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INTALENT.AI, INC.

PRIVACY POLICY

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Welcome to intalent.ai! Protecting your privacy is of utmost importance to us. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website and engage with our SaaS product offerings. By accepting the privacy notice at the bottom of the webpage, and accepting the terms of this Privacy Policy when registering and using our services on our website, you agree to the practices described in this policy.

We will post any changes to this Privacy Policy from time to time at the bottom of our website with a hyperlink to this Privacy Policy. Please regularly review this Privacy Policy. If you subscribe to our newsletter and/or share your email ID with us, we will also send you an email describing such changes to the Privacy Policy.

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1. INTRODUCTION

intalent.AI, Inc. (“intalent.AI,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use intalent.AI Platform (the “Platform”) through intalent.AI’s website at www.intalent.ai (the “Website”) or intalent.AI’s mobile application (the “App”). intalent.AI is inter-alia engaged in the business of assisting organizations in overcoming their most significant talent-related hurdles by harnessing the power of technology, data, and artificial intelligence (AI). 

intalent.AI is committed to protecting the privacy of its Users whose information is collected and stored while using intalent.AI’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.

The capitalized terms have the same meaning as ascribed in our Terms of Use as applicable, unless otherwise noted here.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT INFO@ INTALENT.AI.

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2. TERRITORIAL RESTRICTION

This Privacy Policy covers is applicable to users of the Platform from across the world except for such users who are residents of, visitors to, or are employee or candidates who reside in the European Union (“European”).

If you are a European, please read the EU Privacy Notice and agree to the terms when prompted to do so before you download, register, and/or use our Website, App, or Platform.

If you are a resident of the United States (“US”), the laws of the laws of the State where we are incorporated (Delaware), the state where we are headquartered (California, USA), and the state in which you live may apply.  If you are a resident of any other country, please ensure compliance with all local laws prior to using our Website, App, or Platform.  You must comply with this Privacy Policy and our Terms of Use. 

If you have any questions regarding this Section, please email us at info@intalent.ai

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3. WHAT INFORMATION DO WE COLLECT?

When you browse our Website, App or Platform, we may, subject to your consent, collect limited personal information such as your full name, job title, official email address, phone number with country code, company name and/or company website to connect with you and share marketing and product related information. By You are browsing the website we may may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details. This information is necessary to optimise our Website, App or Platform for you.

When you register to use our Website, App, or Platform as a candidate, we collect personal information (also referred to as personally identifiable information or “PII”) which may include but not limited to

  1. Identification Data

  2. Contact Information

  3. Demographic Data

  4. Data regarding responses to screening question

  5. Background Check information

  6. Previous employment information

  7. Data pertaining to work preferences and abilities

  8. Resume data

  9. Information on certain health conditions (only when required by law)

  10. Jobe interview notes

  11. Assessment results,

  12. Travel related records

The information so collected will be stored on our servers. You are able to change your personal information via email by contacting us at info@intalent.ai  or through your profile or account settings on our Website, App, or Platform. 

DISCLAIMER: We currently do not collect or store any credit cards or bank information, as we are using a third-party payment processor.  However, we will update this Privacy Policy when we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.

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4. HOW DO WE COLLECT INFORMATION?

 We collect personal information from you in the following ways:

 At registration on our Website, App, or Platform; 

  1. In email, text, and other electronic messages between you and our Website, App, or Platform;

  2. Through mobile and desktop applications your downloads from our Website, App, or Platform, which provides dedicated non-browser based interaction between you and our Website, App, or Platform; 

  3. When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy; 

  4. From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform;

  5. When you subscribe to a newsletter; 

  6. From your responses to a survey; 

  7. From forms filled out by you; 

  8. From records or copies of correspondences (including email addresses) if you contact us; 

  9. From search queries on our Website, App, or Platform; and

  10. When you post information to be published or displayed on our Website, App, or Platform. 

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

  1. Usage details; 

  2. IP addresses; 

  3. Information obtained through browser cookies; 

  4. Information obtained through flash cookies; 

  5. Web beacons on our Website; and

  6. Web beacons on emails sent by us;

 

5. HOW DO WE USE YOUR INFORMATION?

We use the information that you provide to:

