Data Privacy Framework Statement

 

Effective Date: September 18, 2023

TalentKeepers complies with the EU-U.S. Data Privacy Framework (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.  TalentKeepers 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.  TalentKeepers 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, the Principles shall govern.  To learn more about theData Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, TalentKeepers is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

TalentKeepers receives personal data which may include name, email address, gender, age and employee identification numbers from client organizations. These data are used to process employee surveys, perform analysis of these data, and generate reports of the survey results. This information is only provided to the client organization which originally provided the personal data. For more information regarding our data handling practices, please refer to our main Privacy Policy.

Pursuant to the Data Privacy Frameworks, EU, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacyinquiries@talentkeepers.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, you may submit a written request to privacyinquiries@talentkeepers.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. TalentKeepers does not sell, trade, nor transfer personal Information with third parties. However, TalentKeepers’ accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Frameworks Principles. In particular, TalentKeepers remains responsible and liable under the Data Privacy Frameworks Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless TalentKeepers proves that it is not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), TalentKeepers commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF and the Swiss-U.S. DPF. EU and Swiss individuals with inquiries or complaints should first contact TalentKeepers at: privacyinquiries@talentkeepers.com.

TalentKeepers has further committed to refer unresolved DPF Principles-related complaints to a U.S.- based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbbprograms.org/dpf-complaints/ for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf