www.frankgroup.com
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Submitted URL: http://links.masonfrank.com/ls/click?upn=Hx2cFrmhkOxz9pQuxrgT9RFI88U9SgwFVSPsnvXSWHITNJ5gwMG787hnMmshGFVue-2BJEQPYhrDdAyk0Kl...
Effective URL: https://www.frankgroup.com/privacy-notice/
Submission: On October 12 via api from US — Scanned from DE
Effective URL: https://www.frankgroup.com/privacy-notice/
Submission: On October 12 via api from US — Scanned from DE
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<h4>Option 1: Submit a Web Form Request</h4>
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<td colspan="2" class="affirm-and-submit"> By clicking "Affirm & Submit" you affirm the information above is accurate and acknowledge that we may need to verify your identity and your state of residence to determine if we can fulfill
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<b><span id="ccpa_error" style="display: none">Error:
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<b><span id="ccpa_success" style="display: none; background-color:#9df2a8; font-style:italic;color:black;">You
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<br>
<h4>Option 2: Call Toll Free</h4> Or call us toll free at <a href="tel:18664678688">1-866-I-OPT-OUT</a> (1-866-467-8688) and enter Service Code 717#. <br>
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<h6 style="padding: 15px 0 0; margin: 0; text-align:
left; font-style: italic; font-weight: 400;">Privacy request management by <a href="https://www.ccpatollfree.com">CCPAtollfree.com</a></h6>
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</form>Text Content
* Home
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Blog
* Tech’s Leading Women – Video Series
* Ep 1 – The new hybrid workplace
* Ep 2 – Are we looking in the right place for talent?
* Ep 3 – Nurturing the missing middle
* Ep 4 – The role of the CEO
* Ep 5 – Allyship
* Ep 6 – Dame Stephanie Shirley, CH
* Contact
* Join us
Menu
* Home
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Blog
* Tech’s Leading Women – Video Series
* Ep 1 – The new hybrid workplace
* Ep 2 – Are we looking in the right place for talent?
* Ep 3 – Nurturing the missing middle
* Ep 4 – The role of the CEO
* Ep 5 – Allyship
* Ep 6 – Dame Stephanie Shirley, CH
* Contact
* Join us
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Tech’s Leading Women
* Episode one – The new hybrid workplace
* Episode two – Are we looking in the right place for talent?
* Episode three – Nurturing the missing middle
* Episode four – The role of the CEO
* Episode five – Allyship
* Episode six – Dame Stephanie Shirley, CH
* Blog
* Contact
Menu
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Tech’s Leading Women
* Episode one – The new hybrid workplace
* Episode two – Are we looking in the right place for talent?
* Episode three – Nurturing the missing middle
* Episode four – The role of the CEO
* Episode five – Allyship
* Episode six – Dame Stephanie Shirley, CH
* Blog
* Contact
Join us
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* EN
* Home
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Blog
* Tech’s Leading Women – Video Series
* Ep 1 – The new hybrid workplace
* Ep 2 – Are we looking in the right place for talent?
* Ep 3 – Nurturing the missing middle
* Ep 4 – The role of the CEO
* Ep 5 – Allyship
* Ep 6 – Dame Stephanie Shirley, CH
* Contact
* Join us
Menu
* Home
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Blog
* Tech’s Leading Women – Video Series
* Ep 1 – The new hybrid workplace
* Ep 2 – Are we looking in the right place for talent?
* Ep 3 – Nurturing the missing middle
* Ep 4 – The role of the CEO
* Ep 5 – Allyship
* Ep 6 – Dame Stephanie Shirley, CH
* Contact
* Join us
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Tech’s Leading Women
* Episode one – The new hybrid workplace
* Episode two – Are we looking in the right place for talent?
* Episode three – Nurturing the missing middle
* Episode four – The role of the CEO
* Episode five – Allyship
* Episode six – Dame Stephanie Shirley, CH
* Blog
* Contact
Menu
* About
* Our people
* Our brands
* Our story
* Our values
* Services
* Permanent Recruitment
* Contract Recruitment
* Salary benchmarking
* Candidate Search
* Equality, diversity, and inclusion
* Women in Tech
* Talent creation and reskilling
* Sustainability
* Insights
* News and media
* Tech’s Leading Women
* Episode one – The new hybrid workplace
* Episode two – Are we looking in the right place for talent?
* Episode three – Nurturing the missing middle
* Episode four – The role of the CEO
* Episode five – Allyship
* Episode six – Dame Stephanie Shirley, CH
* Blog
* Contact
Join us
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PRIVACY NOTICE
EFFECTIVE DATE: 13TH SEPTEMBER, 2022
I. INTRODUCTION
Your privacy is important. This Privacy Notice (the “Privacy Notice,”) together
with its addendums, our Terms of Use and any other documents referred to in this
Privacy Notice or the Terms of Use explains how we comply with applicable
privacy requirements and sets out minimum standards for how we deal with all
personal data that we collect from you, or that you provide to us including via
this website and any other websites or applications of Frank Recruitment Group
Services Limited and its affiliates (collectively, the “Websites”). Frank
Recruitment Group Services Limited and our affiliates (collectively, “we,” “us,”
“our,” or “FRG”) include Nigel Frank International Limited, Mason Frank
International Limited, Frank Recruitment Group UK Services Limited, Frank
Recruitment Group Services USA Ltd., Rebura Limited (“Rebura”), Frank
Recruitment Group Inc., Frank Recruitment Group Services Inc., Frank Recruitment
Group Private Limited (Singapore), Frank Consulting Services Private Limited
(Singapore), Frank Recruitment Group Pty Limited (Australia), Frank Recruitment
Group GmbH (Germany), Frank Recruitment Group K.K. (Japan), Frank Recruitment
Group Sp Zo.o. (Poland), Frank Recruitment Group Poland Sp Zo.o. (Poland), Frank
Recruitment Group BV (Netherlands), Frank Recruitment Group S.L. (Spain), Frank
Consulting Services S.L. (Spain), Frank Recruitment Group Sarl (Switzerland),
Frank Recruitment Group Inc. /Groupe de Recrutement Frank Inc. (Canada), Frank
Consulting Services SAS (France), Frank Recruitment Group SRL (Italy), and
businesses operated by our group under the brand names including Nigel Frank,
Mason Frank, Nelson Frank, Jefferson Frank, The Revolent Group, The Tenth
Revolution Group, Anderson Frank, Washington Frank, FRG Technology Consulting,
Rebura, Digital Revolution Awards, and Dynamic Jobs.
This Privacy Notice sets out the basis on which we collect, store, use and
disclose personal data we receive in writing, through our Websites, through the
awards’ contests we hold, through the consulting services that Rebura provides
or through the recruitment services that we provide. It therefore applies to
personal data that you provide to FRG telephonically, electronically (including
email) and in person.
This information may be updated from time to time, and should be read in the
context of any additional specific information such as that provided in privacy
policies applicable to specific businesses or local areas as displayed on the
relevant Website or distributed to you from time to time.
This Privacy Notice also informs you how we obtain and use information gained by
us through your use of the Websites, including by using “cookies” and third
party vendors.
Please read the following carefully to understand our views and practices
regarding your personal data, how we will treat it and your rights.
This Privacy Notice applies to FRG globally. The first part of the policy is
general and applies globally. The second of the Privacy Notice is comprised of
country-specific addendums, and where applicable, FRG will handle Personal Data
relying on certain exemptions under local law. Please be sure to check the
addendums below to see if there is one that applies to your country or local
jurisdiction. In the event of a conflict between the general part of this
Privacy Notice and an addendum, the addendum prevails.
II. WHO ARE WE?
FRG is a global niche technology recruitment company that operates under the
brands listed above. FRG offers recruitment services for permanent hiring and
contract or temporary services.
Digital Revolution Awards is a brand operating under Frank Recruitment Group
Services Limited to provide awards competitions to celebrate the very best
individuals and businesses in the cloud ecosystem in order to recognise the
power of the cloud to digitally transform our world; to help us live better and
achieve more.
Rebura is a brand that provides AWS consulting services.
If you want to contact FRG or any of its group companies, please click here.
You can contact FRG’s Chief Privacy Officer (“CPO”) by
emailing privacy@tenthrevolution.com or by sending written correspondences here:
Frank Recruitment Group Services Limited
The St. Nicholas Building
St. Nicholas Street
Newcastle-Upon-Tyne
Tyne & Wear U.K. NE1 1RF
Attn: Chief Privacy Officer
III. WHO DOES THIS PRIVACY NOTICE PROTECT?
This Privacy Notice protects individuals throughout the world who access our
Websites or receive recruitment services, AWS consulting services, or
participate in awards competitions from us. In addition to candidates who are
looking for a new or different job or career, this also includes individuals who
are employed by an actual, former or prospective FRG client. An FRG “client” is
one of (a) a business that FRG has contracted with to provide recruitment or AWS
consulting services or is in the process of doing so, (b) a business that FRG
may solicit with the intention of providing recruitment or AWS consulting
services or (c) a business to whom FRG may provide relevant IT market
information. Additionally, FRG acts as the data controller for Personal Data (as
defined below) obtained concerning those protected under this Section III.
Notwithstanding the forgoing, Rebura and/or Rebura Limited acts as the data
processor for Personal Data (as defined below) obtained concerning those
protected under this Section III during the provision of AWS consulting
services.
IV. WHAT INFORMATION WILL WE COLLECT?
Some of the data that we collect and receive from you is personal data which
means that it is information that could personally identify you (“Personal Data”
or “PII”). The Personal Data that we may collect from all users of our Websites
and users of our recruitment services may include any of the following:
* Your name;
* Your gender;
* Contact details e.g. street address, email address, cell (or mobile) or home
telephone numbers;
* Work Experience;
* Job Title;
* Professional Certifications;
* Education & Qualifications;
* Skills;
* Career History;
* Salary Range;
* Right to work status \ citizenship;
* Other information relevant to help us provide recruitment services;
* References from past employers; and
* IP address
1. For Contract Candidates Only (individuals who are employed by, consult with
and/or own an entity recruited by FRG to provide contract or temporary
technical professional services to an FRG client (or an FRG client’s
client))
In addition to the Personal Data listed above, FRG may collect the following
from you:
* Tax details and proof of payment and submission;
* Commercial insurance information; and
* Bank and payment details.
While this information may relate to your company or your employer rather than
being your Personal Data, we have listed this information for transparency.
If your provision of Personal Data to FRG is necessary to enter into a contract
with your company or your employer, your failure to provide us with accurate
Personal Data may result in FRG not being able to offer or render recruitment
services to you, your company or your employer.
V. WHY DO WE PROCESS YOUR PERSONAL DATA?
Generally, we use your Personal Data for our business and activities, and in our
efforts to expand and improve our business. Examples include:
1. All users of the Websites and/or our services
* To provide our recruitment services to you, your employer or your company;
* To facilitate the recruitment process, including but not limited to:
*
* * Qualifying and submitting candidates;
* For clients, negotiating FRG terms of business;
* Arranging interviews and obtaining feedback;
* Negotiating compensation packages; and
* Providing post placement follow up.
* Where permitted by applicable law and unless you tell us otherwise, we (or a
third party to whom we have provided your Personal Data under part VI below
of this Privacy Notice) may send you emails, SMS messages, or text messages
(standard SMS or text message rates may apply);
* To assess data about you against vacancies which we judge may be suitable for
you;
* To enable you to submit your CV/resume to FRG, apply online (including
through the Websites) for jobs or to subscribe to alerts about jobs we think
may be of interest to you;
* To enable us to develop and market other products and services and where you
have consented to being contacted for such purposes;
* To improve our customer service and to make our services more valuable to you
(including tailoring the Websites when you log on to enrich your personal
online experience);
* To send you electronically or by post surveys, reports, FRG event details,
promotions, offers, networking and client events and general information
about relevant industry sectors which we think might be of interest to you,
where you have consented to being contacted for such purposes (and we will
provide you with an opportunity to opt out);
* To identify you, and respond to and process your requests for information and
provide you with a product or service;
* To amend records to remove personal information;
* To use your information on an pseudonymized basis to monitor compliance with
our equal opportunities policy, other FRG policies and any legal or
compliance requirements;
* To use your information on an pseudonymized basis to create marketing
materials such as a salary survey; and
* To carry out our obligations arising from any contracts entered into between
you and us, and for other everyday business purposes that involve use of
Personal Data.
1.
Actual or Prospective Candidates
* To help find you or your company a job;
* To contact you (permanent hire candidates), your employer or your company
(contract candidates) about jobs that FRG is filling or may fill for FRG
clients;
* To provide you or your company with information about the job market;
* To communicate with you (permanent hire candidates), your employer or your
company (contract candidates) after you or it has started a job to make sure
all is going well or to remedy, or attempt to remedy, any problems;
* To answer any questions you have about a job or the job market;
* To fulfill any aspect of your employer’s or your company’s contract with FRG
(for contract candidates only);
* To collect any money due, or allegedly due, to FRG or any FRG client (or
FRG’s client’s client);
* To obtain or inquire about any property (including computers and confidential
business information) owned, or allegedly owned, by FRG or any FRG client (or
FRG’s client’s client);
* To determine if an FRG client or other entity (or their respective
affiliates) to whom FRG presented you has (a) employed you or (b) retained
you or any entity (i) that employed you or (ii) that retained you or (iii) in
which you have an financial interest;
* To establish, exercise or defend any legal claims; and
* To assist you (permanent hire candidates), your employer or your company
(contract candidates) if you are dissatisfied or dislike the job, or any
aspect of it.
1.
Individuals who work for FRG clients (i.e. a “client contact”)
* To fill an open vacancy at your company or employer;
* To contact you about candidates for jobs with whom FRG has a relationship;
* To provide you with information about the job market;
* To communicate with you after your company or employer has hired/retained an
FRG candidate to make sure all is going well and to remedy, or attempt to
remedy, any problems;
* To negotiate and fulfil any aspect of your company’s or employer’s contract
with FRG;
* To answer any questions you have about a job or a candidate or your company’s
or employer’s contract with FRG;
* To resolve any issue with the issuance, payment, collection or enforcement of
an FRG invoice;
* To collect any property owned by FRG or any FRG candidate;
* To establish, exercise or defend any legal claims.
1.
Individuals who participate in awards’ competitions
2. a) To provide our awards’ competition services to you;
3. b) To facilitate the awards’ competition process, including but not limited
to:
*
* * Publishing contest rules;
* Collecting, qualifying and submitting participants, contest applications,
judges, and winners;
* Facilitating the acceptance, rejection, or delivery of contest awards;
* Providing post award follow up.
1.
Entities or individuals who solicit or participate in AWS Consulting
* To contact you, your employer, or your company about AWS Consulting services
that Rebura provides, including but not limited to:
* optimisation,
* migration and enablement,
* monitoring and support,
* architecture review,
* audit and risk management,
* resource and professional services, and
* Amazon WorkSpaces implementation;
* To communicate with you, your employer, or your company after Rebura has
started a consultation to make sure all is going well or to remedy, or
attempt to remedy, any problems;
* To answer any questions you have about a consultation;
* To fulfill any aspect of your employer’s or your company’s contract with FRG;
* To collect any money due, or allegedly due, to FRG or any FRG client (or
FRG’s client’s client);
* To obtain or inquire about any property (including computers and confidential
business information) owned, or allegedly owned, by FRG or any FRG client (or
FRG’s client’s client); and
* To establish, exercise or defend any legal claims.
VI. WHO DO WE SEND YOUR PERSONAL DATA TO?
1. 1. 1. All users of the Websites and/or our services
* To third parties where we have retained them to provide services that
we or you have requested or that FRG clients have requested including
references, qualifications and background reference checking services
and to verify the details you have provided from third party sources.
* To third parties to provide data storage, CV/resume parsing, data
cleansing and marketing services to FRG where such third parties have
agreed to maintain the confidentiality of, and to protect, your
Personal Data in accordance with applicable law.
* To third parties to assist with credit control and payment management
* To third parties, regulatory or law enforcement agencies if we believe
in good faith that we are required by law to disclose it in connection
with the detection of crime, the collection of taxes or duties, in
order to comply with any applicable law or order of a court of
competent jurisdiction, in connection with legal proceedings or other
similar cause or circumstance.
* To FRG affiliates, whose locations can be found
at https://www.frankgroup.com/contact . These entities will process
your Personal Data in accordance with this Privacy Notice.
* In the event of a sale, merger, liquidation, receivership or transfer
of all or substantially all of the assets, or a controlling interest in
the equity, of FRG (or any of its group companies) provided that such
counterparty(ies) to any such transaction agrees to adhere to the terms
of this Privacy Notice (or a similar document) and applicable law.
1. Actual or Prospective Candidates
* To FRG clients in order for them to determine if you (permanent hire
candidate) or your company or employer (contract candidate) are or may
be qualified to fill a vacancy.
* To third parties that you authorize us to send your personal data to
such as “umbrella” companies, insurance brokers and insurance carriers;
* For contract candidates, to third parties under contract with FRG who
may serve as your employer or with whom your company may enter into a
contract;
* To third parties to determine if an FRG client or other entity (or
their respective affiliates) to whom FRG presented you has (a) employed
you or (b) retained you or any entity (i) that employed you or (ii)
that retained you or (iii) in which you have an financial interest.
