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GENERAL PRIVACY POLICY

Last Updated: November 2019

ENTEGEE, Inc., (“Company”, “we”, “us”, “our”) is committed to protecting and
respecting your privacy.

This General Privacy Policy describes our privacy practices in relation to the
information we collect from you when you visit our website, which is accessible
at http://www.entegee.com, or when you access or use any applications or
features made available by us on or through or in connection with this Website
or our services that link to this General Privacy Policy (collectively, the
“Website”).

Note that when we collect Personal Information (defined below) from or about you
in connection with a potential job opportunity, our Candidate Privacy
Information Statement also applies and should be reviewed. You can read our
Candidate Privacy Information Statement by visiting
www.entegee.com/candidate-privacy-information-statement/. 


INDEX

 * Personal Information we may collect from you in using this Website
 * How we use your Personal Information
 * Do you have to give us your Personal Information?
 * How long do you keep my Personal Information?
 * Sharing with third parties
 * Cookies and automated technology
 * International users
 * Do we transfer or store your data outside the United States?
 * Data security
 * Your choices regarding your Personal Information
 * Your rights
 * Verifying your Identity
 * Shine the Light
 * Children’s privacy
 * Changes to this General Privacy Policy
 * Contact


PERSONAL INFORMATION WE MAY COLLECT FROM YOU IN USING THIS WEBSITE

When you visit and interact with this Website, we collect information about you,
including Personal Information. “Personal Information” means information that
identifies or relates to you, or as defined under applicable law. The following
identifies the categories of Personal Information we collect directly from you
(or about you) and how we collect such data:

 * Online forms and accounts: When you complete an online form or create an
   account on our Website, we may collect contact information such as your name
   (first and last), e-mail address, telephone number, physical address, and
   online user account details (collectively, “Identifiers”). We may also
   collect information pertaining to your professional qualifications, including
   your educational and professional background and salary (collectively,
   “Education and Qualifications”).
 * Communications with us online: We will collect any Personal Information you
   provide to us when you use our contact forms (for example “Contact”, “Contact
   us today”, “Send us a message”, or “Contact us about working together”).
   Providing us your Personal Information via our contact forms is not required;
   however, please note that fields marked with an asterisk (*) are mandatory
   fields, because we have determined we need this information to comply with or
   respond to your request, or to improve your future experiences with us and
   our Website. Other information or Personal Information you share with us when
   completing our contact forms is at your sole discretion. If you contact us,
   we will keep a record of that correspondence in accordance with our
   established retention protocol.
 * Marketing: We also may collect information for marketing purposes and
   analysis, including information on how you respond to email, SMS, phone and
   other marketing campaigns as well as feedback you provide about us and our
   services through our satisfaction surveys (collectively, “Correspondence and
   Feedback”).  Messaging and data rates may apply for any SMS, MMS, and other
   electronic communications (typically, this is based on your carrier and
   service plan).  For more information, please visit our Terms of Use.
 * Your company’s staffing needs: If you are interested in our staffing
   solutions, we may collect Personal Information and other information about
   you in connection with your company’s employment needs, including without
   limitation, Identifiers such as your name (first and last), e-mail address,
   telephone number, as well as your company name, job title, job function, job
   level, industry, staffing or employment challenges, current recruitment
   model, your location, sector, experience working with our brands, company
   registration number, purpose of attendance (at an event), size of
   opportunity, and type of staffing need.
 * Social media, online forums, blogs, message boards: We also may collect
   Personal Information and other information about you when you choose to
   interact with us through social media platforms on which we are active. In
   addition, we also may collect the Personal Information you make available on
   your public social network profiles and on other public locations, including,
   without limitation, on Facebook, LinkedIn, Twitter, Instagram, or other
   company websites and/or job boards. The Personal Information we collect in
   this manner may include Identifiers (name (first and last), contact
   information, and location) and Education and Qualifications (education,
   training courses and internships, and work experience), skill sets (for
   example, foreign language skills), professional or employment-related
   information (education and work experience), and any other information you
   make available on social media platforms and other public locations
   (collectively, “Social Media Information”).
 * Career opportunities: If you apply for a career opportunity with or through
   us, we may collect Personal Information and other information from you, which
   may include Identifiers such as your contact information (name (first and
   last), physical address, telephone number, e-mail address), and Education 
   and Qualifications, which includes education, training courses and
   internships, and work experience, skill sets (for example, foreign language
   skills) and any other information you listed on your resume or CV. For more
   information about our collection practices for job candidates, please visit
   our Candidate Privacy Information Statement by visiting
   www.entegee.com/candidate-privacy-information-statement/.
 * Cookies and automated technology: For more information about the information
   we collect about your equipment browsing actions, and patterns, please
   consult the “Cookies and automated technology” section below.
 * We also collect any other Personal Information you choose to provide to us or
   we obtain about you.