  1. Personalize your experience in using our Platform; 

  2. Provide you with information, products, or services requested from us;

  3. Present our Website, App, and Platform and their contents to you;

  4. Provide you with notices about account and/or subscription, including expiration and renewal notices;

  5. Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection; 

  6. Notify you about changes to our Website, App, and Platform and any products or services; 

  7. Allow you to participate in interactive features on our Website, App, and Platform; 

  8. Improve the Website, App, and Platform; 

  9. Improve our customer service;

  10. Administer contests, promotions, and surveys or other Website, App, and Platform features; 

  11. Process transactions;

  12. Anonymize data and aggregate data for statistics;

  13. Contact you for other purposes with your consent;

  14. Contact you about our products and services that may be of interest; 

  15. Contact you about third parties’ goods and services; 

  16. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent; and

  17. Facilitate the recruiting process for the hiring company.

  18. Set up and maintain candidate profiles.

  19. Conduct assessments and organize interviews.

  20. Manage travel or expense reimbursements related to the hiring process.

  21. Comply with applicable legal and regulatory requirements.

  22. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 14, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred. 

 

6. OUR COOKIE POLICY 

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.” 

We use Cookies on our Website and App to (a) help remember and process items in the shopping cart, (b) understand and save your preferences for future visits, (c) keep track of advertisements, (d) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (e) allow trusted third-party services that track this information on our behalf.  You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising. 

We allow third party behavioral tracking and links to third-party web pages.  Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform.  These third-party sites have separate and independent privacy policies.  We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites.  Please contact us at info@intalent.ai 

 

7. HOW DO WE PROTECT INFORMATION WE COLLECT?

Our Website and App are reasonably scanned to meet or exceed PCI Compliance and we are ISO 27001 Compliant. Our Website and App receive regular security scans and penetration tests.  Our Website and App also receive regular malware scans.  In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers.  We accept payment by credit card through a third party credit card processor on our behalf.  We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.  

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8. DATA SECURITY MEASURES.

  1. Security Measures.  We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.  The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform. 

Fair Information Practice Principles.  In the event of a personal data breach, we will notify you within fifteen (15) days via (i) email and/or (ii) our Platform notification system on our Website and/or App.  We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.​

 

9. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us may be shared by Intalent.AI with others to enable us to provide you over Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Intalent.AI may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information: 

Disclosure of Personal Information. 

  1. We may share your Personal Information with the company to which you are applying, as the data controller.

  2. We will share your personal information with affiliated entities for platform operations, data hosting, and IT support.

  3. We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.   

  4. We may disclose personal information to our subsidiaries and affiliates.

  5. We may disclose personal information to contractors, services providers, and other third parties. 

  6. We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.

  7. We may disclose personal information in the event of a merger, sale of business, etc.

  8. We may disclose to third parties to market their products and services to you if you have either consented or not opted out of these disclosures. 

  9. We may disclose personal information to third parties to market their products and services if you have either consented or not opted out of these disclosures. 

  10. We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners. 

  11. We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.

  12. We may disclose personal information for any other purpose for which you have provided it.

  13. We may only disclose personal information as described in this Privacy Policy or your consent.  

Other Disclosure of Personal Information. 

  1. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Intalent.AI our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Intalent.AI, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third Party Disclosure.

We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice.  This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.  

Choices Users Have About How Intalent.AI Uses and Discloses Information. 

  1. Tracking Technologies and Advertising. You can set your browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or function properly. 

  2. Disclosure of Users’ Information for Third-Party Advertising.  Users can opt-out by (i) checking the relevant form when we collect the data; (ii) logging into the Website, App, or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at info@intalent.ai . Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Intalent.AI for product purchases, warranty registration, or other transactions.    

  3. Disclosure of User’s Information for Targeted Advertising.  Users can opt-out by (i) checking the relevant form when we collect the data, (ii) logging into the Website, App, or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at info@intalent.ai .

 

10. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

Retention periods depend on the policies of the hiring company. Typically:

  1. If hired, your data will be transferred to the company’s employee records and retained as per their policies.

  2. If not hired, data will generally be retained for a limited period for recordkeeping, legal compliance, or future hiring considerations (if consent is provided).