1. Individuals who work for FRG clients (i.e. a client contact)
1) To candidates in the course of providing your company or employer with
recruiting services and to further the recruitment process.
* To third parties where we have retained them to provide services that
you have requested including candidate skill tests and other testing.
* To third parties to determine if an FRG client or other entity (or
their respective affiliates) to whom FRG presented a candidate has (a)
employed the candidate or (b) retained the candidate or any entity (i)
that employed the candidate or (ii) that retained the candidate or
(iii) in which the candidate has a financial interest.
VII. WHAT WILL FRG DO IF MY PERSONAL DATA IS BREACHED?
FRG has put in place reasonable technical, administrative and physical
safeguards intended to prevent a breach of your Personal Data. That being said,
FRG cannot guarantee that your Personal Data will not be breached.
A breach can take many forms, including, without limitation, the loss of your
Personal Data or the unauthorized access to, disclosure, modification, copying
and transfer of your Personal Data.
Once FRG becomes aware of the breach, FRG will take reasonable steps to isolate
the breach, stop the breach, determine the root cause, determine the Personal
Data breached, fix the root cause and determine if notice to you and/or the
appropriate government agency(ies) is required. FRG will comply with all
applicable law in reacting to, and dealing with, a breach of Personal Data.
If you believe, for any reason, that your Personal Data has been breached while
in FRG’s care, custody or control, please email FRG immediately
at privacy@tenthrevolution.com.
If FRG obtains your Personal Data from someone other than you, this Privacy
Notice includes all information required under applicable law except that FRG
shall not provide you with this information if you already possess this
information, providing you with such information is against (or not mandatory
under) applicable law, is subject to an obligation of professional secrecy,
proves impossible, would involve a disproportionate effort or would render
impossible or seriously impair the achievement of the objectives of the
processing, in which case, FRG shall take appropriate measures to protect your
rights, freedoms and legitimate interests. If you have any questions, please
contact FRG at privacy@tenthrevolution.com.
VIII. WILL MY PERSONAL DATA BE TRANSFERRED TO ANOTHER COUNTRY?
Yes, FRG may transfer your Personal Data to the categories of third parties
described in this Privacy Notice, some of whom are located outside of the
country in which you provided your Personal Data to FRG or the country of
collection.
If so, FRG will take reasonable steps to ensure that your Personal Data is
protected and treated in accordance with this Privacy Notice and local
applicable law. The countries where FRG may transfer your Personal Data will
have varying levels of data security practices and laws, some of which may be
less stringent or protective than your country. FRG will use all reasonable
efforts to require that any of its suppliers and vendors who receive your
Personal Data are contractually bound to (a) keep your Personal Data
confidential and (b) take, at a minimum, reasonable efforts to maintain the
privacy and security of your Personal Data.
Under certain circumstances, FRG may share your Personal Data with one or more
of its group companies who may be located in a country other than yours or other
than the country in which FRG collected your Personal Data. In such cases, FRG
will comply with applicable laws and its Intercompany Data Processing Agreements
(“DPAs”). The DPAs are incorporated by reference into this Privacy Notice.
IX. HOW LONG WILL FRG STORE MY PERSONAL DATA FOR?
We are required by applicable law to store your Personal Data for as long as is
necessary to comply with our legal, regulatory and contractual obligations.
This period of time will vary based on the law in your country and in the
country where FRG stores your Personal Data.
In addition, FRG will keep your Personal Data for the identified purposes until
it reasonably believes that it no longer needs it, that there is no reasonable
chance that you, your employer or your company will do business with FRG, and
there is no reason to believe that we will need the Personal Data for any
special circumstances such as the issuance or defence of legal proceedings,
audit, investigation or collections.
X. SENDING FRG PERSONAL DATA OVER THE INTERNET
Your Personal Data is held on servers hosted by us, our internet services
providers or third party vendors with whom FRG has a contract. The transmission
of information via the internet is not completely secure. Although we will take
the efforts set forth in the Privacy Notice to protect your Personal Data, we
cannot guarantee the security of any data transmitted through or to our
Websites. Any transmission of data by you to us over the internet is at your
own risk.
XI. HOW WE COLLECT AND AGGREGATE INFORMATION ABOUT VISITORS TO OUR WEBSITES
We also collect information about the way job seekers and visitors use the
Websites in order to improve our services, to understand our users better, and
to determine aggregate trends, most popular pages, etc. By using the Websites,
you agree that we may share de-identified aggregate data with selected third
parties to assist with these purposes. We may also undertake marketing profiling
to help us identify candidates, clients, or jobs which may be of interest to
you. We may process Personal Data that you submit to us through the Websites
under one or more of the permissible bases for processing Personal Data set
forth in the Privacy Notice.
XII. TECHNOLOGY AND TOOLS
Like many companies, we use technology and tools that tell us when a computer or
device has visited or accessed our content. Those tools include services from
search engines and other companies that help us to tailor our products and
services to better suit our customers and potential customers. Search engines
provide facilities to allow you to indicate your preferences in relation to the
use of those tools in connection with computers and other devices controlled or
used by you.
We also set out further information below about Cookies and Web Beacons.
1. What are cookies?
A “cookie” is a piece of information that is stored on your computer’s hard
drive and which records your navigation of a website so that, when you revisit
that website, it can present tailored options to you based upon the stored
information about your last visit. You can normally alter the settings of your
browser to prevent acceptance of cookies.
Cookies are used are many, many websites, including FRG’s Websites.
1. How do we use cookies and plug-ins?
We use “cookies” and plug ins to: (1) make the Websites function properly and as
a user would normally expect of a commercial website, (2) monitor Website user
traffic patterns and Website usage.; and (3) help us to advertise to you jobs we
think you, your company or your employer will be interested in. Our use of
these tools helps us to understand how our users use our Websites so that we can
develop and improve the design, layout and functionality of the Websites and to
provide more efficient and relevant services to you.
1. There are different kinds of cookies with different functions.
The cookies we use are explained below:
1. Session cookies: these are only stored on your computer during your web
session. They are automatically deleted when the browser is closed. They
usually store an anonymous session ID allowing you to browse a website
without having to log in to each page. They do not collect any information
from your computer.
2. Persistent cookies: a persistent cookie is one stored as a file on your
computer, and it remains there when you close your web browser. The cookie
can be read by the website that created it when you visit that website
again.
3. Strictly necessary cookies
These cookies are essential to enable you to use the Websites effectively
and therefore cannot be turned off. Without these cookies, the services
available to you on our Websites cannot be provided. These cookies do not
gather information about you that could be used for marketing or remembering
where you have been on the internet.
4. Performance cookies
These cookies enable us to monitor and improve the performance of our
Websites. For example they allow us to count visits, identify traffic
sources and see which parts of the Websites are most popular. These cookies
do not collect information that identifies a visitor, as all information
these cookies collect is anonymous and is only used to improve how our
Websites work.
5. Functionality cookies
These cookies allow our Websites to remember choices you make (such as your
user name, language or the region you are in) and provide enhanced features.
These cookies can also be used to remember changes you have made to text
size, font and other pages of our Websites that you can customise. They may
also be used to provide services you have requested such as viewing a video
or commenting on a blog.
6. Personalisation cookies
The FRG Websites use personalisation cookies to help us to advertise jobs that
we think may be of interest to you. These cookies are persistent and mean that
when you log in, or return to, the particular FRG Website, you may see
advertising for jobs that are similar to jobs that you have previously browsed.
For information on how to reject these personalisation cookies, see Section E
below
D. Cookies and Plug-ins set by FRG or Third Parties used by FRG
Below are tables listing the cookies that you may encounter on our Websites and
the purpose for which we use each one and the duration that the cookie remains
in place (unless you take action to reject the cookie). FRG may update these
tables from time to time. Most of the cookies on our Websites are set by third
parties. FRG works with several third parties to provide services which help us
to keep the Websites tailored to your needs. Some of these vendors use cookies
to help them deliver these services.
For our FRG Websites generally:
CookieDescriptionDurationTypePHPSESSIDThis cookie is native to PHP applications.
The cookie is used to store and identify a users’ unique session ID for the
purpose of managing user session on the website. The cookie is a session cookies
and is deleted when all the browser windows are closed. Necessary_gaThis cookie
is installed by Google Analytics. The cookie is used to calculate visitor,
session, campaign data and keep track of site usage for the site’s analytics
report. The cookies store information anonymously and assign a randomly
generated number to identify unique visitors.2 yearsAnalytics_gidThis cookie is
installed by Google Analytics. The cookie is used to store information of how
visitors use a website and helps in creating an analytics report of how the
website is doing. The data collected including the number visitors, the source
where they have come from, and the pages visited in an anonymous form.1
dayAnalytics_gat_UA-73161319-1This is a pattern type cookie set by Google
Analytics, where the pattern element on the name contains the unique identity
number of the account or website it relates to. It appears to be a variation of
the _gat cookie which is used to limit the amount of data recorded by Google on
high traffic volume websites.1 minutePerformance_fbpThis cookie is set by
Facebook to deliver advertisement when they are on Facebook or a digital
platform powered by Facebook advertising after visiting this website.2
monthsAdvertisementfrThe cookie is set by Facebook to show relevant
advertisements to the users and measure and improve the advertisements. The
cookie also tracks the behaviour of the user across the web on sites that have
Facebook pixel or Facebook social plugin.2 monthsAdvertisementli_sugrUsed to
make a probabilistic match of a user’s identity outside a user’s country.2
monthsOtherlangThis cookie is used to store the language preferences of a user
to serve up content in that stored language the next time user visit the
website. FunctionallidcThis cookie is set by LinkedIn and used for routing.1
dayFunctionalUserMatchHistoryLinkedIn – Used to track visitors on multiple
websites, in order to present relevant advertisement based on the visitor’s
preferences.4 weeksOtherlangThis cookie is used to store the language
preferences of a user to serve up content in that stored language the next time
user visit the website. FunctionalbcookieThis cookie is set by LinkedIn. The
purpose of the cookie is to enable LinkedIn functionalities on the page.2
yearsFunctionalbscookieThis cookie is a browser ID cookie set by Linked share
Buttons and ad tags.2 yearsAdvertisementlisscUsed to ensure there is correct
SameSite attribute for all cookies in that browser.1
yearOther_wp_sessionConnects the user to the server.12 hoursOtherPHPSESSIDThis
cookie is native to PHP applications. The cookie is used to store and identify a
users’ unique session ID for the purpose of managing user session on the
website. The cookie is a session cookies and is deleted when all the browser
windows are closed. Necessarypll_languageThis cookie is set by Polylang plugin
for WordPress powered websites. The cookie stores the language code of the last
browsed page.1 yearFunctional_gaThis cookie is installed by Google Analytics.
The cookie is used to calculate visitor, session, campaign data and keep track
of site usage for the site’s analytics report. The cookies store information
anonymously and assign a randomly generated number to identify unique visitors.2
yearsAnalytics_gidThis cookie is installed by Google Analytics. The cookie is
used to store information of how visitors use a website and helps in creating an
analytics report of how the website is doing. The data collected including the
number visitors, the source where they have come from, and the pages visited in
an anonymous form.1 dayAnalytics_gat_UA-73161319-1This is a pattern type cookie
set by Google Analytics, where the pattern element on the name contains the
unique identity number of the account or website it relates to. It appears to be
a variation of the _gat cookie which is used to limit the amount of data
recorded by Google on high traffic volume websites.1 minutePerformancelangThis
cookie is used to store the language preferences of a user to serve up content
in that stored language the next time user visit the website. FunctionallidcThis
cookie is set by LinkedIn and used for routing.1
dayFunctionalUserMatchHistoryLinkedin – Used to track visitors on multiple
websites, in order to present relevant advertisement based on the visitor’s
preferences.4 weeksOtherlangThis cookie is used to store the language
preferences of a user to serve up content in that stored language the next time
user visit the website. FunctionalbcookieThis cookie is set by linkedIn. The
purpose of the cookie is to enable LinkedIn functionalities on the page.2
yearsFunctionalbscookieThis cookie is a browser ID cookie set by Linked share
Buttons and ad tags.2 yearsAdvertisementconnect.sidThis cookie contains the
user’s previous session identification and is only present when the browser
connects for the first time to a new node server instance. The browser must have
connected to a previous instance of the node server, which issued a cookie with
the same key value.1 hourOther_fbpThis cookie is set by Facebook to deliver
advertisement when they are on Facebook or a digital platform powered by
Facebook advertising after visiting this website.2 monthsAdvertisementfrThe
cookie is set by Facebook to show relevant advertisements to the users and
measure and improve the advertisements. The cookie also tracks the behaviour of
the user across the web on sites that have Facebook pixel or Facebook social
plugin.2 monthsAdvertisement_hjidThis is a Hotjar cookie that is set when the
customer first lands on a page using the Hotjar script.1
yearAnalytics_hjFirstSeenThis is set by Hotjar to identify a new user’s first
session. It stores a true/false value, indicating whether this was the first
time Hotjar saw this user. It is used by Recording filters to identify new user
sessions.30 minutesAnalytics_hjIncludedInPageviewSampleThis cookie is set to let
Hotjar know whether that user is included in the data sampling defined by your
site’s pageview limit.2 minutesAnalytics_hjAbsoluteSessionInProgressThis cookie
is used to detect the first pageview session of a user. This is a True/False
flag set by the cookie.30 minutesAnalytics_hjIncludedInSessionSampleNo
description available.2 minutesAnalytics_hjIncludedInSessionSampleThis cookie is
set to let Hotjar know whether that user is included in the data sampling
defined by your site’s daily session limit.30
minutesAnalytics_hjIncludedInPageviewSampleThis cookie is set to let Hotjar know
whether that user is included in the data sampling defined by your site’s
pageview limit.30 minutesAnalytics_hjSessionRejectedIf present, this cookie will
be set to ‘1’ for the duration of a user’s session, if Hotjar rejected the
session from connecting to our WebSocket due to server overload. This cookie is
only applied in extremely rare situations to prevent severe performance
issues.sessionOther
Solely with respect to The Tenth Revolution Group:
CookieDescriptionDurationType_gaThis cookie is installed by Google Analytics.
The cookie is used to calculate visitor, session, campaign data and keep track
of site usage for the site’s analytics report. The cookies store information
anonymously and assign a randomly generated number to identify unique visitors.2
yearsAnalytics_gidThis cookie is installed by Google Analytics. The cookie is
used to store information of how visitors use a website and helps in creating an
analytics report of how the wbsite is doing. The data collected including the
number visitors, the source where they have come from, and the pages viisted in
an anonymous form.1 dayAnalytics_gat_UA-155270382-1This is a pattern type cookie
set by Google Analytics, where the pattern element on the name contains the
unique identity number of the account or website it relates to. It appears to be
a variation of the _gat cookie which is used to limit the amount of data
recorded by Google on high traffic volume websites.1
minutePerformanceli_sugrUsed to make a probabilistic match of a user’s identity
outside a user’s country.2 monthsOtherlangThis cookie is used to store the
language preferences of a user to serve up content in that stored language the
next time user visit the website. FunctionallidcThis cookie is set by LinkedIn
and used for routing.1 dayFunctionalUserMatchHistoryLinkedIn – Used to track
visitors on multiple websites, in order to present relevant advertisement based
on the visitor’s preferences.4 weeksOtherlangThis cookie is used to store the
language preferences of a user to serve up content in that stored language the
next time user visit the website. FunctionalbcookieThis cookie is set by
LinkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the
page.2 yearsFunctionalbscookieThis cookie is a browser ID cookie set by Linked
share Buttons and ad tags.2 yearsAdvertisementlisscUsed to ensure there is
correct SameSite attribute for all cookies in that browser.1 yearOther
E. How to reject cookies
If you don’t wish to receive cookies that are not strictly necessary to perform
basic features of our Websites, you may choose to opt out of them by selecting
the appropriate box at the bottom of any of the Websites, in a link called
“Cookie Preferences.”
Note that most web browsers will accept cookies, but if you would rather that we
did not collect data in this way you can choose to accept or reject some or all
cookies in your browser’s privacy settings. Rejecting all cookies means that
certain features of the Website(s) cannot then be provided to you and
accordingly you may not be able to take full advantage of all our Websites’
features. Each browser is different, so check the “Help” menu of your browser to
learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them or
change cookies’ settings, please refer to aboutcookies.org
(http://www.allaboutcookies.org/). You will also find details on how to delete
cookies from your computer. Find out how to manage cookies on popular browsers:
* Google Chrome
* Microsoft Edge
* Mozilla Firefox
* Microsoft Internet Explorer
* Opera
* Apple Safari
To find information relating to other browsers, visit the browser developer’s
website.
To opt out of being tracked by Google Analytics across all websites,
visit http://tools.google.com/dlpage/gaoptout.
