- 2. When we say ‘we’, ‘us’ or ‘Talent Strategy Group’ it’s because that’s who we are and we own and run the Sites for talentstrategygroup.com and optm360.com.
- When we say ‘Qualtrics’ it is referencing the technology platform on which all OPTM360 surveys are developed and maintained. Only clients who purchase OPTM360 surveys and request those services will have data on the Qualtrics platform. Data on the qualtrics.com Site is managed separately from data collected on the Sites for talentstrategygroup.com and optm360.com.
THE TYPE OF PERSONAL INFORMATION WE COLLECT
- 4. We collect certain personal information about visitors and users of our Sites.
- 5. The most common types of information we collect include things like: user-names, member names, email addresses, demographic data requested by the client (i.e. title, department, region, IP addresses, payment information such as payment agent details, transactional details, and web analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).
- FOR THE OPTM360 Qualtircs.com Site: OPTM360 clients will serve as the Data Collector and will be responsible for specifying details related to the scope of development and users information entered on the OPTM360 survey platform. As Data Collector, clients may specify what data to collect, from whom and where, for what purpose, and for how long. The client is solely responsible for such and The Talent Strategy Group will follow the client’s instructions.
HOW WE COLLECT PERSONAL INFORMATION
- 6. We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or through other people when you use services associated with the Sites.
- 7. We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback or send us a communication.
- FOR THE OPTM360 Qualtircs.com Site: OPTM360 data is collected through direct upload by the client, their participants, or by The Talent Strategy Group acting on behalf of the client. Feedback data is also collected from raters. After May 25, 2018 consent will be required of all OPTM360 participants before submitting feedback.
HOW WE USE PERSONAL INFORMATION
- 8. We will use your personal information:
- a. To fulfil a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Sites, like where you purchase a service.
- b. Where you give us consent:
- i. providing you with marketing information about products and services which we feel may interest you; and
- c. For purposes which are required by law.
FOR THE OPTM360 Qualtircs.com Site: Personal data is required for survey functionality to identify individuals and their relation to one another. The nature of 360 feedback requires identification of individuals by name, email and relationship to track responses and report accordingly. Personal data related to cookies and IPs enables save and return features. OPTM360 data is collected through direct upload by the client, their participants, or by The Talent Strategy Group acting on behalf of the client. Feedback data is also collected from raters. After May 25, 2018 consent will be required of all OPTM360 participants before submitting feedback.
WHEN WE DISCLOSE YOUR PERSONAL INFORMATION
- 9. We will disclose personal information to the following recipients:
- a. companies that are in the Talent Strategy Group
- b. authors of any items or services made available to you, so they can facilitate support and license validation, who maybe located in any of the countries our products are available in;
- c. subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers; technical and customer support services; recruitment agencies; marketing and analytics; security and fraud prevention services; subscription management services; payment processing services; identification verification services.
- d. For purposes which are required by law.
FOR THE OPTM360 Qualtircs.com Site: Personal data is not disclosed outside of the request of the user or to the client responsible for user data. Feedback responses from individual raters will be aggregated and not attributed to individual users.
HOW WE KEEP YOUR PERSONAL INFORMATION SECURE
We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.
FOR THE OPTM360 Qualtircs.com Site: The Talent Strategy Group serves the role of Data Processor within that arrangement, sub-contracting processing of data for Qualtrics for the purpose of maintaining the highest standards and security in the industry. Qualtrics is GDPR compliant as a Data Processor and we (and Qualtrics) will only manage data per the client’s instruction. Qualtrics is in the final stages of becoming ISO 27001 certified and FedRAMP authorized - the “gold standard” of security certification. Additionally, a Privacy Impact Assessment was performed by Qualtrics and evaluated by a third party assessor to affirm that all data is secure. The Talent Strategy Group will provide clients with a security white paper to attest to this.
HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION
- 10. You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact us and we will be happy to assist you.
- FOR THE OPTM360 Qualtircs.com Site: Data on the Qualtrics.com Site may be managed through the client’s Brand Administrator, or by contacting [email protected]
MARKETING CHOICES REGARDING YOUR PERSONAL INFORMATION
- 11. Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
- FOR THE OPTM360 Qualtircs.com Site: Data on the Qualtrics.com Site is never used for marketing purposes and is strictly limited to the sole purpose of process 360 Feedback analysis.
- 12. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.
COOKIES AND WEB ANALYTICS
- 13. When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
- a. your IP address or proxy server IP address’;
- b. the domain name you requested;
- c. the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
- d. the date and time of your visit to the website;
- e. the length of your session;
- f. the pages which you have accessed;
- g. the number of times you access our site within any month;
- h. the file URL you look at and information relating to it;
- i. the website which referred you to our Sites; and
- j. the operating system which your computer uses.
In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Please note that the functionality of our website may be limited if cookies are not accepted.
TOOLS AND MISCELLANEOUS
Our website uses Google Maps (AP’I) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Maps is a web service for displaying interactive (country) maps in order to display geographical information visually. Using this service will show you our location and will make it easier for you to find us.
GOOGLE WEB FONTS
This site uses web fonts provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") to uniformly display fonts. When you call up a page, your browser loads the required web fonts into its browser cache to display texts and fonts correctly.
To do this, the browser you are using must have a connection to Google's servers. In this way, Google will be informed that our website has been accessed via your IP address. Google Web Fonts are used for the purpose of a uniform and attractive presentation of our online offers and its use is in our legitimate interest within the meaning of Art. 6 (1) point of GDPR. If your browser does not support web fonts, a default font is used by your computer.
Google LLC, based in the USA, is certified for the US-European data protection agreement "Privacy Shield", which guarantees compliance with the data protection level applicable in the EU.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
- FOR THE OPTM360 Qualtircs.com Site: Data on the Qualtrics.com Site will be retained with the same requirements as specified by The Talent Strategy Group policy above, however may be deleted at any time at the request of the client.
WHEN WE NEED TO UPDATE THIS POLICY
- 15. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
- 16. When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
HOW YOU CAN CONTACT US
- 17. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us at [email protected], [email protected]
IF YOU’RE A USER OR VISITOR IN THE EUROPEAN ECONOMIC AREA THESE RIGHTS ALSO APPLY TO YOU:
- 18. For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION
- 19. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
- 20. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
- 21. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- 22. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.