not process special categories of personal data unless (i) we have obtained such individuals’ explicit consent or (ii) we are otherwise legally permitted to do so.  For example, we may collect special categories of personal data of EEA Individuals in the context of dietary requirements or restrictions for events and meetings that such individuals voluntarily provide to us.

We do not collect personal data about criminal convictions and offenses, unless revealed by due diligence conducted to comply with a legal or regulatory obligation or unless we are authorized to do so under applicable law.

  • Withdrawing Consent

In certain circumstances, EEA Individuals have the right to withdraw their consent to our processing of their personal data.  However, withdrawal of consent will not affect the lawfulness of any processing that had been carried out before consent is withdrawn.  Moreover, if we rely on another legal basis (e.g., performance of a contract or legitimate interest) to process your personal data, we may continue to process your personal data in accordance with such other legal basis even after you withdraw your consent.  If you decide to withdraw your consent, we may not be able to provide our Services to you.

INTERNATIONAL DATA TRANSFERS

We are based in the United States and our computer servers are located in the United States.  Accordingly, all personal data in our possession and control is collected and processed by us in the United States.  Any party that provides personal data to us is thereby transferring such data to the United States and is consenting to the transfer of their personal data to the United States.  Individuals who access the Website from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.

UPDATES TO THIS PRIVACY NOTICE

We reserve the right, at any time, to modify or update this Privacy Notice.  Any such modifications or updates will be effective upon posting.  You are responsible for checking the Website for any updates to this Privacy Notice.  If we modify this Privacy Notice, your continued use of the Website will signify your acceptance of the modified Privacy Notice.

QUESTIONS OR CONCERNS

We will happily address any questions or concerns about our Privacy Notice or about our processing of your personal data. Contact us at legal@careergroupcompanies.com. Our mailing address is below:

Career Group Inc.
10100 Santa Monica Boulevard, Suite 900
Los Angeles, CA 90067