F. Web Beacons
FRG may use or include web beacons in emails or other electronic communications
that FRG sends to you. We use web beacons to help us analyze the effectiveness
of our communications to you. For example, we may use web beacons to understand
when and if you opened our email, how many times you opened the email, if you
have forwarded the email to another email address, or if you clicked on a link
in an email that we sent to you. The web beacons do not collect or give us your
PII but they do provide information to us about your actions after receiving a
communication from us. If you would like to stop receiving emails with web
beacons from us, you may unsubscribe by clicking the “Unsubscribe” link in the
email. However, you may receive auto generated emails from FRG after you create
an account on the Websites or take some other affirmative action on the Websites
which contain web beacons but do not contain an “Unsubscribe” link. In those
cases, just simply email privacy@tenthrevolution.com if you would like to stop
receiving emails from FRG with web beacons.
Also, FRG works with third parties to help manage online advertising who embed
web beacons in online job postings and job advertisements that FRG requests
these third parties to post online. One such third party that we use is
Broadbean. These web beacons allow Broadbean to obtain information such as the
IP address of the computer that downloaded the page on which the beacon appears,
the URL of the page on which the beacon appears, the time the page containing
the beacon was viewed, the type of browser used to view the page, and the
information in cookies set by a third party that Broadbean uses such as Google
Analytics. These files enable Google Analytics to recognize a unique cookie on
your web browser, which in turn enables Broadbean to learn which advertisements
bring users to our Websites or websites on which Broadbean placed our
advertisements. The cookie on your web browser was placed by Broadbean, or by
another advertiser who works with Google Analytics. With both cookies and web
beacon technology, the information that Google Analytics (either directly, see
cookie/plug-in chart above) or Broadbean collects and shares with us is
anonymous and not personally identifiable. It does not contain your name,
address, telephone number, or email address. For more information about Google
Analytics, including information about how to opt out of these technologies, go
to www.google-analytics.com. For more information about web beacons and cookies
placed by Broadbean, please click https://www.broadbean.com/uk/privacy-policy/.
XIII. LINKS TO OTHER WEBSITES
Please note that clicking on links and banner advertisements and RSS (Rich Site
Summary) feeds may result in your transfer to another website, where data
privacy practices may be different than described in this Privacy Notice. It is
your responsibility to check other website privacy notices and policies to
ensure that you are happy for your personal information, including Personal
Data, to be used in accordance with those third parties’ privacy notices and
policies. We accept no responsibility for, and have no control over, third party
websites, links, adverts or RSS feeds or information that is submitted to or
collected by third parties.
XIV. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to change this Privacy Notice from time to time by updating
this Privacy Notice on our website. Any changes to this Privacy Notice or any
of its addendums will be posted on this Website so you are always aware of what
information we collect, how we use it, and under what circumstances, if any, we
disclose it. We encourage you to check this Website frequently for updates.
Your continued use of this Website or any FRG services shall constitute your
acceptance of the revised Privacy Notice.
FRG will interpret and enforce this Privacy Notice in accordance with all
applicable law.
This Privacy Notice was updated on March 25, 2018; October 4, 2018; April 15,
2019; July 10, 2019; January 1, 2020; April 20, 2020; May 18, 2020, October 8,
2020, February 18, 2021, May 12, 2021, June 30, 2021, July 9, 2021.and July 16,
2021
This Privacy Notice was last updated on 13th September 2022.
UNITED KINGDOM AND EUROPEAN ECONOMIC AREA ADDENDUM
I. Who is FRG’s Supervisory Authority for Data Protection Purposes?FRG has
designated the UK Information Commissioner’s Office (“ICO”) as the supervisory
authority for purposes of Data Protection Act of 2018 (“DPA2018”) and UK General
Data Protection Regulation (“UK GDPR”).This addendum applies to the United
Kingdom only.
II. How do we lawfully process your data?
In order to process your Personal Data lawfully FRG must have a legal basis to
do so. FRG relies on three main legal basis for processing your Personal Data:
* where we obtain your affirmative consent to use your Personal Data in this
way;
* where we have a legitimate interest in processing your Personal Data, which
we have balanced against your rights and freedoms and concluded that our
processing is justifiable; or
* where our handling of your Personal Data is necessary for us to perform the
obligations under your company’s or employer’s contract with FRG
(inapplicable to candidates for permanent hire).
We may rely on one or more legal bases to process your Personal Data
A. All users of the Websites and/or our services
Legitimate Interests: FRG uses Personal Data that we collect for the following
general purposes in the performance of our legitimate interests as a business:
to provide the services to our candidates and clients; to enhance their
experience, to improve our services and to contact candidates and clients.
B. Actual or Prospective Candidates
Consent: If you, whether on your own behalf (permanent hire candidate) or on
behalf of your company or your employer (contract hire candidate), would like to
receive general marketing and other communications from us, you will have the
option to affirmatively check a box consenting to FRG processing your Personal
Data for this purpose. FRG may also ask you via email, text message or SMS
(standard SMS or text message rates may apply), or telephone for your
affirmative consent to receive marketing and other communications from us.
Legitimate interest: FRG has a legitimate interest in processing your Personal
Data in order to fill a job, to provide you (permanent hire candidate) or your
company or your employer (contract hire candidate) with other products and
services to help you in your career and to market its products and services to
you in order to grow our business, to demonstrate our knowledge of the
marketplace and relevant technologies and to enhance the standing and
recognition of our brands. FRG also has legitimate interest to process your
Personal Data if you apply for, or seek further information about, a job posted
on one of the Websites or a job advertised by FRG on a job board, social media
site or other forums.
Necessary for the performance of a contract: FRG can process your Personal Data
in the performance of its contract with your company or employer.
C. Individuals who work for FRG clients (i.e. a client contact)
Consent: If you would like to receive general marketing and other communications
from us, you will have the option to affirmatively check a box consenting to FRG
processing your Personal Data for this purpose. FRG may also ask you via email,
text message or SMS (standard SMS or text message rates may apple), or telephone
for your affirmative consent to receive marketing and other communications from
us.
Legitimate Interest: FRG has a legitimate interest in processing your Personal
Data in order to fill a vacancy at your company or employer, and provide you
with other products and services relevant to your company or employer and to
market its products and services to you in order to grow our business, to
demonstrate our knowledge of the marketplace and relevant technologies and to
enhance the standing and recognition of our brands. FRG also has legitimate
interest to process your Personal Data if you seek or obtain further information
about FRG or an FRG candidate.
Necessary for the performance of a contract: FRG can process your Personal Data
in the performance of its contract with your company or employer.
With respect to actual or prospective client contacts and candidates, if FRG
obtains your Personal Data from someone other than you, FRG shall inform you of
the identity and contact details of the person or entity from whom FRG obtained
your Personal Data, whether FRG obtained your Personal Data from publicly
available sources, the categories of Personal Data that FRG obtained and, if FRG
is processing your Personal Data based on its legitimate interest (see Section
III below), the nature of FRG’s legitimate interest. FRG shall provide you with
the information listed in this paragraph by the earlier of (1) one month after
FRG obtains your Personal Data or (2) if FRG uses your Personal Data to
communicate with you, the first time that FRG communicates with you.
FRG shall not provide you with the information described in the paragraph
immediately above if you already possess this information, providing you with
such information is against applicable law, is subject to an obligation of
professional secrecy, proves impossible, would involve a disproportionate effort
or would render impossible or seriously impair the achievement of the objectives
of the processing, in which case, FRG shall take appropriate measures to protect
your rights, freedoms and legitimate interests.
III. Your Special Rights under Data Protection Laws
A. Do I have a right to be erased (forgotten)?
Yes. You have the right to request that FRG deletes or removes your Personal
Data where there is no compelling reason for us to continue to process it. You
can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com.
Please note that your right to erasure is not absolute. FRG will remove your
Personal Data when:
1. the Personal Data is no longer necessary in relation to the purpose for
which FRG originally collected and/or processed it;
2. if FRG is processing your Personal Data on the basis of your consent and you
withdraw consent;
3. you object to the processing of your Personal Data and there is no
overriding legitimate interest for us to continue to process it;
4. the Personal Data was unlawfully processed; and
5. the Personal Data must be erased to comply with a legal obligation.
FRG can refuse to comply with an erasure request in the following limited
circumstances:
(a) to exercise FRG’s right of freedom of expression and information;
(b) to comply with a legal obligation or for the performance of a public
interest task;
(c) for archiving purposes in the public interest, scientific research,
historical research or statistical purposes; or
(d) for the establishment, exercise or defence of legal claims.
If we remove your Personal Data per your request for erasure, then we will
confirm this with you.
If we have disclosed any of your Personal Data to a third party and you submit
an erasure request to us, then we will inform (1) you about the recipients and
(2) any such third parties of your erasure request unless doing so is impossible
or involves disproportionate efforts.
We will respond to your erasure request without undue delay. Please note that,
for your and FRG’s protection, we cannot respond to an erasure request until we
have verified the identity of the person making the request. This verification
process may extend the response timeframes set forth in this paragraph.
B. Do I have a right of access to a copy of my Personal Data?
Yes. You have the right to:
* obtain confirmation that your Personal Data is being processed;
* a copy of your Personal Data being processed;
* the purposes of the processing;
* the categories of personal data being processed;
* the recipients or categories of recipients to whom FRG has disclosed your
Personal Data; and
* the criteria FRG uses to determine how long it will store your Personal Data.
You can exercise this right by sending an email to FRG
at privacy@tenthrevolution.com.
This right is in place to ensure that you are aware of and can verify the
lawfulness of the processing. In most cases, we will provide you with a copy of
your Personal Data free of charge. However, we may charge you a reasonable fee
if your request is manifestly unfounded, excessive or repetitive. With respect
to unfounded, excessive or repetitive requests, in rare cases, FRG may refuse to
respond to your request but will explain the reason(s) for its refusal to you
without undue delay and within one month of its receipt of your request. If FRG
so refuses, you have the right to file a complaint with the ICO and to seek a
judicial remedy.
If you submit your access request to FRG electronically, FRG will provide you
with its response, and a copy of your Personal Data (if applicable) via email or
other commonly used electronic form.
If FRG did not collect your Personal Data from you, FRG will inform you about
the source from which it obtained your Personal Data. Your right of access does
not adversely affect your right of erasure (forgotten) and right of
rectification, both of which are described in this Privacy Notice.
Generally, FRG will provide you with a copy of your Personal Data without undue
delay and within one month of its receipt of your request, provided that FRG may
extend this time period for up to two additional months if your request is
complex or numerous. If FRG exercises this extension of time, FRG will inform
you of its decision to exercise the extension within one month of its receipt of
your request, and will explain the reason(s) for the extension. If your request
is large or complex, FRG may ask you to specify the particular information or
category of information you seek.
Please note that, for your and FRG’s protection, FRG cannot respond to an access
request until it verifies the identity of the person making the request for your
Personal Data. This verification process may extend the response timeframes set
forth in the paragraph above.
C. Do I have a right to object to the processing of my Personal Data, including
the processing of my Personal Data by FRG for direct marketing?
Yes, you have a right to object to the processing of your Personal Data where:
* FRG’s processing is based on its legitimate interest; or
* where FRG is using your Personal Data to directly market to you.
You can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com.
If FRG receives an objection request from you for reasons unrelated to direct
marketing, FRG will stop processing your Personal Data unless we can show
compelling legitimate ground(s) for the processing which override your
interests, rights and freedoms or for the establishment, exercise or defence of
any legal claims.
If FRG receives an objection request from you for reasons related to direct
marketing, we will stop processing your Personal Data.
If you receive a direct marketing communication from FRG and you do not wish to
receive future direct marketing communications from FRG, you may request to
unsubscribe from future marketing communications by sending FRG an email
at privacy@tenthrevolution.com In addition, if the direct marketing
communication you received was via email, you can click the “Unsubscribe” link
at the bottom of the email, fill out the required form and FRG will process your
unsubscribe request. Please allow up to ten (10) business days for your
unsubscribe request to take effect.
D. Do I have a right to restrict processing of my Personal Data?
Yes, you have a right to restrict, the processing of your Personal Data. You
can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com. When you exercise this right, FRG may continue
to store your Personal Data but cannot further process it. FRG will cease
processing your Personal Data in the following circumstances:
1. when you file a rectification request with FRG (see the “Do I have a right
to have any inaccurate or incomplete Personal Data rectified?” section
below) in accordance with this Privacy Notice and applicable law. The
restriction shall remain in place until such time as FRG has verified the
accuracy of the Personal Data that is the subject of your rectification
request;
2. where FRG is processing your Personal Data based on its legitimate interest
and you file a notice with FRG objecting to the processing of your Personal
Data (see the “Do I have a right to object to the processing of my Personal
Data?” section above) in accordance with this Privacy Notice and applicable
law, FRG will cease processing your Personal Data until such time as FRG has
made a determination as to whether its legitimate grounds for continued
processing override your reasons for objecting to the processing;
3. when the processing is unlawful and you do not seek or want erasure and you
file a restriction request with FRG in accordance with this Privacy Notice
and applicable law instead; and
4. if FRG no longer needs the Personal Data and you require the data to
establish, exercise or defend a legal claim.
While the processing of your Personal Data is restricted, FRG may continue to
process such data by storing it, processing it with your consent or processing
it for the establishment, exercise or defence of legal claims.
FRG will inform you if it decides to lift a restriction on processing.
If FRG has disclosed any of your Personal Data to a third party and you submit a
request to restrict processing, FRG will inform (1) you about the recipients if
you so request and (2) any such third parties of your restriction request unless
doing so is impossible or involves disproportionate efforts.
FRG will act on your restriction request in accordance with this Privacy Notice
without undue delay. Please note that, for your and FRG’s protection, FRG cannot
act on a restriction request until it verifies the identity of the person making
the request. This verification process may extend the timeframe in which FRG
acts on your restriction request.
E. Do I have a right to Personal Data portability?
Yes. You can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com. This right exists to allow you to obtain and use
your Personal Data for your own purposes across different services. Under this
right, you can move, copy or transfer your Personal Data from FRG to another
data controller.
This right applies where FRG is processing your Personal Data with your consent
or for the performance of a contract. It also applies if we process your
Personal Data by automated means. If your portability request concerns someone
other than you, FRG will have to consider whether providing or porting the
Personal Data would prejudice the other person’s or people’s rights.
Generally, FRG will respond to your portability request without undue delay and
within one month of its receipt of your request, provided that FRG may extend
this time period for up to two additional months if your request is complex or
numerous. If FRG exercises this extension of time, FRG will inform you of its
decision to exercise the extension within one month of its receipt of your
request, and will explain the reason(s) for the extension. Where technically
feasible, you may request that FRG transmit your Personal Data to another data
controller.
F. Do I have a right to object to decision been taken by automated means?
If FRG uses automated (i.e. non-human) methods to process your Personal Data to
make decisions that could potentially have a damaging legal or similarly
significant effect on you (each, an “Automated Decision”), you have the right
not to be subject to the Automated Decision. This right is inapplicable to any
Automated Decision made by FRG that is necessary for entering into or the
performance of a contract between you and FRG, is authorized by law or is based
on your explicit consent.
If FRG makes any Automated Decisions to which this right applies, FRG will
ensure that you are able to obtain human intervention, express your point of
view and obtain an explanation of the decision and challenge it.
If FRG engages in “profiling” by automated means, FRG will ensure that
appropriate safeguards are in place including (1) ensuring that the processing
is fair and transparent by providing you with meaningful information about the
logic involved and the significance and consequences of the outcome of the
decision, (2) using appropriate mathematical or statistical procedures for the
profiling, (3) implementing appropriate technical and organizational measures to
enable inaccuracies to be corrected and minimize the risk of errors and (4)
securing the Personal Data in a way that is proportionate to the risk to your
interests and rights and prevents discriminatory effects.
G. Do I have a right to have any inaccurate or incomplete Personal Data
rectified?
Yes. You can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com.
Generally, FRG will respond to your rectification request within one month of
its receipt of your request, provided that FRG may extend this time period for
up to two additional months if your request is complex. In rare cases, FRG may
refuse to respond to your request but will explain the reason(s) for its refusal
to you within one month of its receipt of your request. If FRG so refuses, you
have the right to file a complaint with the ICO and to seek a judicial remedy.
If FRG has disclosed any of your Personal Data to a third party and you submit a
rectification request to FRG that FRG is going to honor, FRG will inform (1) you
about the recipients and (2) any such third parties of your rectification
request as well as any corrected Personal Data, unless doing so is impossible or
involves disproportionate efforts.
We will use reasonable endeavours to ensure that your Personal Data is
maintained and up to date.
H. What are my rights if the Security of my Personal Data is breached?
A breach of Personal Data (a “Breach”) means a breach of security leading to the
destruction, loss, alteration, unauthorized disclosure of, or access to, your
Personal Data for which we are responsible under applicable law.
If the Breach is likely to have a significant detrimental effect on your rights
and freedoms (such as resulting in discrimination, damage to reputation or
financial loss), FRG will notify the ICO without undue delay, and if feasible,
within one business day of FRG’s becoming aware of the Breach. FRG will assess
the determination of “significant detrimental effect” on a case by case basis.
If the Breach is likely to result in a “high risk” to your rights and freedoms,
FRG will notify you without undue delay. To be clear, the threshold requiring
FRG to notify you of a Breach is higher than the threshold requiring FRG to
notify the ICO of a Breach so it is possible that FRG will notify the ICO of a
Breach but not you. FRG will assess the determination of “high risk” on a case
by case basis.
