1. Introduction

Welcome to the Suretalent website or mobile application (“Site”). Suretalent LLC (“Suretalent”, “we”, “us”, and/or “our”) operates this Site, and its mobile application, to provide our users (“you” and “your”) with information about Suretalent and its platform.

Suretalent is used by professional freelancers (“Freelancers”) who wish to offer their development, engineering and other services (“Services”) and clients who need the Services (“Clients”). Freelancers that have passed our screening process and are admitted to our network of professional Freelancers (“Network”) are referred to as “Talent”. For purposes of this policy the term “Freelancers” is broader in scope and includes both Talent and Freelancers who are not Talent. The Personal Data we receive from Freelancers and Clients and how we handle it differs, so we explain our data practices for Freelancers and Clients in two distinct sections below. Navigate to the section that applies to you: Freelancers; Clients.

2. Scope

This Privacy Policy sets out how Suretalent collects, retains, and uses information, including personal data (“Personal Data”) about Freelancers, Clients, and other Site visitors and individuals, which include our vendors, partners, blog readers, and job applicants. The Privacy Policy also applies to users of Suretalent software offerings such as our image sharing and editing tool Collabshot, affiliated sites, and data that Suretalent collects in-person, for instance, at business conferences and trade shows.

3. Freelancers

3.1. Information We Collect

A. Information That You Provide To Us

When you apply as a Freelancer on the Site, you are asking to be admitted to our Network. In order to admit you to the Network and match your qualifications with our Client’s needs, we need to perform a screening process, which evaluates your language skills, personality, domain-specific knowledge, competence and professionalism. We may also need to screen potential Freelancers for specific technical skills, as required by our Clients. In this context, you will be asked to provide information about yourself, which includes:

• your name
• contact information
• address
• location
• work experience
• education
• photo
• social network information
• family information
• billing information
• identification

Our provider of background check services may collect additional data about you (including information about criminal convictions or offenses) if and when we undertake vetting/background checks. If applicable to you, your consent to the collection of such additional data will be solicited at such time, pursuant to applicable laws.

When you participate in the community of Suretalent’s experts on our Site or mobile application, we will collect the information that you elect to share in that context. We will use certain of your Personal Data to enable you to create a profile to be displayed within the Services; this profile is searchable and may be viewed by Clients seeking Freelancers. Our mobile application is also accessible by members of our Talent network. The mobile application may collect location information in an effort to tailor the user experience.

Once you are admitted to the Network and you are matched with a Client, we will receive from our Clients information regarding the performance of your services to that Client, as necessary for maintaining standards of integrity and excellence in our Network.

In addition, Suretalent may record video and/or phone calls for quality assurance and training purposes.

B. Information Obtained From Third Parties

We collect information about you that we receive from our affiliates, such as TopTracker LLC, in relation to the TopTracker application which helps you keep track of how you spend your time. Please refer to the TopTracker privacy policy for information regarding the scope of collected data. The disclosures and practices made in this Privacy Policy equally apply to such data that we receive from TopTracker.

C. Automatically Collected Data

When you interact with Suretalent through the Site or services, we automatically collect certain information. Please read the “Site Visitors” section below for more information.

3.2. How We Use the Information

A. To Provide The Service And Respond To Requests

Suretalent uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we will use the Personal Data in connection with the reason for which it was provided.

In particular, we use data that you provide to us (described above) in order to process your request to become a Freelancer and administer our contract with you once you become a member of the Network. For individuals in the EU, our use of Personal Data that you provide to us is necessary in order to implement your request to become a Freelancer prior to entering into a contract with us and, once you are admitted to our Network, to perform our contract with you.

B. As Necessary For Certain Legitimate Interests

We use your Personal Data for the legitimate interests described below:

• To send administrative information to you, for example, information regarding the Site and changes to our terms, conditions, and policies.
• To conduct analytics on how the Site and our Service are being used by you for our internal purposes, namely for providing, maintaining, benchmarking and improving our offerings, and identifying usage trends.
• We use data relating to your use of and interaction with the Site and the Services, including use of product features by you and information that we obtain through cookies and other technologies, to better understand your needs and interests in order to personalize your experience with our Services.
• To market our services and showcase Freelancers (in particular, we can feature certain profiles of Freelancers to drive traffic from potential Clients).
• To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks.
• To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
• If you ask us to delete your data and we are required to fulfill your request, we may keep basic data to identify you and prevent further unwanted processing.