Sensitive Personal Information. When you visit or interact with our Website, you
are not required to submit information that may be considered sensitive,
including your race or ethnic origin or data concerning your health or sexual
orientation. If you decide to provide us with sensitive Personal Information, we
will handle the information according to the practices identified in this
General Privacy Policy as well as those identified in the Candidate Privacy
Information Statement available at
www.entegee.com/candidate-privacy-information-statement/. We reserve the right
to delete the information from our databases in accordance with applicable law.

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HOW WE USE YOUR PERSONAL INFORMATION

We collect and use the information or Personal Information we collect from or
about you, including your Identifiers, Education and Qualifications,
Correspondence and Feedback, and Social Media Information, for the following
business purposes:

 * to provide you, our clients and prospective clients, and our candidates and
   prospective candidates with our services.
 * to best tailor content and resources according to your preferences.
 * to respond to your requests or questions when you contact us.
 * to help us create, publish, and improve content most relevant to you.
 * to ensure that the content provided through the Website is presented in the
   most effective manner for you and for your device.
 * to allow you to participate in interactive features of our Website, when you
   choose to do so.
 * to further develop and improve the Website, and systems to better serve you.
   This mainly takes place in the context of new IT systems and processes so
   that information about you may be used in the testing of those new IT systems
   and processes.
 * where necessary, to comply with any legal obligation.
 * for our business contacts, to attempt to establish or strengthen a business
   relationship with you. This may include, for example, informing you how we
   can assist you with our services.
 * we also may use your information in:
   * investigating or responding to incidents and complaints, and/or
   * complying with investigations carried out by the police, government or
     regulators.

We also use the Personal Information we collect for commercial purposes. We may
use your Identifiers, Education and Qualifications, Correspondence and Feedback,
and Social Media Information in order:

 * to send you direct messaging or marketing via email, text message, and/or
   other communication means. You may opt-out of receiving future messaging or
   marketing communications at any time by emailing us using the information
   listed in the “Contact” section below.  Messaging and data rates may apply
   for any SMS, MMS, and other electronic communications (typically, this is
   based on your carrier and service plan).  For more information, please visit
   our Terms of Use.
 * to inform you about services, products, events that might be of interest to
   you (we may communicate by email, telephone, text message, mail and/or other
   communication methods).
 * to send to you other information – such as Company upcoming events or
   newsletters – that may be of interest to you.
 * to perform analytical research on our prospective client and candidate base,
   including the content, and the services/products in which they are
   interested.
 * to transfer data to third parties (see the “Sharing with third parties”
   section below).

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DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?

You do not have to provide your Personal Information to us when generally
navigating our Website. However, if you do not provide us with a required
minimum, it may limit the services you can receive from us.

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HOW LONG DO YOU KEEP MY PERSONAL INFORMATION?

We retain your Personal Information as long as necessary to fulfil the purposes
set out in this General Privacy Policy in accordance with applicable legal and
regulatory requirements.

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SHARING WITH THIRD PARTIES

To facilitate our efficient use of your information and Personal Information,
and to provide you with content and/or resources, to fulfil a request you make
of us, or to otherwise provide our services, we disclose your information,
including the Personal Information identified in the “Personal Information we
may collect from you in using this Website” section above, to the following
third parties. :

 * To our suppliers. We engage suppliers to carry out administrative and
   operational work in support of our relationship with you. The supplier(s) are
   subject to contractual and other legal obligations to preserve the
   confidentiality of your data and to respect your privacy, and they will only
   have access to and use the data they need to perform their functions.  The
   relevant suppliers are often IT suppliers (who, for example, host or support
   our IT systems, including information about you such as Identifiers and the
   information described in the “Cookies and automated technologies” section
   below), premises management companies (who, for example, look after physical
   security at our buildings, and therefore need to know about you to allow
   access to our buildings) and/or back office finance and accounting management
   providers (who, for example, need to handle details, such as Identifiers,
   professional or employment-related information, and financial information
   like a  bank account number of persons in order to process accounts payable
   and receivable). We also engage suppliers who provide technology services and
   solutions who, for example, provide video interview and skills assessment
   tools and may need access to your Identifiers, Education and Qualifications,
   Correspondence and Feedback, and Social Media Information. 
 * To other members of The Adecco Group. We are part of “The Adecco Group”, an
   organization of related companies located across the world whom are all
   subsidiaries of the same ultimate parent company, Adecco Group AG (a legal
   entity based in Switzerland).  The Adecco Group companies perform a range of
   services including but not limited to temporary staffing and direct hire
   placement services, payroll services, recruitment and selection services,
   testing solutions services, career transition services, talent development
   services, training and education services, outplacement and international
   mobility services.  We may share your information with other members of The
   Adecco Group for different reasons:
   * information is shared with members of The Adecco Group that provide IT
     functions for the The Adecco Group companies world-wide;
   * information may be shared with other affiliate companies of The Adecco
     Group locally and/or globally in furtherance of the services we or The
     Adecco Group provides.  A list of the countries in which we operate is
     available in the ‘choose your country’ function of our website at
     www.adeccogroup.com. 
 * Government & law enforcement. We will share your data with government,
   regulators or law enforcement agencies if, at our sole discretion, we
   consider that we are legally obliged or authorized to do so or we believe it
   would be prudent to do so; and/or
 * Corporate reorganization. As part of due diligence relating to (or
   implementation of) a merger, acquisition or other business transaction, we
   may need to disclose your data to the prospective seller or buyer and their
   advisers.