Any Breach notice issued by FRG will contain, where possible, (1) the categories
and approximate number of individuals and Personal Data records effected by the
Breach, (2) the name and contact details of the Information System Manager
(“ISM”) (or other FRG contact representative if FRG does not have a ISM at the
time that FRG issues the Breach notice), (3) a description of the likely
consequences of the Breach, (4) a description of the measures that FRG has
taken, and may take, to stop the Breach and, where appropriate, to mitigate the
adverse effects of the Breach and (5) recommendations on actions you can take to
protect yourself in light of the Breach.
I. Will my Personal Data be transferred outside the UK?
FRG may transfer your Personal Data to third parties described in this Privacy
Notice who are located outside of the UK. If so, FRG will take reasonable steps
to ensure that your Personal Data is protected and treated in accordance with
this Privacy Notice and local applicable law. Some of the countries outside the
UK where your Personal Data may be transferred will be on the ICO’s list of
countries that it has deemed to have adequate security controls in place (the
“Approved List”). Given the European Court of Justice’s decision in Data
Protection Commissioner v. Facebook Ireland and Maximilian Schrems, Case
C-311/18 (July 16, 2020) (“Schrems II”) , and absent consent from the Data
Subject (or any other reason provided in UK GDPR Article 49(1)(b)-(f) as may be
amended from time to time), if FRG transfers your Personal Data to processors
(which could be external third party vendors or suppliers) that store, transfer,
process, or control your Personal Data in a country not on the Approved List or
not in the UK (“Third Countries”), then FRG shall determine whether each
processor (and each subprocessor that a processor has provided FRG formal notice
of) can store, transfer, process, or control the Personal Data solely within the
UK, or a country on the Approved List.
(a) If FRG determines that the processor (and each subprocessor that a processor
has provided FRG formal notice of) can store, transfer, process, or control the
Personal Data solely within a country on the Approved List or in the UK, we will
require such processor (and will require the processor to require each of its
applicable subprocessors) to do so.
(b) If FRG determines that the processor (and each subprocessor that a processor
has provided FRG formal notice of) cannot store, transfer, process, or control
the Personal Data in a country on the Approved List or in the UK, then:
(i) FRG will require such processor (and will require the processor to require
each of its applicable subprocessors) to be bound by the model clauses
promulgated by the ICO under S119A(1) Data Protection Act 2018, including but
not limited to the International Data Transfer Addendum to the EU Commission
Standard Contractual Clauses VERSION B1.0, as in force 21 March 2022, any
successor versions thereto, and any other valid transfer mechanism promulgated
by the ICO (collectively for this Addendum, “Model Clauses”). When relying on
the Model Clauses, FRG shall (a) monitor the laws and regulations of Third
Countries for the adequate protections of UK. Data Subjects as required by the
UK GDPR or other local laws and regulations; and (b) terminate the storage,
transfer, processing , or control of Personal Data by a processor (or a
subprocessor where the process has informed FRG of the country in which such
subprocessor is processing your Personal Data) when (i) such laws and
regulations of Third Countries are incompatible with the UK GDPR or other local
laws and regulations, or (ii) access to Personal Data is requested by the public
authorities of Third Countries and such access is lawful under the laws of the
Third Countries but is prohibited under the UK GDPR or other local laws and
regulations. If the events described in III(I)(b)(i)(b)(i) or (ii) occur, FRG
will confer with the appropriate supervisory authority regarding appropriate
actions to safeguard your Personal Data.
(c) FRG shall also require the processor (and will require each processor to
require its applicable subprocessors) to determine whether each processor or
subprocessor can store, transfer, process, or control the Personal Data solely
within the UK, or a country on the Approved List.
1. If processor (or its applicable subprocessors) can store, transfer, process,
or control the Personal Data solely within the UK, or a country on the
Approved List, then FRG shall contractually require the processors (and
require processor to require its subprocessors to) do so.
2. If processor (or its applicable subprocessors) must store, transfer,
process, or control the Personal Data in a Third Country, then FRG shall
require its processors (and require processor to require its subprocessors
to) to be bound by the Model Clauses. When relying on the Model Clauses, FRG
shall contractually require such processors (and shall also require
processors to require their subprocessors) to agree to (a) monitor the laws
and regulations of Third Countries for the adequate protections of UK Data
Subjects as required by the UK GDPR or other local laws and regulations; and
(b) terminate the transfer, processing, or control of Personal Data when (i)
such laws and regulations of Third Countries are incompatible with the UK
GDPR or other local laws and regulations, or (ii) access to Personal Data is
requested by the public authorities of Third Countries and such access is
lawful under the laws of the Third Countries but is prohibited under the UK
GDPR or other local laws and regulations. If the events described in
III(I)(c)(2)(b)(i) or (ii) occur with respect to your Personal Data (and if
FRG has formal notice that the events described in III(I)(c)(2)(b)(i) or
(ii) have occurred), FRG will confer with the appropriate supervisory
authority regarding appropriate actions to safeguard your Personal Data.
Under certain circumstances, FRG may share your Personal Data with one or more
of its group companies who may be located in a Third Country. In such cases, FRG
will comply with its DPAs. The DPAs are incorporated by reference into this
Addendum.
J. How long will FRG store my Personal Data for?
We are required by law to store your Personal Data for as long as is necessary
to comply with our legal, regulatory and contractual obligations.
With respect to UK GDPR (and similar laws), we will store and process your
Personal Data that we obtain via: (i) your consent, until the earlier of (a) the
purpose for which we obtained such information has been fully accomplished or
(b) you inform us that you have withdrawn your consent; (ii) our legitimate
interest until the earlier of (a) your Personal data is no longer necessary for
the purpose for which it is being processed, or (b) FRG concludes that your
rights and freedoms outweigh our right to process your Personal Data; and (iii)
our necessity for the performance of a contract, until the termination or
expiration of the contract including the termination or expiration of FRG’s and
your employer’s or company’s duties or obligations that survive any such
termination or expiration.
Furthermore, we will store your Personal Data in special circumstances related
to the issuance or defense of legal proceedings, outstanding invoices or in
connection with any investigation by or of a government authority.
K. What Protections do I have if FRG transfers my Personal Data to the U.S.?
For Personal Data transferred before December 31st 2020, you have the
protections of the Privacy Shield as defined below and the Model Clauses as
defined above. For Personal Data transferred after December 31st 2020, you have
the protection of the Model Clauses only. Frank Recruitment Group Inc., a
Delaware corporation, is FRG’s primary affiliate and operating company in the
United States (“FRG US Parent”). FRG US Parent has a subsidiary, Frank
Recruitment Group Services Inc., also a Delaware corporation (“FRGS US Sub,”
collectively with FRG US Parent, “FRG US”).
FRG US and FRG US Sub complies with the EU-U.S. Privacy Shield Framework
(“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred from the
United Kingdom, as applicable to the United States in reliance on Privacy
Shield. FRG US and FRG US Sub has certified to the Department of Commerce that
it adheres to the Privacy Shield Principles with respect to such information.
If there is any conflict between the terms in this Privacy Notice and the
Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn
more about the Privacy Shield program, and to view our certification, please
visit https://www.privacyshield.gov/ . This Privacy Notice only applies to
Personal Data within the scope of the FRG US’s Privacy Shield certifications.
FRG US’s contractual clauses for its clients are in the United States of America
Addendum below.
FRG US’s Privacy Shield certifications cover Personal Data regarding:
(1) current, former, and prospective employees in connection with the employment
relationship which is covered by a separate, employee only, Privacy Notice that
has been made available to FRG US employees;
(2) Personal Data regarding client contacts and candidates (temp and perm), such
as the sale and delivery of recruitment services and the administration of the
client and candidate relationship; and
(3) Personal Data regarding third parties (such as service providers and
independent contractors) and their personnel and employees, in connection with
recruitment services and the provision and performance of technical professional
services to client and, where applicable, their end customers and the management
and administration of the business relationships with such third parties.
Our certifications do not cover any disclosure of an individual’s Personal Data
to a third party who processes the Personal Data for its own purposes when the
disclosure is made at the request of the individual.
FRG US disclose Personal Data to third party service providers in connection
with the operation of their respective businesses, including their provision of
services to clients and candidates. FRG US ascertain that these third party
service providers provide at least the same level of privacy protection as is
required by the Privacy Shield Principles. FRG US may be liable if both (a)
third parties fail to meet these obligations and (b) FRG US is responsible for
the event giving rise to the damage.
FRG US are subject to the investigatory and enforcement powers of the United
States Federal Trade Commission. FRG US may be required to disclose Personal
Data to law enforcement, regulatory or other government agencies, or to other
third parties, in each case to comply with legal, regulatory, or national
security obligations or requests.
Any questions or complaints concerning FRG US’s Privacy Shield compliance, or
requests to access, correct, amend, delete, or limit the use or disclosure of
Personal Data (opt out) may be directed to privacy@tenthrevolution.com. If FRG
US has not been able to satisfactorily resolve the issue, then you may raise it
with (1) your data protection authority (see paragraph immediately below) or (2)
the International Centre for Dispute Resolution/American Arbitration Association
(“ICDR/AAA“) for non-HR related recourse, which can be contacted
at http://go.adr.org/privacyshield.html. Under certain conditions, individuals
may have the possibility to engage in binding arbitration through the Privacy
Shield Panel. To find out more about individual binding arbitration, please
visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
L. UK residents. Should your complaint relate to FRG US’s failure to comply with
its Privacy Shield commitments and remains unresolved and you reside in the UK,
then you should contact the UK Supervisory Authorities (the “SAs”) who act as an
independent recourse mechanism to settle all such disputes. Such complaints can
be directed either to the UK DPAs panel secretariat or individual UK SAs.
Information Commissioner’s
Office
Wycliffe House
Water
Lane
Wilmslow
Cheshire
SK9
5AF
Tel: 0303 123 1113 (local rate)
Fax: 0162 552 4510
Or via below link :
https://ico.org.uk/make-a-complaint/
ICO REGIONAL OFFICES
SCOTLAND
Information Commissioner’s Office
45 Melville Street
Edinburgh
EH3 7HL
Tel: 0303 123 1115
Email: scotland@ico.org.uk
WALES
Information Commissioner’s Office
2nd floor
Churchill House
Churchill way
Cardiff
CF10 2HH
Tel: 0330 414 6421
Email: wales@ico.org.uk
NORTHERN IRELAND
Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB
Tel: 028 9027 8757 or 0303 123 1114
Email: ni@ico.org.uk
EUROPEAN ECONOMIC AREA & SWISS ADDENDUM
I. Who is FRG’s Supervisory Authority for Data Protection Purposes?
This addendum applies to the European Economic Area & Swiss residents.
II. How do we lawfully process your data?
In order to process your Personal Data lawfully FRG must have a legal basis to
do so. FRG relies on three main legal basis for processing your Personal Data:
* where we obtain your affirmative consent to use your Personal Data in this
way;
* where we have a legitimate interest in processing your Personal Data, which
we have balanced against your rights and freedoms and concluded that our
processing is justifiable; or
* where our handling of your Personal Data is necessary for us to perform the
obligations under your company’s or employer’s contract with FRG
(inapplicable to candidates for permanent hire).
We may rely on one or more legal bases to process your Personal Data
A. All users of the Websites and/or our services
Legitimate Interests: FRG uses Personal Data that we collect for the following
general purposes in the performance of our legitimate interests as a business:
to provide the services to our candidates and clients; to enhance their
experience, to improve our services and to contact candidates and clients.
B. Actual or Prospective Candidates
Consent: If you, whether on your own behalf (permanent hire candidate) or on
behalf of your company or your employer (contract hire candidate), would like to
receive general marketing and other communications from us, you will have the
option to affirmatively check a box consenting to FRG processing your Personal
Data for this purpose. FRG may also ask you via email, text message or SMS
(standard SMS or text message rates may apply), or telephone for your
affirmative consent to receive marketing and other communications from us.
Legitimate interest: FRG has a legitimate interest in processing your Personal
Data in order to fill a job, to provide you (permanent hire candidate) or your
company or your employer (contract hire candidate) with other products and
services to help you in your career and to market its products and services to
you in order to grow our business, to demonstrate our knowledge of the
marketplace and relevant technologies and to enhance the standing and
recognition of our brands. FRG also has legitimate interest to process your
Personal Data if you apply for, or seek further information about, a job posted
on one of the Websites or a job advertised by FRG on a job board, social media
site or other forums.
Necessary for the performance of a contract: FRG can process your Personal Data
in the performance of its contract with your company or employer.
C. Individuals who work for FRG clients (i.e. a client contact)
Consent: If you would like to receive general marketing and other communications
from us, you will have the option to affirmatively check a box consenting to FRG
processing your Personal Data for this purpose. FRG may also ask you via email,
text message or SMS (standard SMS or text message rates may apple), or telephone
for your affirmative consent to receive marketing and other communications from
us.
Legitimate Interest: FRG has a legitimate interest in processing your Personal
Data in order to fill a vacancy at your company or employer, and provide you
with other products and services relevant to your company or employer and to
market its products and services to you in order to grow our business, to
demonstrate our knowledge of the marketplace and relevant technologies and to
enhance the standing and recognition of our brands. FRG also has legitimate
interest to process your Personal Data if you seek or obtain further information
about FRG or an FRG candidate.
Necessary for the performance of a contract: FRG can process your Personal Data
in the performance of its contract with your company or employer.
With respect to actual or prospective client contacts and candidates, if FRG
obtains your Personal Data from someone other than you, FRG shall inform you of
the identity and contact details of the person or entity from whom FRG obtained
your Personal Data, whether FRG obtained your Personal Data from publicly
available sources, the categories of Personal Data that FRG obtained and, if FRG
is processing your Personal Data based on its legitimate interest (see Section
III below), the nature of FRG’s legitimate interest. FRG shall provide you with
the information listed in this paragraph by the earlier of (1) one month after
FRG obtains your Personal Data or (2) if FRG uses your Personal Data to
communicate with you, the first time that FRG communicates with you.
FRG shall not provide you with the information described in the paragraph
immediately above if you already possess this information, providing you with
such information is against applicable law, is subject to an obligation of
professional secrecy, proves impossible, would involve a disproportionate effort
or would render impossible or seriously impair the achievement of the objectives
of the processing, in which case, FRG shall take appropriate measures to protect
your rights, freedoms and legitimate interests.
III. Your Special Rights under Data Protection Laws
A. Do I have a right to be erased (forgotten)?
Yes. You have the right to request that FRG deletes or removes your Personal
Data where there is no compelling reason for us to continue to process it. You
can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com.
Please note that your right to erasure is not absolute. FRG will remove your
Personal Data when:
1. the Personal Data is no longer necessary in relation to the purpose for
which FRG originally collected and/or processed it;
2. if FRG is processing your Personal Data on the basis of your consent and you
withdraw consent;
3. you object to the processing of your Personal Data and there is no
overriding legitimate interest for us to continue to process it;
4. the Personal Data was unlawfully processed; and
5. the Personal Data must be erased to comply with a legal obligation.
FRG can refuse to comply with an erasure request in the following limited
circumstances:
(a) to exercise FRG’s right of freedom of expression and information;
(b) to comply with a legal obligation or for the performance of a public
interest task;
(c) for archiving purposes in the public interest, scientific research,
historical research or statistical purposes; or
(d) for the establishment, exercise or defence of legal claims.
If we remove your Personal Data per your request for erasure, then we will
confirm this with you.
If we have disclosed any of your Personal Data to a third party and you submit
an erasure request to us, then we will inform (1) you about the recipients and
(2) any such third parties of your erasure request unless doing so is impossible
or involves disproportionate efforts.
We will respond to your erasure request without undue delay. Please note that,
for your and FRG’s protection, we cannot respond to an erasure request until we
have verified the identity of the person making the request. This verification
process may extend the response timeframes set forth in this paragraph.
B. Do I have a right of access to a copy of my Personal Data?
Yes. You have the right to:
* obtain confirmation that your Personal Data is being processed;
* a copy of your Personal Data being processed;
* the purposes of the processing;
* the categories of personal data being processed;
* the recipients or categories of recipients to whom FRG has disclosed your
Personal Data; and
* the criteria FRG uses to determine how long it will store your Personal Data.
You can exercise this right by sending an email to FRG
at privacy@tenthrevolution.com.
This right is in place to ensure that you are aware of and can verify the
lawfulness of the processing. In most cases, we will provide you with a copy of
your Personal Data free of charge. However, we may charge you a reasonable fee
if your request is manifestly unfounded, excessive or repetitive. With respect
to unfounded, excessive or repetitive requests, in rare cases, FRG may refuse to
respond to your request but will explain the reason(s) for its refusal to you
without undue delay and within one month of its receipt of your request. If FRG
so refuses, you have the right to file a complaint with our lead supervisory
authority under GDPR Chapter 6, the Autoriteit Persoonsgegevens (AP) within the
Kingdom of the Netherlands (“LSA”) and to seek a judicial remedy. Our European
Union Representative for purposes of GDPR Article 27 is Frank Recruitment Group
B.V. (“EU Rep.”)
If you submit your access request to FRG electronically, FRG will provide you
with its response, and a copy of your Personal Data (if applicable) via email or
other commonly used electronic form.
