Last Update: April 2023
We may collect, process, and store your personal data in the United States and other countries where our servers (or the servers of our service providers) reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where we operate and where our service providers operate.
You have the right at any time to withdraw your consent to our collection and processing of your information or to the transfer of your personal data to the United States and other countries. You may withdraw your consent by emailing us at email@example.com.
Information Collection and Use
We collect several different types of information for various purposes, including to provide and improve our Service to you, as described more fully below.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personal Data may include, but is not limited to:
- Identifiers and contact information, such as first and last name, physical address, email address, telephone number, unique personal identifiers, online identifiers, IP address, or other similar identifiers
- Demographic information, such as gender and date of birth
- Professional or employment related information, such as company name or current or past job history
- Usage Data such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data
- Inferences drawn from other personal information, such as personal preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)
We obtain the categories of Personal Data listed above from the following categories of sources: directly from you as described herein, indirectly from your activity on the Service, and from third-parties that interact with us in connection with our Service.
Use and Disclosure of Personal Data
We collect the following subcategories of personal information:
We collect such personal information for the following purposes:
Consistent with and in addition to the information set forth in the “Types of Data Collected” section above:
First and last name, physical address, telephone number, email address.
Performing services or providing products to you, providing customer services, verifying user information, facilitating access to services or products.
Communicating with you when you have requested support, information, services, etc.
To send promotional communications about us, to the extent permitted by applicable law.
Internet or other electronic network activity information
Consistent with and in addition to the “Passive Information Collection and Use” section below:
IP addresses, log files, login information, and cookies and device information (e.g., online activity such as date and time of accessing our websites, website addresses accessed, the length of website visit).
Analytical purposes, including, without limitation, to help us improve your access to the Service (for example, by remembering your contact and other information when you access or use the Service), to identify repeat visitors to the Service, to track how you access and use the Service, to learn when and how users visit the Service, to learn how popular Service pages are and aren’t, to learn which search terms are used to find the Service, to learn which websites direct you to the Service, to help display certain information on the Service, and to improve your enjoyment of the Service.
To administer the Service and its servers, to generate statistical information, to monitor and analyze Service traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve the Service.
Physical address; work / business address, state, region.
To communicate with you and send you information about our products or services, or to respond to your request for information or products and services.
To send you promotional communications about us and our products or services, to the extent permitted by law.
Professional or employment-related information
Business contact information, including, but not limited to, job title, place of employment, business phone number, business address.
Performing the services or providing products, including, without limitation, providing customer services, verifying user information, facilitating access to the Service.
Communicating with users who have requested support, information, or services.
To send you promotional communications about us and our products and services, to the extent permitted by law.
In addition to and consistent with the purposes identified above (and as expanded on in the above table), TalentLaunch uses your Personal Data for various purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues
- Identifiers: including but not limited to name, telephone number, address, age, email address, or date of birth;
- Commercial Information: including but not limited to financial account information, payment card information, your employer, and your billing information;
- Internet or other electronic network activity information: including but not limited to computer and connection information, IP address, and cookies and other tracking technologies described further above; and
- Inferences: drawn from the above categories of personal information.
We may also disclose Personal Data for business purposes to the following categories of third parties:
- To contractors, service providers, and other third parties we use to support our business
- To third parties to market their products of services to you if you have consented to these disclosures
- To our affiliates for related business purposes
In addition, we use and disclose Personal Data collected through the Services as we believe to be necessary to appropriate:
- As permitted by applicable law
- To comply with a legal obligation
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
We may also use and disclose Personal Data collected through this Service in other ways, with your consent.
We also use and disclose Personal Information we collect passively as described below, under “Passive Information Collection and Use.” In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked, or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as Personal Data as long as it is combined.
Passive Information Collection and Use
As you navigate the Service, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:
THROUGH YOUR BROWSER AND DEVICE
Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We collect Device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
The Service may use both cookies that we implement, and cookies implemented by our suppliers and other third parties. “First-party” cookies allow your browser to talk to the actual website that you are visiting, whereas “third-party” cookies allow your browser to talk to third-party websites, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.
The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. By way of illustration, the types of cookies used, the types of information collected by those cookies, and the purposes for which that information are used are described below. We may combine information collected by cookies with other Collected Information.
- Operationally necessary cookies (also called essential cookies). These are cookies that are required for the operation of the Service. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of the Service to make use of its functions. Without these cookies, features and services you have requested will not be able to be provided.
- Functional cookies. These cookies allow us to offer you enhanced functionality when accessing or using the Service. This may include to remembering choices you make, for example, remembering your preferences or settings, remembering if you reacted to something on or through the Service so that you are not asked to react to it again, remembering if you have used any feature of the Service before, remembering your username or preferences, remembering if you have used any feature of the Service before, restricting the number of times you are shown a particular advertisement, and enabling social media components. If functional cookies are disabled, various functions of the Service may be unavailable to you or may not work the way you want them to.
- Performance cookies (also called analytical cookies). These cookies assess the performance of the Service, including as part of our analytic practices to help us understand how visitors use and interact with the Service, for example, which pages on our websites users visit most often. These cookies also enable us to personalize content and remember your preferences. These cookies help us improve the way our websites work and provide a better, personalized user experience.
- Advertising or targeted cookies. These cookies record your visits to the Service, the pages you visit on our websites, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. Talent Launch and its third-party advertising platforms or networks may use this information to make the Service and its content more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed above). These cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.
