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CCPA (California Consumer Privacy Act) Notice

Privacy Policy for California Residents

This CCPA (California Consumer Privacy Act) Notice supplements the information contained in the Privacy Policy of Tahlent, Inc., (hereinafter referred to as "Swoop") and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected (Yes/No)

A.      Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Yes

B.      Personal information categories listed in the California Customer Records Statute

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes

C.       Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

D.      Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

E.       Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F.       Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

No

G.      Geolocation data.

Physical location or movements.

No

H.      Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I.        Professional or employment-related information.

Current or past job history or performance evaluations.

Yes

J.        Non-public education information (per the Family Educational Rights and Privacy Act)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Yes

K.      Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

We obtain the categories of ‘Personal Information’ listed above directly from our clients or their representatives through forms on our website.

Under CCPA (California Consumer Privacy Act ‘Personal Information’ does not include information that is publicly available (“Public Data”). Following are the approaches and principles that we adopt when dealing with Public Data. Our third-party service providers are also required to act in compliance with these principles;

General Approach to the Collection and Storage of Public Data. SwoopTalent scrapes data from various public data sources to combine into our aggregated set of public data. Typically, we create our own crawlers but in some instances use third party suppliers to gather data for us. The following sections explain the way we handle public data we scrape ourselves.

Principles

  1. Professional Data Only. Data is collected from identified sources of data (“source site/s”). We analyze each source site to determine whether each data point on a profile is professional or not. We then design and program our crawlers to gather only those data that are directly related to careers, skills and other professional attributes. Personal and non-professional data existing on source sites is ignored.
  2. Public Data Only. We collect only data specifically designated as public data. We do not use login access, API’s, credentials, front end browser scraping or any other form of “logged in” access to gather data, we gather only the same data that any search engine could gather - i.e., data collected is always visible to without login to the site. The public nature of these data is in the terms and conditions of each source site. If a record is public when we find it but is subsequently removed or changed to no longer be public, we remove the data which is no longer public. Data is public if it can be seen in a browser while there is no logged in user.
  3. Current Data Only. We make every effort to collect data as frequently as various source site and technical limits allow us to do so, in order to keep our data as current as possible. If a new version of a record removes data previously gathered, we also remove that data.

Third Party Suppliers. Where we use 3rd party suppliers to gather data for us, we require that they adhere to our principles on professional, public, current data, particularly that all data must be available without logging in to the site concerned. We do not require that our suppliers disclose their trade secrets to us, but we do regularly audit the provided data to ensure that it complies to those three key principles.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  1. To fulfill or meet the purpose for which the information is provided.
  2. To provide you with information, products or services that you request from us.
  3. To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  5. To improve our website and present its contents to you.
  6. For testing, research, analysis and product development.
  7. As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  9. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sharing of Personal Information

We would never disclose the ‘Personal Information’ submitted to us by our clients and customers through forms, on our website, to anyone.

In the preceding twelve (12) months, we have not disclosed any category of personal information mentioned in the CCPA (California Consumer Privacy Act).

Moreover, in the preceding twelve (12) months, ‘we have not sold’ any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your rights, applicable to our business, under CCPA;

  1. Data Portability Rights

You have the right to request that we provide to you, all the data that you have stored with us, in a readily useable, machine readable format, such that it can be used by competing services. We shall fulfill this request once we have received a verifiable consumer request.

  1. Deletion Request Rights

You have the right to request that we delete any of the personal information that you have submitted to us through forms, retained in our perpetual databases, for storage and processing. Once we receive and confirm your verifiable consumer request, we will delete your submitted personal information from our records and perpetual databases.

  1. Exercising Data Portability and Deletion Rights

To exercise the deletion rights described above, please submit a verifiable consumer request by emailing us at privacy@swooptalent.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  1. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If you have an account with us, we will deliver our written response to that account.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  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 verifiable consumer 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, 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 California law, please do not hesitate to contact us at privacy@swooptalent.com

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