If FRG did not collect your Personal Data from you, FRG will inform you about
the source from which it obtained your Personal Data. Your right of access does
not adversely affect your right of erasure (forgotten) and right of
rectification, both of which are described in this Privacy Notice.
Generally, FRG will provide you with a copy of your Personal Data without undue
delay and within one month of its receipt of your request, provided that FRG may
extend this time period for up to two additional months if your request is
complex or numerous. If FRG exercises this extension of time, FRG will inform
you of its decision to exercise the extension within one month of its receipt of
your request, and will explain the reason(s) for the extension. If your request
is large or complex, FRG may ask you to specify the particular information or
category of information you seek.
Please note that, for your and FRG’s protection, FRG cannot respond to an access
request until it verifies the identity of the person making the request for your
Personal Data. This verification process may extend the response timeframes set
forth in the paragraph above.
C. Do I have a right to object to the processing of my Personal Data, including
the processing of my Personal Data by FRG for direct marketing?
Yes, you have a right to object to the processing of your Personal Data where:
* FRG’s processing is based on its legitimate interest; or
* where FRG is using your Personal Data to directly market to you.
You can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com.
If FRG receives an objection request from you for reasons unrelated to direct
marketing, FRG will stop processing your Personal Data unless we can show
compelling legitimate ground(s) for the processing which override your
interests, rights and freedoms or for the establishment, exercise or defence of
any legal claims.
If FRG receives an objection request from you for reasons related to direct
marketing, we will stop processing your Personal Data.
If you receive a direct marketing communication from FRG and you do not wish to
receive future direct marketing communications from FRG, you may request to
unsubscribe from future marketing communications by sending FRG an email
at privacy@tenthrevolution.com In addition, if the direct marketing
communication you received was via email, you can click the “Unsubscribe” link
at the bottom of the email, fill out the required form and FRG will process your
unsubscribe request. Please allow up to ten (10) business days for your
unsubscribe request to take effect.
D. Do I have a right to restrict processing of my Personal Data?
Yes, you have a right to restrict, the processing of your Personal Data. You
can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com. When you exercise this right, FRG may continue
to store your Personal Data but cannot further process it. FRG will cease
processing your Personal Data in the following circumstances:
1. when you file a rectification request with FRG (see the “Do I have a right
to have any inaccurate or incomplete Personal Data rectified?” section
below) in accordance with this Privacy Notice and applicable law. The
restriction shall remain in place until such time as FRG has verified the
accuracy of the Personal Data that is the subject of your rectification
request;
2. where FRG is processing your Personal Data based on its legitimate interest
and you file a notice with FRG objecting to the processing of your Personal
Data (see the “Do I have a right to object to the processing of my Personal
Data?” section above) in accordance with this Privacy Notice and applicable
law, FRG will cease processing your Personal Data until such time as FRG has
made a determination as to whether its legitimate grounds for continued
processing override your reasons for objecting to the processing;
3. when the processing is unlawful and you do not seek or want erasure and you
file a restriction request with FRG in accordance with this Privacy Notice
and applicable law instead; and
4. if FRG no longer needs the Personal Data and you require the data to
establish, exercise or defend a legal claim.
While the processing of your Personal Data is restricted, FRG may continue to
process such data by storing it, processing it with your consent or processing
it for the establishment, exercise or defence of legal claims.
FRG will inform you if it decides to lift a restriction on processing.
If FRG has disclosed any of your Personal Data to a third party and you submit a
request to restrict processing, FRG will inform (1) you about the recipients if
you so request and (2) any such third parties of your restriction request unless
doing so is impossible or involves disproportionate efforts.
FRG will act on your restriction request in accordance with this Privacy Notice
without undue delay. Please note that, for your and FRG’s protection, FRG cannot
act on a restriction request until it verifies the identity of the person making
the request. This verification process may extend the timeframe in which FRG
acts on your restriction request.
E. Do I have a right to Personal Data portability?
Yes. You can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com. This right exists to allow you to obtain and use
your Personal Data for your own purposes across different services. Under this
right, you can move, copy or transfer your Personal Data from FRG to another
data controller.
This right applies where FRG is processing your Personal Data with your consent
or for the performance of a contract. It also applies if we process your
Personal Data by automated means. If your portability request concerns someone
other than you, FRG will have to consider whether providing or porting the
Personal Data would prejudice the other person’s or people’s rights.
Generally, FRG will respond to your portability request without undue delay and
within one month of its receipt of your request, provided that FRG may extend
this time period for up to two additional months if your request is complex or
numerous. If FRG exercises this extension of time, FRG will inform you of its
decision to exercise the extension within one month of its receipt of your
request, and will explain the reason(s) for the extension. Where technically
feasible, you may request that FRG transmit your Personal Data to another data
controller.
F. Do I have a right to object to decision been taken by automated means?
If FRG uses automated (i.e. non-human) methods to process your Personal Data to
make decisions that could potentially have a damaging legal or similarly
significant effect on you (each, an “Automated Decision”), you have the right
not to be subject to the Automated Decision. This right is inapplicable to any
Automated Decision made by FRG that is necessary for entering into or the
performance of a contract between you and FRG, is authorized by law or is based
on your explicit consent.
If FRG makes any Automated Decisions to which this right applies, FRG will
ensure that you are able to obtain human intervention, express your point of
view and obtain an explanation of the decision and challenge it.
If FRG engages in “profiling” by automated means, FRG will ensure that
appropriate safeguards are in place including (1) ensuring that the processing
is fair and transparent by providing you with meaningful information about the
logic involved and the significance and consequences of the outcome of the
decision, (2) using appropriate mathematical or statistical procedures for the
profiling, (3) implementing appropriate technical and organizational measures to
enable inaccuracies to be corrected and minimize the risk of errors and (4)
securing the Personal Data in a way that is proportionate to the risk to your
interests and rights and prevents discriminatory effects.
G. Do I have a right to have any inaccurate or incomplete Personal Data
rectified?
Yes. You can exercise this right, free of charge, by sending an email to FRG
at privacy@tenthrevolution.com.
Generally, FRG will respond to your rectification request within one month of
its receipt of your request, provided that FRG may extend this time period for
up to two additional months if your request is complex. In rare cases, FRG may
refuse to respond to your request but will explain the reason(s) for its refusal
to you within one month of its receipt of your request. If FRG so refuses, you
have the right to file a complaint with the LSA and to seek a judicial remedy.
If FRG has disclosed any of your Personal Data to a third party and you submit a
rectification request to FRG that FRG is going to honor, FRG will inform (1) you
about the recipients and (2) any such third parties of your rectification
request as well as any corrected Personal Data, unless doing so is impossible or
involves disproportionate efforts.
We will use reasonable endeavours to ensure that your Personal Data is
maintained and up to date.
H. What are my rights if the Security of my Personal Data is breached?
A breach of Personal Data (a “Breach”) means a breach of security leading to the
destruction, loss, alteration, unauthorized disclosure of, or access to, your
Personal Data for which we are responsible under applicable law.
If the Breach is likely to have a significant detrimental effect on your rights
and freedoms (such as resulting in discrimination, damage to reputation or
financial loss), FRG will notify the LSA without undue delay, and if feasible,
within one business day of FRG’s becoming aware of the Breach. FRG will assess
the determination of “significant detrimental effect” on a case by case basis.
If the Breach is likely to result in a “high risk” to your rights and freedoms,
FRG will notify you without undue delay. To be clear, the threshold requiring
FRG to notify you of a Breach is higher than the threshold requiring FRG to
notify the LSA of a Breach so it is possible that FRG will notify the LSA of a
Breach but not you. FRG will assess the determination of “high risk” on a case
by case basis.
Any Breach notice issued by FRG will contain, where possible, (1) the categories
and approximate number of individuals and Personal Data records effected by the
Breach, (2) the name and contact details of the ISM (or other FRG contact
representative if FRG does not have a ISM at the time that FRG issues the Breach
notice), (3) a description of the likely consequences of the Breach, (4) a
description of the measures that FRG has taken, and may take, to stop the Breach
and, where appropriate, to mitigate the adverse effects of the Breach and (5)
recommendations on actions you can take to protect yourself in light of the
Breach.
I. Will my Personal Data be transferred outside the EEA & Switzerland?
FRG may transfer your Personal Data to third parties described in this Privacy
Notice who are located outside of the EEA or Switzerland. If so, FRG will take
reasonable steps to ensure that your Personal Data is protected and treated in
accordance with this Privacy Notice and local applicable law. Some of the
countries outside Switzerland or EEA where your Personal Data may be
transferred will be on the EU Commission’s or Swiss Federal Data Protection and
Information Commission’s list of countries that it has deemed to have adequate
security controls in place (for this Addendum, the “Approved List”). Given the
European Court of Justice’s decision in Data Protection Commissioner v. Facebook
Ireland and Maximilian Schrems, Case C-311/18 (July 16, 2020) (“Schrems II”) as
well as the September 8, 2020 Swiss Federal Data Protection and Information
Commissioner’s Policy paper on the transfer of personal data to the USA and
other countries lacking an adequate level of data protection within the meaning
of Art. 6 Para. 1 Swiss Federal Act on Data Protection, and absent consent from
the Data Subject (or any other reason provided in GDPR Article 49(1)(b)-(f) or
Swiss law as may be amended from time to time), if FRG transfers your Personal
Data to processors (which could be external third party vendors or suppliers)
that store, transfer, process, or control your Personal Data in a country not on
the Approved List or not in Switzerland or EEA (for this Addendum, “Third
Countries”), then FRG shall determine whether each processor (and each
subprocessor that a processor has provided FRG formal notice of) can store,
transfer, process, or control the Personal Data solely within Switzerland EEA,
or a country on the Approved List.
(a) If FRG determines that the processor (and each subprocessor that a processor
has provided FRG formal notice of) can store, transfer, process, or control the
Personal Data solely within a country on the Approved List or in Switzerland or
EEA, we will require such processor (and will require the processor to require
each of its applicable subprocessors) to do so.
(b) If FRG determines that the processor (and each subprocessor that a processor
has provided FRG formal notice of) cannot store, transfer, process, or control
the Personal Data in a country on the Approved List or in Switzerland or EEA,
then:
(i) FRG will require such processor (and will require the processor to require
each of its applicable subprocessors) to be bound by the model clauses
promulgated by the European Commission as provided
here: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021D0914&from=EN
(or any updated link which the European Commission may supply from time to time)
(for this Addendum, the “Model Clauses”). When relying on the Model Clauses, FRG
shall (a) monitor the laws and regulations of Third Countries for the adequate
protections of Swiss or EEA Data Subjects as required by the GDPR or other local
laws and regulations; and (b) terminate the storage, transfer, processing , or
control of Personal Data by a processor (or a subprocessor where the process has
informed FRG of the country in which such subprocessor is processing your
Personal Data) when (i) such laws and regulations of Third Countries are
incompatible with the GDPR or other local laws and regulations, or (ii) access
to Personal Data is requested by the public authorities of Third Countries and
such access is lawful under the laws of the Third Countries but is prohibited
under the GDPR or other local laws and regulations. If the events described in
III(I)(b)(i)(b)(i) or (ii) occur, FRG will confer with the appropriate
supervisory authority regarding appropriate actions to safeguard your Personal
Data.
(c) FRG shall also require the processor (and will require each processor to
require its applicable subprocessors) to determine whether each processor or
subprocessor can store, transfer, process, or control the Personal Data solely
within Switzerland, EEA, or a country on the Approved List.
1. If processor (or its applicable subprocessors) can store, transfer, process,
or control the Personal Data solely within Switzerland, EEA, or a country on
the Approved List, then FRG shall contractually require the processors (and
require processor to require its subprocessors to) do so.
2. If processor (or its applicable subprocessors) must store, transfer,
process, or control the Personal Data in a Third Country, then FRG shall
require its processors (and require processor to require its subprocessors
to) to be bound by the Model Clauses. When relying on the Model Clauses, FRG
shall contractually require such processors (and shall also require
processors to require their subprocessors) to agree to (a) monitor the laws
and regulations of Third Countries for the adequate protections of Swiss or
EEA Data Subjects as required by the GDPR or other local laws and
regulations; and (b) terminate the transfer, processing, or control of
Personal Data when (i) such laws and regulations of Third Countries are
incompatible with the GDPR or other local laws and regulations, or (ii)
access to Personal Data is requested by the public authorities of Third
Countries and such access is lawful under the laws of the Third Countries
but is prohibited under the GDPR or other local laws and regulations. If the
events described in III(I)(c)(2)(b)(i) or (ii) occur with respect to your
Personal Data (and if FRG has formal notice that the events described in
III(I)(c)(2)(b)(i) or (ii) have occurred), FRG will confer with the
appropriate supervisory authority regarding appropriate actions to safeguard
your Personal Data.
Under certain circumstances, FRG may share your Personal Data with one or more
of its group companies who may be located in a Third Country. In such cases, FRG
will comply with its DPAs. The DPAs are incorporated by reference into this
Addendum
J. How long will FRG store my Personal Data for?
We are required by law to store your Personal Data for as long as is necessary
to comply with our legal, regulatory and contractual obligations.
With respect to GDPR (and similar laws), we will store and process your Personal
Data that we obtain via: (i) your consent, until the earlier of (a) the purpose
for which we obtained such information has been fully accomplished or (b) you
inform us that you have withdrawn your consent; (ii) our legitimate interest
until the earlier of (a) your Personal data is no longer necessary for the
purpose for which it is being processed, or (b) FRG concludes that your rights
and freedoms outweigh our right to process your Personal Data; and (iii) our
necessity for the performance of a contract, until the termination or expiration
of the contract including the termination or expiration of FRG’s and your
employer’s or company’s duties or obligations that survive any such termination
or expiration.
Furthermore, we will store your Personal Data in special circumstances related
to the issuance or defense of legal proceedings, outstanding invoices or in
connection with any investigation by or of a government authority.
K. What Protections do I have if FRG transfers my Personal Data to the U.S.?
In short, you have the protections of the Privacy Shield as defined below and
the Model Clauses as defined above. Frank Recruitment Group Inc., a Delaware
corporation, is FRG’s primary affiliate and operating company in the United
States (“FRG US Parent”). FRG US Parent has a subsidiary, Frank Recruitment
Group Services Inc., also a Delaware corporation (“FRGS US Sub,” collectively
with FRG US Parent, “FRG US”).
FRG US and FRG US Sub complies with the EU-U.S. Privacy Shield Framework and the
Swiss-U.S. Privacy Shield Framework(s) (“Privacy Shield”) as set forth by the
U.S. Department of Commerce regarding the collection, use, and retention of
personal information transferred from the European Union, EEA, and/or
Switzerland, as applicable to the United States in reliance on Privacy Shield.
FRG US and FRG US Sub has certified to the Department of Commerce that it
adheres to the Privacy Shield Principles with respect to such information. If
there is any conflict between the terms in this Privacy Notice and the Privacy
Shield Principles, the Privacy Shield Principles shall govern. To learn more
about the Privacy Shield program, and to view our certification, please visit
https://www.privacyshield.gov/ . This Privacy Notice only applies to Personal
Data within the scope of the FRG US’s Privacy Shield certifications.
FRG US’s contractual clauses for its clients are in the United States of America
Addendum below.
FRG US’s Privacy Shield certifications cover Personal Data regarding:
(1) current, former, and prospective employees in connection with the employment
relationship which is covered by a separate, employee only, Privacy Notice that
has been made available to FRG US employees;
(2) Personal Data regarding client contacts and candidates (temp and perm), such
as the sale and delivery of recruitment services and the administration of the
client and candidate relationship; and
(3) Personal Data regarding third parties (such as service providers and
independent contractors) and their personnel and employees, in connection with
recruitment services and the provision and performance of technical professional
services to client and, where applicable, their end customers and the management
and administration of the business relationships with such third parties.
Our certifications do not cover any disclosure of an individual’s Personal Data
to a third party who processes the Personal Data for its own purposes when the
disclosure is made at the request of the individual.
FRG US disclose Personal Data to third party service providers in connection
with the operation of their respective businesses, including their provision of
services to clients and candidates. FRG US ascertain that these third party
service providers provide at least the same level of privacy protection as is
required by the Privacy Shield Principles. FRG US may be liable if both (a)
third parties fail to meet these obligations and (b) FRG US is responsible for
the event giving rise to the damage.
FRG US are subject to the investigatory and enforcement powers of the United
States Federal Trade Commission. FRG US may be required to disclose Personal
Data to law enforcement, regulatory or other government agencies, or to other
third parties, in each case to comply with legal, regulatory, or national
security obligations or requests.
Any questions or complaints concerning FRG US’s Privacy Shield compliance, or
requests to access, correct, amend, delete, or limit the use or disclosure of
Personal Data (opt out) may be directed to privacy@tenthrevolution.com. If FRG
US has not been able to satisfactorily resolve the issue, then you may raise it
with (1) your data protection authority (see paragraph immediately below) or (2)
the International Centre for Dispute Resolution/American Arbitration Association
(“ICDR/AAA“) for non-HR related recourse, which can be contacted
at http://go.adr.org/privacyshield.html. Under certain conditions, individuals
may have the possibility to engage in binding arbitration through the Privacy
Shield Panel. To find out more about individual binding arbitration, please
visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
L. EEA residents. Should your complaint relate to FRG US’s failure to comply
with its Privacy Shield commitments and remains unresolved and you reside in the
EEA, then you should contact the EEA Supervisory Authorities (the “SAs”) who act
as an independent recourse mechanism to settle all such disputes. Such
complaints can be directed either to the EEA SAs panel secretariat or individual
EEA SAs.