We do not sell your Personal Information to third parties.

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COOKIES AND AUTOMATED TECHNOLOGY

Automatic Data Collection. In addition to collecting Personal Information, we
may use automatic data collection technologies to collect certain statistical
(non-identifiable) information about your equipment, browsing actions, and
patterns. This includes (i) details about your visits to our Website, which may
include traffic data and location data, date and time of access, frequency and
other communication data; and (ii) information about your computer and internet
connection, which may include your IP address, operating system, browser type,
and host domain; and (iii) details of referring website actions and patterns.

Cookies. We may collect information from you using a “cookie.” “Cookies” are
small bits of data cached or stored on your computer based on your internet
activity. They can be placed on your computer both by us as well as by third
parties with whom we have a relationship, such as web analytic services and
advertising networks. Cookies help us track and understand how individuals use
and interact with our Website. For more information on the types of cookies that
we use and your ability to disable cookies, please see the “Your choices
regarding your Personal Information” section below and our Cookie Policy
available at www.entegee.com/cookie-policy.

Web Beacons. We use a technology known as web beacons to collect your web log
information. A web beacon is a small graphic used on a website or within an
e-mail message designed to track pages viewed or messages opened. Web log
information is gathered by the computer that hosts our Website (called a
“webserver”) when you visit our Website. Web beacons in e-mails help us
determine which of our e-mail messages were opened and whether a message was
acted upon. They also help us analyze the effectiveness of our web pages by
measuring the number of visitors to certain pages of our Website and how many
visitors click on key elements of it.

Social Media Plug-ins. Our Website uses social media plugins (“Plugins”) from
the social networks such as Facebook, LinkedIn, Twitter, and Instagram to enable
you to easily share information with others. We may use information collected
from the Plugins to learn about your interests and to help us better understand
how to serve you. This information may include your preferences about how to
contact you or further develop a business or professional relationship with you
as well as demographic data.  For more information, please visit our Cookie
Policy at www.entegee.com/cookie-policy

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INTERNATIONAL USERS

This General Privacy Policy is intended for individuals located in North
America. Users who use the Website understand that their data will be collected,
used, and stored in North America, in addition to other countries in the world
(for example, in other countries from which IT functions are provided to us).

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DO WE TRANSFER OR STORE YOUR DATA OUTSIDE THE UNITED STATES?

Your Personal Information may be transferred to and/or stored in any country
where we conduct business, which includes outside North America. By using our
Website or by otherwise providing information to us, you understand that the
information from or about you or your use of our Website may be transferred to
and/or stored in countries outside of your country of residence, including the
United States.

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DATA SECURITY

We maintain commercially reasonable security safeguards designed to protect the
Personal Information we collect against unauthorized use, disclosure, alteration
or destruction. Although we aim to protect the security and integrity of the
Personal Information we collect, we cannot guarantee or warrant that any
information, during transmission through the Internet or while stored on our
system or otherwise in any case, is 100% secure from intrusion by others. If you
have reason to believe that your interaction with us is not secure or that data
has been compromised, please immediately notify us of the problem by contacting
us using the contact information below.

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YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

Disabling Cookies and Managing the Collection of Your Personal Information. At
any time, you can disable cookies by adjusting your browser settings. Each
browser is different, so please refer to the specific instructions related to
your browser to learn more about cookie-related and other privacy and security
settings that may be available to you.

Please note, by disabling cookies, you may not be able to take full advantage of
the services offered by our Website.  For more information, please visit our
Cookie Policy at www.entegee.com/cookie-policy.

Do Not Track. Currently we do not alter our information collection and use
practices in response to Do Not Track signals.

Commercial E-mails, Newsletters, and Other Communications.  Where we send
marketing or other communications to you, you may opt out of receiving any
further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’
function when available. You can also exercise your opt-out right at any time by
contacting us using the information listed in the ”Contact” section below and
providing the following information: your name, your email address, a contact
telephone number, the marketing communications you would like to opt out of
receiving.