Where consent is given, data may be retained for up to three years for potential job opportunities, or as otherwise specified.

 

11. GOOGLE ADSENSE AND GOOGLE ANALYTICS

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google-partners. 

We have implemented advertising features on our Website, App, and Platform including: (a) remarketing with Google AdSense; (b) Google Display Network Impression Reporting; (c) Google Demographics and Interests Reporting; and (d) Google’s Double Click platform integration.  

We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App. 

 

12. OTHER PRIVACY RIGHTS

  1. Right to Request Personal Information. Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we sell your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. We require such Personal Information to be able to provide to you, our Services. Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.

  2. Disclosure of Personal Information. We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.

  3. Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.

  4. For California residents:

    1. Intalent.AI does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h).  Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to info@intalent.ai  or write us at Intalent.AI, Inc., 108 W. 13th Street, New Castle County, Wilmington, Delaware USA 19802. Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at info@intalent.ai or write us at Intalent.AI, Inc., 108 W. 13th Street, New Castle County, Wilmington, Delaware USA 19802.

    2. CPRA. This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Privacy Rights Act that is effective from January 1, 2023 (“CPRA”) and any terms defined in the CPRA have the same meaning when used in this Section. 

    3. Non-Discrimination Right. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, 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.

    1. Financial Incentives. However, we may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

  1. Under 16. We will not sell your Personal Information of any Users, including any persons under the age of 16.

  2. Opt In Consent.  We will only process, collect, use and store your Personal Information upon receiving your express consent to do so. YOU EXPRESSLY AGREE THAT YOU HAVE READ, UNDERSTOOD, AND CONSENT TO US COLLECTING, USING, PROCESSING, DISCLOSING, STORING, AND RETAINING YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, OUR TERMS OF SERVICE, AND OUR TERMS OF USE WHEN YOU CHECK THE APPLICABLE BOX SIGNIFYING YOUR CONSENT. YOU EXPRESSLY AGREE THAT THIS CONSENT IS FREELY GIVEN, EXPRESS, AND AFFIRMATIVE.  

  3. Right to Opt-Out. At any time, upon your request, we will stop selling your Personal Information (sometimes called your Opt Out-Right). You may send the request to Opt Out (i) to info@intalent.ai , or (ii) by writing to us at Privacy Officer, Intalent.AI, Inc., 108 W. 13th Street, New Castle County, Wilmington, Delaware USA 19802.

  4. Data Protection Officer.  We have appointed a Privacy and Data Protection Officer, Avinash Kohli at avi.kohli@intalent.ai  to make sure the privacy rights of our Users are protected.

 

13. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at info@intalent.ai .

IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM. 

 

14. CAN-SPAM ACT OF 2003 

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations.  Per the CAN-SPAM Act, we will:

  1. not use false or misleading subjects or email addresses; 

  2. identify the email message as an advertisement in some reasonable way; 

  3. include the physical address of Intalent.AI, Inc. which is 108 W. 13th Street, New Castle County, Wilmington, Delaware USA 19802; 

  4. monitor third-party email marketing services for compliance, if one is used;

  5. honor opt-out/unsubscribe requests quickly; and

  6. give an “opt-out” or “unsubscribe” option.    

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at info@intalent.ai  and we will promptly remove you from all future marketing correspondences.

 

15. LIST OF THIRD-PARTY SERVICE PROVIDERS

Intalent.AI, uses the following third-party service provider for the provision of services as detailed under the Terms of Use, as applicable

S.No.

Name of the Entity

Details of the entity

Purpose for Disclosure

  1.  

Okta 

Website: https://www.okta.com/

Address: Okta HQ North America, 100 First Street, San Francisco, CA 94105, US

 

Okta is engaged by Intalent.AI to authenticate the identity of the users loging into the platform.

Additionally, if you have any questions or concerns about our third-party service providers, please email us at info@intalent.ai . 