Currently, the contact information relevant to the submission of the standard
complaint form is as follows: Commission Européenne, Directorate General
Justice, Directorate C (Fundamental Rights and Union Citizenship) of the
European Commission, Data Protection Panel, B-1049 Brussels, Belgium, Telephone:
(32-2) 299 11 11, Fax: (32-2) 298.80.94, email: ec-dppanel-secr@ec.europa.eu.
FRG’s Lead Supervisory Authority is Authoriteit Persoonsgegevens (AP) within the
Kingdom of the Netherlands and our European Union Representative is Frank
Recruiment Group BV.
You can find the standard compliant form
at https://edps.europa.eu/data-protection/our-role-supervisor/complaints/edps-complaint-form_en.
FRG’s Lead Supervisory Authority is Authoriteit Persoonsgegevens (AP) within the
Kingdon of the Netherlands and our European Union Representative is Frank
Recruiment Group BV.
The contact information for individual EU SAs can be found
at: http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm
M. Swiss residents. Should your complaint relate to FRG US’s failing to comply
with our Privacy Shield commitments and remains unresolved and you reside in
Switzerland, then you should contact the Federal Data Protection and Information
Commissioner (FDPIC) of Switzerland with whom FRG US has agreed to cooperate
regarding such disputes.
The contact information for the Swiss FDPIC can be found
at: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.
Under the EU-U.S. Privacy Shield, the following independent dispute resolution
bodies designated to address complaints will provide appropriate recourse free
of charge to the individual: (1) the panel established by SAs, (2) an
alternative dispute resolution provider based in the EU, or (3) an alternative
dispute resolution provider based in the United States.
Also, under the Swiss-U.S. Privacy Shield, the following independent dispute
resolution bodies designated to address complaints will provide appropriate
recourse free of charge to the individual: (1) the Commissioner of the FDPIC,
(2) an alternative dispute resolution provider based in Switzerland, or (3) an
alternative dispute resolution provider based in the United States.
SINGAPORE ADDENDUM
This Singapore Addendum shall prevail in the event of inconsistency between the
principles stated herein and those as described under the Privacy Statement.
1. INTRODUCTION TO THE PERSONAL DATA PROTECTION ACT 2012 (“PDPA”)
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not,
about an individual who can be identified from that data, or from that data and
other information to which an organisation has or is likely to have access.
1.2 We will collect your Personal Data in accordance with the PDPA. In general,
before we collect any Personal Data from you, we will notify you of the purposes
for which your Personal Data may be collected, used and/or disclosed, as well as
obtain your consent for the collection, use and/or disclosure of your Personal
Data for the intended purposes.
1.3 Your Personal Data may also be collected, used or disclosed if we have
assessed that to do so would be in our legitimate interests and beneficial to
the public. Before doing so, we will take steps to ensure that any adverse
effects that might arise for you have already been identified and eliminated,
reduced or mitigated.
2. PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA
2.1 The Personal Data which we collect from you may be collected, used and/or
disclosed for the following purposes:
(a) facilitating, processing, dealing with, administering, and/or managing your
employment with FRG.
(b) processing and/or administering any consultations, negotiations, and an a
suitable placement within FRG
(c) processing and/or administering requests for access and/or correction of
your Personal Data;
(d) processing your registration and/or participation for seminars, exhibitions,
and other events organized or co-organized by FRG;
(e) carrying out your instructions or responding to any enquiry given by (or
purported to be given by) you or on your behalf;
(f) conducting employee due diligence or other screening and personal
identification in accordance with laws, regulations or our risk management
procedures that may be required by law or that may have been put in place by us;
(g) to prevent or investigate any fraud, unlawful activity or omission or
misconduct, whether or not there is any suspicion of the aforementioned;
(h) complying with or as required by any applicable law, governmental or
regulatory requirements of any relevant jurisdiction, including meeting the
requirements to make disclosure under the requirements of any law binding on us
and/or for the purposes of any guidelines issued by regulatory or other
authorities, whether in Singapore or elsewhere, with which we are expected to
comply;
(i) complying with or as required by any request or direction of any
governmental authority, or responding to requests for information from public
agencies, ministries, statutory boards or other similar authorities. For the
avoidance of doubt, this means that we may/will disclose your Personal Data to
the aforementioned parties upon their request or direction; etc.
(collectively, the “Purposes”).
2.2 To conduct our business operations more smoothly, we may also be disclosing
the Personal Data you have provided to us to our third-party service providers,
agents and/or our affiliates or related corporations, which may be sited outside
of Singapore, for one or more of the above-stated Purposes. This is because such
third-party service providers, agents and/or affiliates or related corporations
would be processing your Personal Data on our behalf for one or more of the
above-stated Purposes.
3. DISCLOSURE OF YOUR PERSONAL DATA TO A THIRD PARTY
3.1 We respect the confidentiality of the Personal Data you have provided to us.
3.2 In that regard, we will not disclose any of your Personal Data to any third
parties without first obtaining your express consent permitting us to do so.
However, please note that we may disclose your Personal Data to third parties
without first obtaining your consent in certain situations, including, without
limitation, the following:
(a) cases in which the disclosure is required based on the applicable laws
and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests,
and if consent cannot be obtained in a timely way, provided that we shall, as
soon as may be practicable, notify you of the disclosure and the purposes of the
disclosure;
(c) cases in which the disclosure is necessary to respond to an emergency that
threatens the life, health or safety of yourself or another individual;
(d) cases in which there are reasonable grounds to believe that the health or
safety of yourself or another individual will be seriously affected and consent
for the disclosure of the data cannot be obtained in a timely way, provided that
we shall, as soon as may be practicable, notify you of the disclosure and the
purposes of the disclosure;
(e) cases in which the disclosure is necessary for any investigation or
proceedings;
(f) cases in which the Personal Data is disclosed to any officer of a prescribed
law enforcement agency, upon production of written authorization signed by the
head or director of that law enforcement agency or a person of a similar rank,
certifying that the Personal Data is necessary for the purposes of the functions
or duties of the officer; and/or
(g) cases in which the disclosure is to a public agency and such disclosure is
necessary in the public interest.
3.3 The instances listed above at paragraph 3.2 are not intended to be
exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse
the First and Second Schedules of the PDPA which is publicly available at
https://sso.agc.gov.sg/.
3.4 In all other instances of disclosure of Personal Data to third parties with
your express consent, we will endeavour to provide adequate supervision over the
handling and administration of your Personal Data by such third parties, as well
as to provide for adequate forms of protection over such Personal Data.
3.5 Where Personal Data is transferred by us to any third parties outside of
Singapore, we will ensure that such transfers are compliant with the
requirements under the PDPA. In this regard, we will take such necessary
measures to ensure that such overseas recipients are bound by legally
enforceable obligations to ensure that these overseas recipients provide a
standard of protection to the Personal Data so transferred that is comparable to
the protection under the PDPA.
4. REQUEST FOR ACCESS AND/OR CORRECTION OF YOUR PERSONAL DATA
Access Request
4.1 An individual may request for us to provide access to Personal Data about
the individual that is in our possession or under our control as well as
information about the ways in which the Personal Data has been used or disclosed
by us within a year before the date of the request.
4.2 Unless an exception to the access request applies, we will respond to your
access request as soon as reasonably possible from the time the access request
is received. If we are unable to respond to an access request within thirty (30)
days after receiving the request, we shall inform you in writing within the
thirty (30) day period, of the reasonably soonest time in which we will respond.
Correction Request
4.3 An individual may also request for us to correct Personal Data that is in
our possession or under our control. Unless an exception to the correction
request applies, or we are satisfied on reasonable grounds that a correction
should not be made, we will endeavour to correct the Personal Data as soon as
practicable and send the corrected Personal Data to every other organisation to
which the Personal Data was disclosed by us within a year before the date the
correction was made. This is unless that other organisation does not need the
corrected Personal Data for any legal or business purpose.
4.4 Where we are unable to respond to a correction request within thirty (30)
days after receiving the request, we shall inform you in writing within the
thirty (30) day period, of the reasonably soonest time in which we will respond.
4.5 You may submit your access or correction request to the contact details
listed at paragraph 7.2 of this Singapore Addendum.
5. REQUEST TO WITHDRAW CONSENT
5.1 You may withdraw your consent for the collection, use and/or disclosure of
your Personal Data in our possession or under our control at any time by
submitting your request to the contact details listed at paragraph 7.2 of this
Singapore Addendum.
5.2 We will process your request as soon as practicable such a request for
withdrawal of consent being made, and will thereafter refrain from collecting,
using and/or disclosing your Personal Data in the manner stated in your request.
6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 We will take appropriate measures to keep your Personal Data accurate,
complete and updated.
6.2 We will also take commercially reasonable efforts to take appropriate
precautions and preventive measures to ensure that your Personal Data is
adequately protected and secured. Appropriate security arrangements will be
taken to prevent any unauthorized access, collection, use, disclosure, copying,
modification, leakage, loss, damage and/or alteration of your Personal Data.
However, we cannot assume responsibility for any unauthorized use of your
Personal Data by third parties which are wholly attributable to factors beyond
our control.
6.3 We will also take commercially reasonably efforts to ensure that the
Personal Data in our possession or under our control is destroyed and/or
anonymized as soon as it is reasonable to assume that (i) the purpose for which
that Personal Data was collected is no longer being served by the retention of
such Personal Data; and (ii) retention is no longer necessary for any other
legal or business purposes.
7. COMPLAINT PROCESS
7.1 If you have any complaint or grievance regarding about how we are handling
your Personal Data or about how we are complying with the PDPA, we welcome you
to contact us with your complaint or grievance.
7.2 The contact details of Frank Recruitment Group’s Chief Privacy Officer
(“CPO”) are:
Frank Recruitment Group Services Limited
The St. Nicholas Building
St. Nicholas Street
Newcastle-Upon-Tyne
Tyne & Wear UK NE1 1RF
Attn: Chief Privacy Officer
Email: privacy@tenthrevolution.com
7.3 Where it is an email or a letter through which you are submitting a
complaint, your indication at the subject header that it is a PDPA complaint
would assist us in attending to your complaint speedily by passing it on to the
relevant department within FRG to handle. For example, you could insert the
subject header as “PDPA Complaint”.
7.4 We will certainly strive to deal with any complaint or grievance that you
may have speedily and fairly.
UNITED STATES OF AMERICA ADDENDUM
I. If you would like a copy of FRG’s US comprehensive information security
program, please email FRG’s CPO at privacy@tenthrevolution.com.
If FRG receives a “Do Not Track” signal or request from a web browser, FRG will
not honor such request or signal. FRG has taken this position in part to provide
you with a personalized and efficient experience on the Websites.
As discussed in this Privacy Notice, there are third parties who conduct
tracking on the Websites.
Information about web beacons used by FRG and third parties with whom it
contracts can be found in Section XII.F of the Privacy Notice above.
II. For information on FRG US’s compliance with the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks, see the section titled “What protection do I have if
FRG transfers my Personal Data to the US?” in our privacy policy,
https://www.frankgroup.com/privacy-notice/. Additionally, U.S. law requires
certain contracts entered into by FRG US contain the rights, obligations and
requirements set forth in Sections II(A) through II(C) inclusive below
(collectively, the “Privacy Shield Terms”). Accordingly, the following Privacy
Shield Terms, to which FRG reserves the right to revise from time to time
without notice, shall be incorporated by reference where these Privacy Shield
Terms are required in client contracts:
(A). In the event FRG US transfers to client or any of its affiliates, or
provides client or any of its affiliates with access to any Personal Data (as
defined for this Section II below) of European Union or Switzerland residents,
including employees of FRG or its affiliates and actual or prospective FRG
clients contacts or candidates, and client maintains, receives, has access to,
stores, uses or processes such Personal Data in the United States, client shall
comply with data protection, data security and confidentiality requirements at
least as strong as those set forth in the Privacy Shield Principles issued by
the U.S. Department of Commerce, as revised from time to time (collectively, the
“Principles”) During the term of such contracts and while client creates,
receives, maintains, stores, uses, processes or disseminates any Personal Data,
client shall:
1. use the Personal Data only for the specific and limited purposes intended in
the client contract including for recruitment purposes;
2. provide immediate written notice to either FRG US Parent or FRG US Sub as
applicable if (a) client determines that it can no longer meet its
obligation to provide the same level of protection of the Personal Data as
is required by the Principles, and in such case client shall cease
processing the Personal Data or (b) client becomes aware of any accidental
or unlawful destruction of, or accidental loss or alternation of or
unauthorized disclosure or access to, any Personal Data (a “Breach”) which
notice shall include a description of the quantity of Personal Data subject
to the Breach, the approximate length and duration of the Breach, the data
subjects whose Personal Data was subject to the Breach and a Breach
remediation plan;
3. at its cost, employ its best efforts to stop, limit and remediate the
Breach, perform a “root cause” analysis of the Breach, employ its best
efforts to prevent the same or a similar Breach from reoccurring and keep
FRG up to date on all its efforts under this subsection II(A)(3);
4. implement appropriate technical and organizational measures to protect
Personal Data against a Breach;
5. not transfer any Personal Data to third parties without the data subject’s
prior written or email consent (which either FRG US Parent or FRG US Sub as
applicable shall attempt to obtain after receiving notice from client of its
need to transfer Personal Data to a third party);
6. assist FRG US in responding to data subjects exercising their rights under
the Principles;
7. act only on instructions from FRG US; and
8. either have in place an independent recourse mechanism to handle data
subject complaints that complies with the requirements of the Principles or
make available an equivalent mechanism.
(B) Upon the termination or expiration of the applicable client contract, client
shall, at FRG US’s option, return all Personal Data to either FRG US Parent or
FRG US Sub as applicable or permanently destroy all Personal Data (and all
copies and derivative works thereof) in its care, custody or control except for
any Personal Data that applicable law, if any, requires client to maintain
(“Archival Personal Data”). With respect to any Archival Personal Data, client’s
obligations and requirements under this Section II shall remain in full force
and effect for as long as such Archival Personal Data remains in client’s care,
custody or control.
(C) If client forwards or gives access to any of the Personal Data to any third
party at any time, including any subprocessor or controller of client, client
shall ensure that its written contract with such third party contains the
Privacy Shield Terms.
(D) For purposes of this Section II, the term “Personal Data” shall have the
same meaning ascribed to that term as in the Principles which can be found at
https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg
as revised from time to time.
CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURES
Our goal is to enable individuals and organizations to comply as easily as
possible with the California Consumer Privacy Act’s requirement to protect the
privacy and data of consumers. As a recruitment service, we respect and protect
your privacy and security and are committed to following best practices to
support this principle.
Thanks for using FRG. Our goal is to enable individuals and organizations to
comply as easily as possible with the California Consumer Privacy Act’s
requirement to protect the privacy and data of consumers. As a recruitment
service, we respect and protect your privacy and security and are committed to
following best practices to support this principle.
We – meaning The Frank Recruitment Group, which is a trademark and brand owned
by rank Recruitment Group Services Limited and its subsidiaries, including
without limitation, Nigel Frank International Limited, Mason Frank International
Limited, Frank Recruitment Group UK Services Limited, Frank Recruitment Group
Services USA Ltd., Rebura Limited, Frank Recruitment Group Inc., Frank
Recruitment Group Services Inc., Frank Recruitment Group Private Limited
(Singapore), Frank Consulting Services Private Limited (Singapore), Frank
Recruitment Group Pty Limited (Australia), Frank Recruitment Group GmbH
(Germany), Frank Recruitment Group K.K. (Japan), Frank Recruitment Group Sp
Zo.o. (Poland), Frank Recruitment Group BV (Netherlands), Frank Recruitment
Group S.L. (Spain), Frank Consulting Services S.L. (Spain), Frank Recruitment
Group Sarl (Switzerland), Frank Recruitment Group Inc. /Groupe de Recrutement
Frank Inc. (Canada),Frank Consulting Services SAS (France), Frank Recruitment
Group SRL (Italy) and businesses operated by our group under the brand names
including Nigel Frank, Mason Frank, Nelson Frank, Jefferson Frank, The Revolent
Group, The Tenth Revolution Group, Anderson Frank, , Washington Frank, FRG
Technology Consulting, Rebura, Digital Revolution Awards, and Dynamic Jobs
(collectively, “we,” “us,” “our,” or “FRG”)–prepared this Privacy Addendum to
help you understand our practices regarding the collection, use, and disclosure
of information we collect from you through Revolent Group’s web applications,
our websites that link to this Privacy Addendum, and any other services we
provide to our customers (collectively, “Services”).
By accessing or using the Services, you agree to this Privacy Addendum, our Do
Not Sell Notice, Privacy Notice, the Terms of Use.
I. Information from Children
FRG is not directed to children under the age of 13 and we do not knowingly
collect personally identifiable information from children under the age of 13.