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YOUR RIGHTS

You have certain legal rights with respect to the Personal Information that you
provide and/or which we obtain about you depending on the state/country where
you reside.  For example, if you are a resident of California, the California
Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100, et seq.) provides you with
specific rights regarding your Personal Information depending on the nature of
your relationship with us. 

Where applicable, your rights include, among others:

 * Right to be informed about collection, sale or disclosure:  You have the
   right to be informed of the categories of Personal Information that we
   collect about you as well as the categories of sources from which the
   Personal Information was collected. You also have the right to be informed of
   the business or commercial purposes for which we use, disclose, or sell, your
   Personal Information as well as the categories of third parties with whom we
   share that Personal Information, as set forth in this General Privacy Policy.
 * Right to access and obtain a copy of your Personal Information:  You have the
   right to request that we disclose certain information to you about our
   collection, use, and disclosure of your Personal Information over the past 12
   months. Once we have verified your identity, we will disclose the specific
   pieces of Personal Information we collected about you in a portable and, to
   the extent technically feasible, in a readily useable format.
 * Right to delete:  In certain circumstances, you may have the right to request
   that your Personal Information is deleted, subject to certain exceptions. 
 * Right to opt-out of the sale of Personal Information:  We do not sell your
   information.  However, certain laws afford you the right to opt out of the
   sale of your Personal Information.
 * Right to equal service for exercising your privacy rights:  Unless permitted
   by applicable law, we will not discriminate against you when you exercise
   your privacy rights under the California Consumer Privacy Act or other
   applicable law, including by: denying you goods or services; charging you
   different prices or rates for goods or services, including through the use of
   discounts or other benefits or by imposing penalties; providing you with a
   different level of quality of good or services; or suggesting that you will
   receive a different price or rate for goods or services or a different level
   of quality of goods or services.

To exercise your rights, please use the contact information listed in the
“Contact” section below. 

Candidates may access, review, correct or update their Personal Information in
accordance with our Candidate Privacy Information Statement available at
www.entegee.com/candidate-privacy-information-statement.


VERIFYING YOUR IDENTITY

To exercise the rights described above, it may be necessary for us to verify
your identity or authority to make the request and confirm the Personal
Information relates to you. To exercise your rights, we will collect your name,
e-mail and/or telephone to verify your identity. Upon receiving your request, we
may also contact you via e-mail and/or other secured communication channel to
verify your identity by asking you additional security questions in order to
match your identity with the data we maintain about you.

For residents of California only, you, or a person registered with the
California Secretary of State that you authorize to act on your behalf, may make
a verifiable consumer request related to your Personal Information.  Your
authorized representative may be required to submit a declaration or affidavit
demonstrating that they have the authority to act on your behalf.

Once we have verified your identity, we will disclose the specific pieces of
Personal Information we collected about you, by mail or electronically, at your
option, in a readily usable format that allows you to transmit the information
from one entity to another entity without hindrance.

Please note that if we cannot verify your identity, we are not obligated to
provide you or your authorized representative information regarding your
Personal Information.

To submit a request or for more information on how to submit a request, please
contact us using the information listed in the “Contact” section below. Making a
verifiable consumer request does not require you to create an account with us.

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SHINE THE LIGHT

California’s “Shine the Light” law (Civil Code Code § 1798.83) permits users of
our Website that are California residents to request certain information
regarding our disclosure of Personal Information to third parties for their
direct marketing purposes. To make such a request, please contact us using the
information listed in the “Contact” section below.

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CHILDREN’S PRIVACY

Our Website is designed and intended for adults. By accessing and/or using our
Website, you represent that you are a legal adult.  If you are not a legal
adult, you must have your parent or legal guardian access and use the Website
for you. If you want to purchase any goods or services that may be offered on
our Website, such purchase(s) must be made by your parent or legal guardian on
your behalf.

Our Website is not intended for, and we do not knowingly collect information
from or otherwise market our website or other materials to children under
thirteen (13) years of age. If you are a parent or guardian of a child under the
age of thirteen (13) and believe that he or she has disclosed Personal
Information to us, please contact us using the information listed in the
“Contact” section below. You may review and request the deletion of your child’s
Personal Information or prohibit the further use of such information.

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CHANGES TO THIS GENERAL PRIVACY POLICY

The terms of this General Privacy Policy may change from time to time. We shall
publish any material changes to this General Privacy Policy through appropriate
notices either on this Website or contacting you using other communication
channels. The date this General Privacy Policy was last revised is identified at
the top of the page in the “Last Updated” legend.

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CONTACT

If you have any questions, comments and/or requests regarding this General
Privacy Policy or to exercise your rights with respect to your Personal
Information (as applicable), please contact us by email at  privacy@entegee.com,
by telephone at 800.793.7657 option 6, or by visiting our privacy rights request
webform at https://adeccogroup.force.com/privacy/s/bu=Entegee.

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CONTACT US

 * info@entegee.com


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