 

16. COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent. 

  1. Your physical or electronic signature;

  2. Identification of the copyrighted work(s) that you claim to have been infringed;

  3. Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove;

  4. Sufficient information to permit us to locate such material;

  5. Your address, telephone number, and email address;

  6. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and

  7. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

Intalent.AI’s Copyright Agent to receive DMCA Takedown Notices is Avinash Kohli, at avi @intalent.ai and at Intalent.AI, Inc. Attn: DMCA Notice, 108 W. 13th Street, New Castle County, Wilmington, Delaware USA 19802. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Intalent.AI in connection with the written notification and allegation of copyright infringement. 

 

17. ANTI-BRIBERY COMPLIANCE

Intalent.AI’ represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws.  Intalent.AI represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an “Official”).  Intalent.AI further represents and warrants that, to its knowledge, neither it nor any of the Officials has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving Intalent.AI, or (B) the obtaining or retention of business by Intalent.AI.  Intalent.AI further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Officials.  

 

18. CONTACT US 

Contact Information. You may contact us (i) at avi@intalent.ai , or (ii) by writing to us at Privacy Officer, at Intalent.AI, Inc., 108 W. 13th Street, New Castle County, Wilmington, Delaware USA 19802. to (i) make a Personal Information Request, (ii) lodge a complaint about our use or storage of your Personal Information, (iii) ask us to delete such Personal Information, and/or (iv) discuss our Privacy Policy and/or anything that has to do with it. We will respond within forty-five (45) days of receiving such request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

 

EMPLOYEE SECTION

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1. INTRODUCTION

This Employee Privacy Policy Statement (the “Employee Privacy Statement”) contains the policies, procedures and practices to be followed by Intalent.AI, Inc. and any of its present or future subsidiaries (the “Company”) pertaining to the collection, use and disclosure of personal information (the “Personal Information”) of an identifiable person (the “Individual”) that is a present, future or former employee of the Company.

The Company recognizes the confidential nature of the Personal Information in its care and is accountable for the compliance of itself and its directors, officers, management, employees, representatives and agents including consultants and independent contractors (the “Staff”) in protecting this Personal Information.

For the purpose of this Employee Privacy Statement, the term “Personal Information” has the meaning of any information or collection of information in any form, whether oral, electronic or written that pertains to the Individual excluding information that is publicly available in its entirety. Personal Information will also include any publicly available information that is combined with non-publicly available information.

Personal Information includes but is not limited to name, home address, home phone number, home email address, identity verification information, Social Security Number, physical description, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, credit history, contents of resume, references, interview notes, performance review notes and emergency contact information.

Personal Information will not include the Individual's business title, and business address and contact information when used or disclosed for the purposes of reasonable business communication.

The Company will implement policies and procedures that give effect to this Employee Privacy Statement including procedures to protect and secure Personal Information, procedures to receive, investigate and resolve complaints, procedures to ensure adequate training of the Staff concerning the Company's privacy policies, and procedures to distribute new and current information pertaining to the Company's Employee Privacy Statement.

 

2. CORPORATE EMPLOYEE PRIVACY STATEMENT

The Company and the Staff will at all times respect the confidentiality of the Personal Information placed in its care. The Company will endeavor to ensure that the policies affecting the collection, storage and disclosure of Personal Information reflect the confidential nature of the information.

The Company will comply with all applicable privacy legislation and regulations in force now and in the future related to protecting the confidentiality of Personal Information.

 

3. PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED

Personal Information will be collected, used and disclosed for purposes pertaining to the Individual's employment relationship with the Company, including but not limited to the administration of employee hiring, performance reviews, the administration of employee payroll, processing of employee benefit claims, and for the purpose of complying with all applicable labor and employment legislation.

The purposes for collecting Personal Information will be documented by the Company. Personal Information will only be used for the stated purpose or purposes for which it was originally collected. The purposes for which Personal Information is being collected will be identified orally or in writing to the Individual before it is collected. The person collecting the information will be able to explain the purpose at the time that the information is collected.

The Company may use Personal Information for a purpose other than the originally stated purpose where the new purpose is required by law or where the Company has obtained consent in writing from the affected Individual for each new purpose.

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4. KNOWLEDGE AND CONSENT

Knowledge and consent are required from the affected Individual for the collection, use and disclosure of all Personal Information subject to exceptions noted elsewhere in the Employee Privacy Statement.

Consent will not be obtained through deception or misrepresentation.