If we learn that we have collected personally identifiable information of a
child under the age 13, we will take reasonable steps to delete such information
from our files as soon as is practicable. Please contact us
at privacy@tenthrevolution.com, fill the webform here, or give us a call at
1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 if you believe we
have any information from or about a child under the age of 13.
II. California Consumer Privacy Act Disclosures
The California Consumer Privacy Act, or CCPA, requires businesses subject to
this law to provide consumers residing in California with certain rights
regarding their personal information.
At this time, we may sell your personal information, so the opt-out or opt-in
choices may apply. For more information, visit www.frankgroup.com/donotsell.
Here’s a summary of rights for California consumers under the CCPA:
A. Your Right to Opt Out. You have the right to tell businesses that do sell
your personal information to third parties (i.e. not us) not to sell it at any
time. Businesses that sell your personal information to third parties must also
ensure that the third parties do not resell it unless the business notified you
explicitly and provided you with a chance to opt out of resales. These opt-out
rights apply to businesses that do not know your age, or know you are older than
16. Additionally, we must also respect opt outs made by your authorized agent if
such authorized agent provides signed written permission from you to do so.
B. Your Right to Opt In. If a business has actual knowledge that you are between
ages 13 and 16 (e.g., based information the business collects), businesses
cannot sell or allow resales of your personal information without your
affirmative authorization. If a business has actual knowledge that you are
younger than 13, it may not sell or allow resales of your personal information
without your parent or guardian’s affirmative authorization. This is your right
to opt in.
C. Your Right to Disclosures. You have the right to know:
1. A link to FRG’s “Do Not Sell My Personal Information” notice.
a) Please visit www.frankgroup.com/donotsell.
2. A description of a consumer’s rights pursuant to CCPA Section 1798.120:
(a) Your Right to Opt Out. If you’re a consumer residing in California and we
sell your information to third parties, you can tell us at any time not to sell
your personal information. This right to opt-out applies if we do not know your
age or if we know you are older than age 16. Additionally, we must also respect
opt outs made by your authorized agent if such authorized agent provides signed
written permission from you to do so.
(b) Your Right to Opt In. If we have actual knowledge that you are between ages
13 and 16 (e.g., based information we collect, or because someone informed us),
we will never sell your personal information without your affirmative
authorization. If we have actual knowledge that you are younger than 13, we will
never sell your personal information without your parent or guardian’s
affirmative authorization. This is your right to opt in.
(c) Do We Sell Your Personal Information? At this time, we may sell your
personal information and you can opt out at any time. If you opt out, or for
children 16 and younger, if you have not opted in, we will not sell your
personal information to third parties unless you expressly authorize us to do
so.
3. A description of a consumer’s rights pursuant to CCPA Section 1798.110:
California consumers have the right to request that we disclose to you:
(a) The categories of personal information it has collected about you.
(b) Personal information is information that identifies or relates to a
particular consumer or household including name, postal address, email address,
IP address, social security number, personal property records, purchasing
histories, biometric information, internet activity such as browsing or search
history, geolocation data, employment information, education information and
inferences drawn from this information, in so far as it is not publicly
available information. In addition to the above types of personal information
that we may collect, FRG may collect personal information. Personal information
also includes any of the following:
(i) Name;
(ii) Contact details e.g. street address, email address, telephone number;
(iii) Work Experience;
(iv) Job Title;
(v) Professional Certifications;
(vi) Education & Qualifications;
(vii) Skills;
(viii) Career History;
(ix) Salary Range;
(x) Right to work status/citizenship;
(xi) Other information relevant to help us provide technology talent creation
services;
(xii) References from past employers; and
(xiii) IP address
4. The categories of third parties with whom the business shares personal
information.
(a) All users of the websites and/or our services
(i) To third parties where we have retained them to provide services that we or
you have requested or that FRG clients have requested including references,
qualifications and background reference checking services and to verify the
details you have provided from third party sources.
(ii) To third parties to provide data storage, CV/resume parsing, data cleansing
and marketing services to FRG where such third parties have agreed to maintain
the confidentiality of, and to protect, your personal information in accordance
with applicable law.
(iii) To third parties to assist with credit control and payment management.
(iv) To third parties, regulatory or law enforcement agencies if we believe in
good faith that we are required by law to disclose it in connection with the
detection of crime, the collection of taxes or duties, in order to comply with
any applicable law or order of a court of competent jurisdiction, in connection
with legal proceedings or other similar cause or circumstance.
(v) To FRG affiliates, whose locations can be found
at https://www.frankgroup.com/contact . These entities will process your
personal information in accordance with the Privacy Addendum.
(vi) In the event of a sale, merger, liquidation, receivership or transfer of
all or substantially all of the assets, or a controlling interest in the equity,
of FRG (or any of its group companies) provided that such counterparty(ies) to
any such transaction agrees to adhere to the terms of the Privacy Addendum (or a
similar document) and applicable law.
(b) Actual or Prospective FRG Clients
(i) To FRG clients in order for them to determine if you are or may be qualified
to fill a vacancy.
(ii) To third parties that you authorize us to send your personal information to
such as your CV
(iii) To third parties to determine if an FRG client or other entity (or their
respective affiliates) to whom FRG presented you has (a) employed you or (b)
retained you or any entity (i) that employed you or (ii) that retained you or
(iii) in which you have an financial interest.
(c) Individuals who work for FRG clients (i.e. a client contact)
(i) To Contacts in the course of providing your company or employer with
recruiting services and to further the recruitment process.
(ii) To third parties where we have retained them to provide services that you
have requested including Freelancer skill tests and other testing.
(iii) To third parties to determine if an FRG client or other entity (or their
respective affiliates) to whom FRG presented a candidate has (a) employed the
candidate or (b) retained the candidate or any entity (i) that employed the
candidate or (ii) that retained the candidate or (iii) in which the candidate
has a financial interest.
5. The categories of sources from which the personal information is collected.
(i) We collect personal information from you actively when you enter it into our
services (e.g., your name, your CV/resume, etc.).
(ii) We collect personal information passively when you access our services, to
the extent your web browser provides this information to our servers (e.g., your
operating system) and also based on your service usage (e.g., when and from what
IP address you log on to our services).
(iii) We collect personal information when it is provided to us by either
yourself or a third party (for example, LinkedIn, Jobboard, CV databases, etc.).
6. The business or commercial purpose for collecting or selling personal
information.
(a) Why do we process your personal information?
(i) Generally, we use your personal information for our business and activities,
and in our efforts to expand and improve our business. Examples include:
1. All users of the Websites and/or our services
(a) To provide our technology talent creation services to you, your employer or
your company;
(b) To facilitate the recruitment process, including but not limited to:
(i) Qualifying and submitting Candidates;
(ii) For clients, negotiating FRG terms of business;
(iii) Arranging interviews and obtaining feedback;
(iv) Negotiating compensation packages; and
(v) Providing post placement follow up.
(c) Where permitted by applicable law and unless you tell us otherwise, we (or a
third party to whom we have provided your Personal Data under part VI below of
this Privacy Notice) may send you emails, SMS messages, or text messages
(standard SMS or text message rates may apply);
(d) To assess data about you against vacancies which we judge may be suitable
for you;
(e) To third party vendors to assist us in hosting, managing and operating our
websites;
(f) To third party vendors who provide data analysis and data updating services
to us;
(g) To third party vendors who provide email and other communications related
services to us
(h) To enable you to submit your CV/resume to FRG, apply online (including
through the Websites) for jobs or to subscribe to alerts about jobs we think may
be of interest to you;
(i) To enable us to develop and market other products and services and where you
have consented to being contacted for such purposes;
(j) To improve our customer service and to make our services more valuable to
you (including tailoring the Websites when you log on to enrich your personal
online experience);
(k) To send you electronically or by post surveys, reports, FRG event details,
promotions, offers, networking and client events and general information about
relevant industry sectors which we think might be of interest to you, where you
have consented to being contacted for such purposes (and we will provide you
with an opportunity to opt out);
(l) To identify you, and respond to and process your requests for information
and provide you with a product or service;
(m) To amend records to remove personal information;
(n) To use your information on an anonymized basis to monitor compliance with
our equal opportunities policy, other FRG policies and any legal or compliance
requirements;
(o) To use your information on an anonymized basis to create marketing materials
such as a salary survey; and
(p) To carry out our obligations arising from any contracts entered into between
you and us, and for other everyday business purposes that involve use of
personal information.
2. Actual or Prospective Candidates
(a) To help find you a job;
(b) To contact you about jobs that FRG is filling or may fill for FRG clients;
(c) To provide you or your company with information about the job market;
(d) To communicate with you (permanent hire candidates), your employer or your
company (contract candidates) after you or it has started a job to make sure all
is going well or to remedy, or attempt to remedy, any problems;
(e) To answer any questions you have about a job or the job market;
(f) To fulfill any aspect of your Employment Agreement or Contract of Employment
with FRG;
(i) To third party vendors who provide customer relationship management database
services to us;
(ii) To third party vendors who provide data analysis and data updating services
to us
(iii) To third party vendors who provide document execution, transmission and
storage services to us
(iv) To third party vendors who provide email and other communications related
services to us
(g) To collect any money due, or allegedly due, to FRG or any FRG client (or
FRG’s client’s client);
(h) To obtain or inquire about any property (including computers and
confidential business information) owned, or allegedly owned, by FRG or any FRG
client (or FRG’s client’s client);
(i) To determine if an FRG client or other entity (or their respective
affiliates) to whom FRG presented you has (a) employed you or (b) retained you
or any entity (i) that employed you or (ii) that retained you or (iii) in which
you have an financial interest;
(j) To establish, exercise or defend any legal claims; and
(k) To assist you (permanent hire candidates), your employer or your company
(contract candidates) if you are dissatisfied or dislike the job, or any aspect
of it.
3. Individuals who work for FRG clients (i.e. a “client contact”)
(a) To fill an open vacancy at your company or employer;
(b) To contact you about candidates for jobs with whom FRG has a relationship;
(c) To provide you with information about the job market;
(i) To third party vendors who provide customer relationship management database
services to us;
(ii) To third party vendors who provide data analysis and data updating services
to us
(iii) To third party vendors who provide document execution, transmission and
storage services to us
(iv) To third party vendors who provide email and other communications related
services to us
(d) To communicate with you after your company or employer has hired/retained an
FRG candidate to make sure all is going well and to remedy, or attempt to
remedy, any problems;
(e) To negotiate and fulfil any aspect of your company’s or employer’s contract
with FRG Group;
(f) To answer any questions you have about a job or a candidate or your
company’s or employer’s contract with FRG;
(g) To resolve any issue with the issuance, payment, collection or enforcement
of an FRG invoice;
(h) To collect any property owned by FRG or any FRG candidate
(i) To third parties to determine if a FRG client or other entity (or their
respective affiliates) to whom FRG presented a candidate has (a) employed the
candidate or (b) retained the candidate or any entity (i) that employed the
candidate or (ii) that retained the candidate or (iii) in which the candidate
has a financial interest; and
(J) To establish, exercise or defend any legal claims.
7. The specific pieces of personal information it has collected about that
consumer.
(a) Please email us at privacy@tenthrevolution.com, fill out the webform here,
or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code
717 to request this information. Before we can respond to your request, we’ll
need to verify your identity.
8. A description of a consumer’s rights pursuant to CCPA Section 1798.115:
(a) If we sell your personal information or disclose it for a business purpose,
you have the right to know:
(i) The categories of personal information that the business collected about the
consumer.
(aa) See Section 3 4) above (e.g., web log data, registration data, resume/CV
data, etc.).
(ii) The categories of personal information that the business sold about the
consumer and the categories of third parties to whom the personal information
was sold, by category or categories of personal information for each third party
to whom the personal information was sold.
(aa) See Sections 3 4), 3 5) and 3 6) above.
(iii) The categories of personal information that the business disclosed about
the consumer for a business purpose.
(aa) See Section 3 6) above.
(b) If we sell your personal information or disclose it for a business purpose,
you have the right to request that we disclose to you (1) the categories of
personal information that we collected about you, (2) the categories of personal
information we sold about you and the categories of third parties to whom we
sold it, by category of personal information for each third party to whom we
sold your personal information and (3) the categories of personal information
that the business disclosed about the consumer for a business purpose. We are
required to verify your identity before providing you with this information if
the information would constitute your personal information.
To exercise these important rights, please: mail us
at privacy@tenthrevolution.com or call us toll free at
1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 to request this
information. Before we can respond to your request, we’ll need to verify your
identity.
(c) If we sell your personal information to a third party or disclose it for a
business purpose, we are required to disclose:
(i) The category or categories of consumers’ personal information we sold, or if
we have not sold your personal information, we shall disclose that fact.
(aa) If we sell your personal information, it will be in the form of your
CV/resume, anonymized or pseudonymized.
(ii) The category or categories of consumers’ personal information it has
disclosed for a business purpose, or if the business has not disclosed the
consumers’ personal information for a business purpose, it shall disclose that
fact.
(aa) We rely on vendors to operate our infrastructure, and accordingly for each
category of personal information that we disclosed above as a category that we
collect, we disclose it to one of our third-party vendors for a business purpose
(i.e. to develop, market, provide and support our business services). Those
categories are: web log data, registration data, payment data, service usage
data, customer content, consumer content and marketing data.
(d) If we sell your personal information to a third party, it is not allowed to
resell it unless we notified you explicitly and provided you with a chance to
opt out.
(aa) We do not allow third parties to whom we sell your personal information to
resell the personal information, so no opt-out choices apply.
See https://www.frankgroup.com/privacy-notice/#ccpa for details.
9. A description of a consumer’s rights pursuant to CCPA Section 1798.125:
(a) Businesses, including us, may not discriminate against you because you
exercised any of your consumer privacy rights such as by: (1) denying you goods
or services; (2) charging you different prices or rates for goods or services,
including via discounts or other benefits or penalties; (3) providing you a
different level or quality of goods or services or (4) suggesting that you will
receive a different price or rate for goods or services or a different level or
quality of goods or services. Businesses may however discriminate where any
difference is reasonably related to the value provided to you by your data.
(b) Businesses, including us, may offer you financial incentives, including
payments as compensation, for the collection, sale or deletion of your personal
information. If we offer any incentives we will (1) notify you about them in our
privacy policy and in any California-specific descriptions of consumer privacy
rights we post and (2) only enroll you in them with you opt-in consent after
disclosing all material incentive program terms to you. Incentive programs may
never be unjust, unreasonable, coercive, or usurious.
(i) We do not currently offer any financial incentives.
10. A description of a consumer’s rights pursuant to CCPA Section 1798.105:
(a) You have the right to request that we delete any personal information about
you that we have collected. Before we delete any information, we’ll need to
verify your identity. If we delete your information, we’ll also instruct our
vendors (aka service providers) to delete it. The CCPA does not obligate us to
delete information under all circumstances, including where we need the
information to provide our services to you, to detect security incidents, to
identify errors in our services, or to comply with legal obligations. If you
request that we delete information, we’ll let you know if we are deleting it or
if we are not deleting it based on exemptions provided by the CCPA.
11. One or more designated methods for submitting requests (at minimum, a
toll-free telephone number):
(a) You may submit any consumer privacy requests by emailing us
at privacy@tenthrevolution.com, fill out the webform below, or by calling us
toll free at 1-866-I-OPT-OUT (1-866-467-8688) and entering Service Code 717.
Before we can respond to your request, we’ll need to verify your identity.
III. Your Right to Data Deletion. You have the right to request that we delete
any personal information about you that we have collected. Before we delete any
information, we’ll need to verify your identity. If we delete your information,
we’ll also instruct our vendors (aka service providers) to delete it. The CCPA
does not obligate us to delete information under all circumstances, including
where we need the information to provide our services to you, to detect security
incidents, to identify errors in our services, or to comply with legal
obligations. If you request that we delete information, we’ll let you know if we
are deleting it or if we are not deleting it based on exemptions provided by the
CCPA. You may also delete personal information by using our services dashboard
as described above.
IV. Your Anti-Discrimination Rights. Businesses may not discriminate against you
exercising any of your consumer privacy rights such as by: (1) denying you goods
or services; (2) charging you different prices or rates for goods or services,
including via discounts or other benefits or penalties; (3) providing you a
different level or quality of goods or services or (4) suggesting that you will
receive a different price or rate for goods or services or a different level or
quality of goods or services. Businesses may however discriminate where any
difference is reasonably related to the value provided to you by your data. We
will not discriminate against you in any way for exercising your privacy rights.
V. Your Rights Regarding Financial Incentives. Businesses may offer you
financial incentives, including payments as compensation for the collection,
sale or deletion of your personal information. In this case a business must: (1)
notify you about the incentives in its Privacy Addendum and in any
California-specific descriptions of consumer privacy rights it posts and (2)
only enroll you in them only with your opt-in consent after disclosing all
material incentive program terms. Incentive programs may never be unjust,
unreasonable, coercive, or usurious. We do not currently offer any financial
incentives.
VI. Designated methods for submitting requests. We offer three ways to express
your privacy preferences: the following interactive web form, our email
at privacy@tenthrevolution.com, and the toll free phone number below.
Show/Hide privacy manager.