A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the applicable website. Session cookies are typically deleted or removed when you exit or quit your browser application. Persistent cookies exist for a set period of time, for example, six months or one year. Each time you visit a website that has implemented a persistent cookie, that cookie will remain active until its predetermined expiration date. You can also manually delete persistent cookies as discussed above.
Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technologies is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.
Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Service, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating usage levels of the Service, helping diagnose server problems, and administering this Service.
Advertising, Remarketing, & Retargeting
From time to time the Services may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including, without limitation, Google Ads and advertising services provided by LinkedIn. These services collect information about your visits to and interactions with the Services and other websites and will use that information to target advertisements for goods and services and to display those advertisements on other websites. The information collected may be associated with your personal information.
Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether you visit specific pages of the Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.
Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Services and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet.
We may also enable and implement the following Google Analytics Advertising Features on the Services: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video 360 integration, Google Display Network (“GDN”) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Services. Demographics and Interest reporting uses a third-party cookie to collect information about our Services traffic by tracking users across websites and across time, which generates a report for us to better understand users of the Services. Campaign Manager integration allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. GDN Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of users of the Services by sorting our Google Analytics data.
To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
We may use third-party service providers to monitor and analyze the use of our Service. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Use of Information for Marketing Purposes
We may send you regular promotional communications about our services. Such promotional materials may use the “TalentLaunch” brand and may be sent to you via different channels, such as: email, phone, SMS text messages, postal mailings, and third party social networks.
In order to provide you with the best personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Service visits, or based on the links you click in our emails). When required by applicable law, we will obtain your consent before starting these activities. In addition, you may withdraw your consent (opt-out) at any time.
In particular, you can opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. If you can sign-in to your account, you may be able to change your communication preferences under the relevant section of the Service. You can also contact us using the contact details provided below to opt-out from receiving marketing-related communications.
Please note that even if you opt-out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our products, order confirmations, notifications about your account activities, and other important notices.
Links To Other Sites
General Principles for the Processing of Personal Data
Personal Data will be collected, stored, processed and transmitted in accordance with our established policies and applicable federal, state, local and foreign laws, rules and regulations.
Our with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information we collect will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information we collect will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information we collect will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal information will be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
If we engage in the processing of personal information for purposes other than those specified in this Policy, we will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
Choices and Access
If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Service, please contact us. We will try to comply with your request as soon as reasonably practicable.
Collection and Use of Sensitive Categories of Personal Information
Certain jurisdictions provide sensitive categories of personal information that are considered sensitive under applicable law. We collect and use the following sensitive categories of personal information:
- Race or ethnicity;’
- Social Security Number;
- Financial or banking information;
- Citizenship or immigration status; and
- Health or disability status.
We collect and use the foregoing sensitive categories of personal data for the following legitimate business purposes:
- To carry out our obligations under applicable law;
- For the performance of our contract or agreement with you, to provide services requested by you, and to provide services reasonably expected based on our relationship with you;
- To protect our legal interests and to ensure the physical safety of Talent Launch and other individuals; and
- As otherwise required by law.
Where we have a legitimate need to process sensitive personal information for purposes not identified above or where required by applicable law, we will only do so after providing you with notice and, if required by applicable law, obtaining your prior consent.
It is your responsibility to provide us with accurate personal information. Except as otherwise set forth in this Policy, we will only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and relevant to our intended use.
Privacy Rights for California, Colorado, Connecticut, Utah, and Virginia Residents
Certain laws in California, Colorado, Connecticut, Utah, and Virginia (as each may be amended from time to time) may grant users of our Service that are California, Colorado, Connecticut, Utah, and Virginia residents certain rights—subject to all applicable limitations, exemptions, or exceptions—in regards to our collection of personal information. These rights include, to the extent applicable and to the extent granted under applicable law:
- The right to confirm whether personal information about you is processed and to access such personal information;
- The right to request the disclosures of (1) what personal information has been collected; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collection or selling personal information; (4) the categories of third parties with whom the business shares personal information; and (5) the specific pieces of personal information we have collected (e.g., the right to data portability);
- The right to request the deletion of their personal information that has been collected;
- The right to request the correction of your personal information that we collected;
- The right to opt-out of targeted advertising and the sharing of personal information that is shared for cross-contextual behavioral advertising purposes;
- The right to opt-out of the automated profiling of your personal information in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to opt-out of the sale of their personal information;
- The right to withdraw consent of our processing of your personal information where consent was required by law prior to the initial collection and processing of your personal information;
- The right to limit or opt-out of (or opt-in to) our processing of sensitive personal information to what is necessary; and
- The right to not be discriminated against due to your exercise of your rights under applicable law. We do not discriminate against users for exercising the rights granted to them under applicable law.
The above rights are only exercisable by you where the applicable law grants you the right being exerted and where no exception or exemption under applicable law applies. You may also have a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act.
We do not use your personal information to profile you in furtherance of decisions that produce legal or significantly similar effects (as may be defined under applicable law).
If applicable law grants you certain rights over our collection and use of your personal information as discussed above and as it relates to the Services, you may make such a request by calling 216-654-0066 or click here to fill out a request form.
To exercise your rights as described herein, you may submit a verifiable consumer request to us (as described above) or by contacting us via the contact methods provided in the CONTACT US section below. We will not discriminate in any way against any users of the Site that exercise their rights provided by law.
Only you or a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. Without limiting the foregoing, the verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will respond to your request within the applicable timeframe required under applicable law. If we deny your request, you can appeal such denial by emailing Legal@mytalentlaunch.com.
We have implemented security measures designed to protect personal information provided by you against unauthorized access and use. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACT US section below.
Our Service does not address anyone under the age of 18 (“Child(ren)”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.