Any use or disclosure of Personal Information will be within the reasonable expectations of the Individual.

Subject to legal and contractual obligations, an Individual may withdraw their consent on reasonable notice.

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5. LEGISLATION AND REGULATION

Where the Company has Individuals living and working in different jurisdictions the specific rights and obligations of Individuals may vary between jurisdictions.

The Company is subject to the privacy legislation in all jurisdictions in which the Company operates. If any term, covenant, condition or provision of this Employee Privacy Statement is held by a court of competent jurisdiction to be invalid, void or unenforceable, it is the intent of this Employee Privacy Statement that the scope of the rights and obligations of the Employee Privacy Statement be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Employee Privacy Statement will in no way be affected, impaired or invalidated as a result.

Where this Employee Privacy Statement provides greater rights and protections to the Individual than the available governing law, the terms of this Employee Privacy Statement will prevail wherever allowed by law.

 

6. SCOPE AND APPLICATION

The rights and obligations described in this Employee Privacy Statement will apply to all Individuals. The Company and the Staff must comply with the policies, procedures and practices described in the Employee Privacy Statement.

 

7. COLLECTION OF PERSONAL INFORMATION

The type and amount of Personal Information collected by the Company will be limited to the minimum necessary to accomplish reasonable business purposes. Personal Information will not be collected maliciously, indiscriminately or without a reasonable business purpose.

Personal Information will be collected using fair and lawful means.

 

8. ACCESS BY AUTHORIZED COMPANY REPRESENTATIVES

All Personal Information will be released internally only on a need-to-know basis. In the course of normal and reasonable business practices it is the policy of the Company to grant designated Company representatives access to Personal Information files. This access will not exceed that necessary to accomplish the specific business function of the Company representative nor the purpose for which the information was originally collected.

Accuracy of Personal Information

The Company will endeavor to ensure that all Personal Information collected is accurate and validated using reasonable business practices and procedures. The Company is also committed to ensuring that the Personal Information remains accurate for the purpose for which it was collected.

Rights of Access and Correction

The Company will make reasonable efforts to ensure that Personal Information is at all times complete and accurate for its stated purpose.

An Individual may apply for access to their Personal Information by submitting a request in writing along with adequate proof of identity to an authorized personnel officer. Where the application is made in person the requirement for proof of identity will be at the discretion of the personnel officer. The Individual will be provided with a copy of all available information that is not subject to restriction as described in this Employee Privacy Statement. All Personal Information and Medical Information will be provided at no cost or at a minimal cost that is not prohibitive.

The Company will also provide a specific summary of how the Personal Information has been used and to whom it has been disclosed. Where a detailed account of disclosure is not available, the Company will provide a list of organizations to which the Personal Information may have been disclosed.

The Personal Information disclosed to an Individual must be in a form that is reasonable and understandable. Where the meaning of information is not clear then translations and explanations will be provided without additional cost.

Where an Individual suspects that an error exists in their Personal Information, the Individual may submit a request in writing for correction. This request should include any relevant information substantiating the error and should describe the correction to be made. The Company will make all reasonable efforts to address any request for correction.

Where the Individual successfully demonstrates an error in their Personal Information the Company will make appropriate corrections. Any modifications, additions or deletions to the Individual's Personal Information will be made only by an authorized personnel officer.

Where a request for correction is not successful, the details and substantiating evidence of the request will be recorded and retained by the Company.

The Company will endeavor to respond promptly to any reasonable request for disclosure and correction made by an Individual to ensure the continued accuracy of Personal Information.

In some instances the Company may be required to limit access to Personal Information because of statutory or regulatory requirements. In all instances however the Company will make all reasonable efforts to comply with the Individual's request for access and correction to the extent of what is allowed by statute or regulation.

The Company may refuse access to portions of the Personal Information of an Individual where it is found to contain Personal Information pertaining to another Individual.