For individuals in the EU, please see the “EU Individuals” section below for information on our legitimate interests and your rights.

4. Clients

4.1. Information We Collect

A. Information that you provide to us

We collect Personal Data from our prospective Clients when we receive a request for hiring our Freelancers. This includes names and contact information of prospective Client’s representatives, and any information relating to the Client’s needs. We also collect Personal Data that is entered on our Site or sent to us electronically, for example when you complete a web form to give Personal Data to us directly (such as on our “Contact Us” page), when you voluntarily provide such information such as when you register for access to the platform (for example, your name and mailing address), contact us with inquiries or respond to one of our surveys. Wherever Suretalent collects Personal Data we make an effort to provide a link to this Privacy Policy.

In addition, Suretalent may record video and/or phone calls for quality assurance and training purposes.

B. Information Obtained From Third Parties

We may supplement the information that we collected from you (such as your email address) with additional information about you and your company obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information).

C. Automatically Collected Data

When you interact with Suretalent through the Site or services, we automatically collect certain information. Please read the “Site Visitors” section below for more information.

4.2. How We Use the Information

A. To Provide The Services And Respond To Requests

Suretalent uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such Services, maintain your account, contact you regarding your use of the Services and/or the Site or to notify you of important changes to the Services and/or the Site, and to monitor your use of such services. For individuals in the EU, such use is necessary to respond to or implement your request and for the performance of the contract between you and us.

B. For Marketing Purposes

We may use your contact details to tell you about services we believe will be of interest to you, upcoming events or other promotions. If we do so, each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. Note, however, that as a user of our services you cannot opt out of some administrative communications that are reasonably necessary to the services, such as billing or service notifications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Where required by applicable law (for example, if you are an individual in the EU), we will only send you marketing information by email if you consent to us doing so at the time you provide us with your Personal Data. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.

C. As Necessary For Certain Legitimate Interests

We use your Personal Data for the legitimate interests described below:

• To send administrative information to you, for example, information regarding the Site and changes to our terms, conditions, and policies.
• To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
• To conduct analytics on how the Site and our Service are being used by you for our internal purposes (namely for providing, maintaining, benchmarking and improving our offerings, identifying usage trends and determining the effectiveness of our promotional campaigns) and to inform our marketing strategy and personalize our communications with you (including providing information on our features and other marketing and service-related announcements relevant to the content and features you engage with).
• To supplement the information that we collected from you with information obtained from third parties (described above) in order to update, expand and analyze our records, identify new Clients, and provide products and services that may be of interest to you.
• To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks.
• To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
• If you ask us to delete your data and we are required to fulfil your request, we may keep basic data to identify you and prevent further unwanted processing.

For individuals in the EU, please see the “EU Individuals” section below for information on our legitimate interests and your rights.

If Suretalent intends to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected and pursuant to the applicable law.

5. Job Applicants

5.1. Information We Collect

A. Application and assessment process

When you apply for employment through our Site, our provider of recruiting services will collect the Personal Data that you provide in your resume and cover letter. It is for you to decide what you include in these documents. However, the kinds of information you may wish to include are: your name, contact details, employment history and education.

If you are invited to undertake further assessments (such as an interview) in connection with your application and you participate in such assessments, we will collect further Personal Data that you provide to us as part of that process. The kinds of information you may disclose include information about your qualifications and information about your employment experience.

If you do not provide us with certain information when requested, it may impact our ability to assess your suitability for a role with us or we may not be able to make you an offer of employment.

Throughout the recruitment process, we may create Personal Data in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. We may also record interviews with you for quality assurance and training purposes.