Privacy Request Manager
OPTION 1: SUBMIT A WEB FORM REQUEST
First Name: Last Name: Email: State of Residence: Other Alabama Alaska Arizona
Arkansas California Colorado Connecticut Delaware District Of Columbia Florida
Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine
Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska
Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota
Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota
Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming
I am a: Customer Employee Job Applicant Vendor Ad/Email Recipient Other Tell me
more about the data you collect, disclose and / or sell Do not sell my personal
information (if applicable) Delete my personal information Send me a copy of my
personal information Other:
By clicking "Affirm & Submit" you affirm the information above is accurate and
acknowledge that we may need to verify your identity and your state of residence
to determine if we can fulfill your request. Error: Please complete all form
fields, check at least one request box and solve the Captcha to submit. You have
successfully submitted your request.
OPTION 2: CALL TOLL FREE
Or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code
717#.
PRIVACY REQUEST MANAGEMENT BY CCPATOLLFREE.COM
VII. Changes to Privacy Addendum
Any information that we collect is subject to the Privacy Addendum in effect at
the time such information is collected. We may, however, revise the Privacy
Addendum from time to time. If a revision is material, as determined solely by
us, we will notify you, for example via email. The current version will always
be posted to our Privacy Addendum.
If you have any questions about this Privacy Addendum, or wish to exercise any
of your privacy rights, please contact us at privacy@tenthrevolution.com or at
any of the methods described above.
AUSTRALIA ADDENDUM
I. For users accessing the Websites or using our services in Australia, we
comply with Australian privacy requirements including the Privacy Act 1988 (Cth)
and Australian Privacy Principles, the Spam Act 2003 (Cth), the Do Not Call
Register Act 2006 (Cth) and any applicable state/territory privacy laws or
industry codes.
II. We will deal with your Personal Data (which has the same meaning as
“Personal Information” under the Privacy Act 1988 (Cth)) in accordance with
those laws, namely any information from which your identity is apparent or can
be reasonably ascertained.
III. Residents of Australia accessing and using the Websites or services are
notified that:
A. your Personal Data will be held and processed overseas including in the
United States, United Kingdom, Berlin, Germany or Singapore where our offices
are located and other countries in which we may open offices in the future. We
may also disclose your personal information to others, like our consultants,
agents, contractors and service providers, and those that act as data
processors, auditors or external advisers, and may be held and processed in
other countries including without limitation those listed at the beginning of
this subsection “A”;
B. If we use your Personal Data to contact you and you would prefer us not to,
or if you indicate a preference for a method of communication, please let us
know and we will do our best to respect your preference. When your choice is to
continue to deal with us, we take it that you agree to and consent to us using
your Personal Information in these ways, providing we follow the system and
approach we explain in this Privacy Notice and comply with the applicable law.
Where we do not have your Personal Information, we are not able to contact you,
process your requests or provide our services to you; and
C. the governing law for the purposes of the Terms of Use and Privacy Notice,
and any matters relating to them, including all disputes, will be governed by
the laws of New South Wales, Australia. You unconditionally submit to the
non-exclusive jurisdiction of the courts having jurisdiction there.
IV. You may wish to contact us to request access to your Personal Information,
to seek to correct it or to make a complaint about privacy. Our contact details
are set out below:
Frank Recruitment Group Pty Ltd
Suite 5, Level 3
350 Collins Street
Melbourne VICTORIA 3000
Australia
Email: privacy@tenthrevolution.com
We will respond to your request for access to Personal Information we hold about
you as soon as we reasonably can, including if we are unable to provide you with
access (such as when we no longer hold the information).
We do not impose any charge for a request for access, but we may charge you a
reasonable fee for our costs associated with providing you with access and
retrieval costs.
For complaints about privacy, we will establish in consultation with you a
reasonable process, including timeframes, for seeking to resolve your complaint.
CANADIAN ADDENDUM
1. Introduction
This Canada Addendum (“Canada Addendum”), in addition to the forgoing Privacy
Notice, sets out the basis on which all “Personal Information” (“Personal
Information” means information about an identifiable individual, including but
not limited to sensitive Personal Information), that Frank Recruitment Group
Inc. / Group de Recruitement Frank Inc. and its affiliated entities and their
respective representatives trading under the FRG brand (collectively for the
purposes of this Canada Addendum, “FRG,” “we,” “our,” or “us”) collects from
you, or that you provide to us via the Websites (as defined elsewhere in the
Privacy Notice) will be processed by us in Canada. If there is a conflict
between the Privacy Notice and this Canada Addendum, the Canada Addendum
controls with respect to Canadian users of our Websites. Please read the
following carefully to understand our views and practices regarding your
Personal Information in Canada and how we will treat it. All capitalized/defined
terms not defined herein are defined elsewhere in the Privacy Notice.
II. Canadian Privacy Law and Privacy Principles
FRG is committed to maintaining the confidentiality, security, and accuracy of
your Personal Information in accordance with applicable Canadian federal and
provincial law, including but not limited to the Canadian Personal Information
Protection and Electronic Documents Act (“PIPEDA”), Canada’s Anti-Spam
Legislation, SC 2010 c 23 (“CASL”), and the data privacy laws of Canada’s
provincial counterparts including but not limited to the British Columbia
Personal Information Protection Act, SBC 2003 c 63 (“BC PIPA”), Alberta Personal
Information Protection Act, SA 2003 c P-6.5 (“AB PIPA”), and Quebec Act
respecting the Protection of Personal Information in the Private Sector, CQLR c
P-39.1 (“Quebec Private Sector Act”) to govern our activities as they relate to
the use of your Personal Information. As part of this commitment, we follow the
ten privacy principals established under the PIPEDA. These principals are as
follows:
* Principle One: Accountability
FRG is responsible for the Personal Information it controls. FRG has designated
its Chief Privacy Officer (privacy@tenthrevolution.com) as responsible and
accountable for compliance with the Canadian Privacy Principles and other
applicable Canadian data privacy law.
* Principle Two: Identifying Purpose
FRG must identify the purposes for which Personal Information is used,
collected, and disclosed before or at the time we collect Personal Information.
FRG demonstrates its compliance by making the Privacy Notice and this Canada
Addendum available to individuals, among other actions.
* Principle Three: Consent
Your knowledge and consent are required for the collection, use or disclosure of
your Personal Information, except where inappropriate or permitted by Canadian
law. Depending on the level of sensitivity of the Personal Information, this
consent may be implied or expressed; however, wherever commercially feasible,
FRG shall attempt to obtain express consent. Consent to our use of your Personal
Information can be withdrawn at any time by sending an email requesting same
to privacy@tenthrevolution.com.
* Principle Four: Limited Collection
FRG must collect Personal Information by fair and lawful means and limit its
collection of Personal Information to those details reasonably necessary for the
purposes identified. Accordingly, FRG does not collect your race, ethnicity, or
health Personal Information nor do we use Canadian Social Insurance Numbers (or
a foreign equivalent) to identify or organize the information we hold, and will
not record it if you submit it.
* Principle Five: Limiting Use, Disclosure and Retention
We may only use or disclose Personal Information for the purpose for which it
was collected unless you have otherwise consented, or when it is required or
permitted by law. We may only retain your Personal Information for the period of
time required to fulfill the purpose for which it was collected (taking into
account our statutory and contractual obligations to retain information).
* Principle Six: Accuracy
We shall maintain your Personal Information in as complete, accurate and
up-to-date form as is necessary to fulfill the purpose for which we are to use
it. Please inform us if any of your information changes by contacting us
at privacy@tenthrevolution.com so that we can make any necessary changes.
* Principle Seven: Safeguarding Information
We must protect your Personal Information by following security safeguards that
are appropriate to the sensitivity level of the Personal Information. For
example, we have a document minimization process in our office to prevent
inadvertent disclosures of your Personal Information. We also physically lock
our offices after business hours to avoid/prevent unauthorized access.
* Principle Eight: Openness
We are required to make information available to you that is specific and
easy-to-understand concerning FRG’s policies and practices that apply to the
management of your Personal Information. A key method of making such information
available is via this Canada Addendum, via our website.
* Principle Nine: Access
Upon request to privacy@tenthrevolution.com, we shall inform you of the use,
disclosure, and existence of your Personal Information, and shall give you
access to it. You may verify the completeness and accuracy of your Personal
Information, and may request amendments to your Personal Information for these
reasons, if appropriate. Contact us at the email address above. We will attempt
to respond to requests for summary information within 30 days of receipt. If you
send us a more detailed request (typically these require archival or other
retrieval costs), we may take longer to respond and you may be subject to our
normal disbursement and professional fees to the highest extent permitted by
applicable law.
* Principle Ten: Challenging Compliance
Direct any complaints, suggestions, enquiries or questions respecting our
privacy practices, compliance, or these principles by
contacting privacy@tenthrevolution.com.
III. May We Deny Access To Your Personal Information?
Your right to access your Personal Information is not absolute. We may deny
access to your Personal Information when:
* required by applicable law;
• such Personal Information relates to existing or anticipated legal
proceedings against you or was generated as a result of a dispute resolution
mechanism (whether arbitration, mediation, court cases, or similar
proceedings);
• when granting you access would have an unreasonable impact on other
people’s privacy, security or proprietary information;
• to protect our rights and property; or
• where the request is frivolous or vexatious or generates costs which are
prohibitively expensive.
We shall explain to you in writing why we deny a request for access to, or
refuse a request to correct your Personal Information.
IV. How To Ask A Question Or File A Complaint
FRG has a Chief Privacy Officer who may be contacted to answer any comments or
questions about this Canada Addendum, including where to file a complaint.
Please forward your communications to:
E-mail: privacy@tenthrevolution.com
Telephone: +44 20 733 0865
Address:
Frank Recruitment Group Inc. / Group de Recruitement Frank Inc.
d/b/a FRG
The St. Nicholas Building
St. Nicholas Street
Newcastle-Upon-Tyne
Tyne & Wear U.K. NE1 1RF
Attn: Chief Privacy Officer
Attention: Chief Privacy Officer
V. Sending Us Information Over The Internet
With respect to CASL, by using our Websites or Services, you hereby expressly
consent to receiving, during and after our business relationship, electronic
messages from FRG, including via emails and through social media, providing
information to you including newsletters, updates, alerts, other publications,
news and communications, other information of interest to you and/or information
on our services. You can withdraw this consent or modify your preferences as to
the types of electronic messages which you wish to receive from us, at any time,
simply by notifying us at privacy@tenthrevolution.com or by using the
unsubscribe mechanism on any of our electronic messages.
VI. Location of Personal Information and Transfers of Personal Information
Outside Canada
Your Personal Information is stored on various servers, including our own, and
those maintained by our third party service providers who help us provide our
services to you. These servers may be located outside of Canada. Accordingly, by
providing us Your Personal information, you explicitly consent to our transfer
of your Personal Information to countries outside of Canada. If you do not wish
for your Personal Data to be transferred outside of Canada, do not provide your
Personal Information to us. You have rights to access and rectification of your
Personal Information, among other rights, which you may invoke as otherwise
described in this Canada Addendum or this Privacy Notice. When we transfer your
Personal Information outside of Canada, we take commercially reasonable and
legally required measures with data importers as is reasonably necessary for the
protection of such Personal Information, which may include entering into
contractual clauses or data protection/security agreements as appropriate. As
required by the Quebec Private Sector Act, in general, our server is located in
the United Kingdom; our customer relationship database provider keeps its main
server in Germany and its disaster recovery server in France; our word
processing and office program, email, and cloud storage provider has its main
servers in the United Kingdom and the European Union; and another cloud storage
provider has its main server in Ireland. For more details about your specific
Personal Information and where it is located, please
contact privacy@tenthrevolution.com.
VII. What If I Do Not Agree With This Canada Addendum?
Please do not submit any Personal Information to us if you do not agree to our
processing of your Personal Information as described herein in this Canada
Addendum.
VIII. Changes to this Canada Addendum
We reserve the right to change this Canada Addendum and Privacy Notice from time
to time by updating this Canada Addendum on our website or updating the Privacy
Notice as described above. Any changes to this Canada Addendum and Privacy
Notice will be posted on this Website so you are always aware of what
information we collect, how we use it, and under what circumstances, if any, we
disclose it. We encourage you to check this Website frequently for updates. Your
continued use of this Website or any FRG services shall constitute your
acceptance of the revised Canada Addendum.
FRG will interpret and enforce this Canada Addendum in accordance with all
applicable law.
This Canada Addendum was updated on June 21, 2021.This Canada Addendum was last
updated on July 16, 2021.
JAPANESE ADDENDUM
Frank Recruitment Group株式会社（以下「当社」）は登録者の個人情報の取り扱いについては個人情報保護法及びＪＩＳＱ15001：2006
に基づき 適正な管理に努めてまいります。
Frank Recruitment Group K.K (hereinafter referred to as “FRG“) will endeavor to
properly manage the handling of personal information of registrants based on the
Act on the Protection of Personal Information and JISQ15001: 2006.
ここでいう個人情報とは、当社に提供する個人（以下「本人」という）に関する情報で、氏名、住所、生年月日、電話番号、メールアドレス、その他の記述の組み合わせにより本人を特定できる情報をいいます。
Personal information is the information of the individual ( hereinafter referred
to as “person“) provided to and, which is the information received by the person
who entered the name, entry, date of birth, telephone number, email address, and
other versions.
個人情報の収集・利用目的 個人情報の収集・利用目的
皆さまからお預かりした個人情報は、以下の目的にのみ利用いたします。
Purpose of collection and use of personal information Purpose of collection and
use of personal information
Personal information entrusted to you will be used only for the following
purposes.
1. 人材派遣又は有料職業紹介等における最適な仕事のご案内・仕事に関するご連絡、及び契約締結に関する業務。
Guidance on optimal work in contract or perm, contact for introduce job details
and work related to contract conclusion.
2. 提供していただいた本人の個人情報は、就職や転職のために、第三者である求人企業に提供するため。
To provide the personal information of the person provided to a third-party to
company for applied to company.
3. 当社のサービス向上を目的として、意見、要望、情報の提供をお願いするために、個人情報を利用する場合。
We may use personal information to request opinions, requests, and information
for the purpose of improving our service.
上記以外の目的で利用する場合は、事前にお知らせし同意を得たうえで利用いたします。
If we use it for purposes other than the above, we will inform you in advance
and obtain your consent before using it.
個人情報の利用、提供について
About the use and provision of personal information
当社は収集目的の範囲内で個人情報を委託する場合があります。
We may entrust personal information within the scope of the purpose of
collection.
また、以下の場合を除き、本人の同意を得ずに第三者に提供をすることはいたしません。
In addition, except in the following cases, we will not provide it to a third
party without the consent of the person.
・ 人の生命、身体又は財産の保護のために必要がある場合であり、本人の同意を得ることが困難な時。
・ 公衆衛生の向上又は児童の健全な育成の推進のために特に必要のある場合であり、本人の同意を得ることが困難な時。
・
国の機関若しくは地方公共団体又はその委託を受けた者が法令の定める事務を遂行することに対して協力する必要があり、本人の同意を得ることにより当該事務の遂行に支障を及ぼすおれがある時。
・ 法令に基づく場合。
・ 合併その他の事由による事業の承継に伴って個人情報の提供が必要な場合。
・ When it is necessary to protect the life, body or property of a person and it
is difficult to obtain the consent of the person.
・ When it is particularly necessary to improve public health or promote the
sound development of children, and it is difficult to obtain the consent of the
person.
・ It is necessary for a national institution or a local public body or a person
entrusted with it to cooperate in carrying out the affairs stipulated by laws
and regulations, and obtaining the consent of the person will hinder the
performance of the affairs. At one point.
・ When required by law.
・ When it is necessary to provide personal information due to business
succession due to merger or other reasons.
個人情報の取り扱いについて
Handling of personal information
ご提供いただいた個人情報は、適切に取り扱います。
またご本人は、当社に個人情報を提供することは任意ですが、もしご提供をいただけなかった場合は、当社はご登録やサービスをお断りする場合がございます。
We will handle the personal information you provide appropriately.
In addition, the person is voluntary to provide personal information to us, but
if we do not provide it, we may refuse registration or service.
個人情報に関する苦情・相談 に関する苦情・相談及び開示等の請求について
及び開示等の請求についてお預かりした個人情報に関する苦情・相談につきましては、速やかに対応させていただきます。
Complaints about personal information / complaints about consultations /
requests for consultations and disclosures, etc. and requests for disclosures,
etc. We will promptly respond to complaints / consultations regarding personal
information that we have received.
お預かりした個人情報につきまして、利用目的の通知、開示、訂正、追加、削除、利用停止をご希望の場合は、ご本人であることを確認させていただいた上で速やかに対応いたします。
If you wish to notify, disclose, correct, add, delete, or suspend the use of
your personal information, we will promptly respond after confirming your
identity.
お気軽にお問い合わせください
Please feel free to contact us on;
Frank Recruitment Group株式会社への個人情報に関するお問い合わせ窓口
TEL：03-4563-8890
E メール privacy@tenthrevolution.com
※本同意書の効力、適用、解釈にあたっては、日本国法が適用されるものとします。
制定日 ２０XX年XX月XX日
CONTACT
Privacy Team
Frank Recruitment Group
St. Nicholas Building, 2nd Floor
St. Nicholas Street
Newcastle upon Tyne
United Kingdom
NE1 1RF
Email: privacy@frankgroup.com
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