 

9. USE AND DISCLOSURE OF PERSONAL INFORMATION

The Company and the Staff will keep confidential all Personal Information in its control except where one or more of the following conditions apply:

  1. where the Individual who is the subject of disclosure has provided written consent;

  2. where the disclosure is in accord with the purposes for which the Personal Information was originally collected;

  3. where the disclosure is for the purpose of providing employment references to prospective employers and where the Personal Information disclosed is limited to information considered reasonably necessary for the purpose of providing employment references;

  4. where the Company is permitted or required to do so by applicable legislation or regulation;

  5. where the disclosure is directed to health benefit providers and where the purpose of the disclosure is in accord with the purposes for which the Personal Information was originally collected;

  6. where the disclosure is required by authorized government representatives who are acting to enforce any federal or state law or carrying out an investigation relating to the enforcement of any federal or state law or gathering information for the purpose of enforcing any federal or state law;

  7. where the Company is required to comply with valid court orders, warrants or subpoenas or other valid legal processes and

  8. in an emergency to protect the physical safety of any person or group of persons.

 

10. OWNERSHIP OF PERSONAL INFORMATION

All Personal Information collected by the Company in compliance with this Employee Privacy Statement are business records of the Company.

 

11. RETENTION AND DISPOSAL OF PERSONAL INFORMATION

Any Personal Information collected by the Company will be retained by the Company during the period of active employment of the Individual as well as during the post-employment period only as long as the Personal Information is required to serve its original purpose or as directed by applicable legislation or regulation.

Personal Information that is no longer needed for its stated purpose will be destroyed, erased or made anonymous.

The Company will ensure that all practices and procedures relating to the disposal of Personal Information will respect the fundamental policy of confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, will ensure the complete destruction of Personal Information so that there will be no risk of subsequent unauthorized disclosure of Personal Information.

Deceased Individuals

The rights and protections of the Company's Privacy Policies will extend to deceased Individuals.

 

12. SECURITY

The Company will take and enforce all reasonable security measures appropriate for the sensitivity of the information to ensure that all Personal Information for every Individual is protected against any form of unauthorized use including but not limited to accidental or malicious disclosure, unauthorized access, unauthorized modification, unauthorized duplication or theft.

Methods of security will include but not be limited to the following:

  1. physical security including locked filing cabinets and secure-access offices;

  2. organizational security including security clearances and access limited on a “need-to-know” basis and

  3. technological security including passwords and encryption.

The Company will educate and inform all Staff regarding the Employee Privacy Statement and related procedures and on the importance of confidentiality of Personal Information and will monitor compliance with the Employee Privacy Statement and may observe and investigate the information management practices of all Staff having care of Personal Information.

 

13. KNOWLEDGE OF UNAUTHORIZED DISCLOSURE

Responsibility for the security of Personal Information is a responsibility that the Company holds in very serious regard. Any Staff having knowledge of an impending unauthorized disclosure, whether intentional or unintentional, and who fail to act to prevent the unauthorized breach will be subject to sanction as described in the Enforcement section of this document including the immediate dismissal of the offending Staff.

 

14. ENFORCEMENT

All Staff having care over Personal Information must comply with the policies, procedures and practices described in the Employee Privacy Statement. Any breach of any term or condition of this Employee Privacy Statement, whether intentional or unintentional, including but not limited to the unauthorized disclosure of Personal Information is grounds for disciplinary action up to and including the immediate dismissal of any and all responsible Staff. Any breach of any term or condition of this Employee Privacy Statement, whether intentional or unintentional, is grounds for dismissal with cause.

 

15. COMPLIANCE WITH EMPLOYEE PRIVACY STATEMENT

The Company will have a procedure that will allow Individuals to challenge the Company's compliance with this Employee Privacy Statement. The Company will also have procedures to promptly respond to Employee Privacy Statement compliance challenges.

The Company will make all reasonable efforts to investigate and respond to compliance challenges relating to this Employee Privacy Statement. Where a challenge is well founded the Company will take action to correct any outstanding problems up to and including amending the Employee Privacy Statement and related procedures.

 

16. ARBITRATION

In the event a dispute arises out of or in connection with this Employee Privacy Statement, the parties will first attempt to resolve the dispute through friendly consultation.

If the dispute is not resolved within a reasonable period then any or all outstanding issues may be submitted to final and binding arbitration in accordance with the laws of the State of Delaware. The arbitrator's award will be final, and judgment may be entered upon it by any court having jurisdiction within the State of Delaware.

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