We have a legitimate interest in facilitating the interview process and communicating offers of employment to you, making informed recruitment decisions and selecting suitable candidates for roles with us, and improving our recruiting and hiring processes. Your Personal Data may be shared with third party providers for the recruitment and interview process.We’ve partnered with third party providers who may obtain access to your Personal Data. Examples of these providers include interview scheduling and recruitment software.

We will retain your contact details and resume to inform you of current and future career opportunities (unless you tell us that you do not want us to keep your details for that purpose) pursuant to our legitimate interest in doing so.

B. If your application is successful

If your application is successful we will collect further Personal Data about you in connection with conducting reference and background checks where required or permitted by applicable local law (including if applicable to you special categories of Personal Data, and your consent to the collection of such additional data will be solicited at such time, pursuant to applicable laws). We will also collect copies of relevant identification documents from you (such as your passport or driving license, proof of address, a copy of your work permit (where applicable), a photograph and a copy of your signature). We use this information to comply with immigration requirements and to verify your identity for our own internal security purposes. We have a legitimate interest in collecting and using this data to comply with our legal obligations and for the performance of your employment contract with us.

If you are hired, your Personal Data will be used as part of your employee record under our employee privacy policies.

Please see the “EU Individuals” section below for information on your rights in relation to the Personal Data we hold about you.

C. Automatically Collected Data

When you interact with Suretalent through our Site in relation to your application, we automatically collect certain information. Please read the “Site Visitors” section below for more information.

6. Site Visitors

When you interact with Suretalent through the Site or the Services (whether as a Freelancer, as a Client, a job applicant, a blog reader, software end user, external domain visitor, or other visitor to our Site), we and our service providers acting on our behalf will automatically collect information about you through cookies (small text files placed on your device) and other technologies. These cookies may be used to show you ads about our company and services. Although these cookies do not disclose your identity, you may opt out of these cookies at any time. Please see our Cookie Policy to learn more about how we use cookies and other technologies.

As a visitor to our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

Where the information that we collect automatically on our Site is Personal Data, our legal basis for the use of this information is that it is necessary for the purposes of our legitimate interests in maintaining the safe operation of our Site as well as in learning how Site visitors interact with our Site to improve your use of it. By continuing to use our site, you are allowing us to share your IP address with third party providers for the purposes of fraud prevention and security. If you wish to opt out, please message [email protected].

6.1 External Domain Visitors

Suretalent owns, leases, or operates several sites and services in which this section applies, but their domains are external to Suretalent.com.

7. External Domain Visitors

7.1 Staffing.com

Visitors to Staffing.com may opt to provide their name and email. We will use this data to respond to any requests you forward to us or to transmit the requested content to you, such as the staffing.com newsletter, or to share information and materials regarding Suretalent products and services. This information is collected on a consent basis and is not required to access the site.

Staffing.com operates as an extension of Suretalent. The data collected as part of the Staffing.com operations are in the same system, and connected to, Suretalent operating data. We may directly access, or cross reference, the data for purposes including Analytics, Client Experience, Lead Conversion, Marketing, and Technical Support and Operations.

7.2 Affiliated Sites

Visitors to domains owned and managed by TalentSites, LLC may opt to provide their name, e-mail, and phone number. We will use this data to respond to any requests you forward to us. This information is collected on a consent basis and is not required to access the site. Domains owned and managed by TalentSites, LLC are affiliated with Suretalent. The data collected as part of the TalentSites, LLC operations are in the same system, and can be connected to Suretalent operating data. We may directly access, or cross reference, the data for purposes including analytics, lead conversion, and marketing.

8. Software end users

When you use Suretalent software Collabshot, we will collect account level data (your name, email and password) for access, storage of historical data, and operation of software. If you create an account by using credentials from a third party service or sign-in services such as your Google account, these services will authenticate your identity and provide you with the option to share certain Personal Data, such as name and email address(es), with us. Use of account level data is necessary to perform a contract with us in relation to your use of the software, and it is in our legitimate interest to respond to your requests and ensure we provide our services in the best way that we can.

When you use the software, we may collect usage statistics for analytics and to support and troubleshoot the software to give you a better user experience. We have a legitimate interest in conducting usage statistics to ensure our software is working as intended and to make improvements to our services. We use service providers to assist in authentication of users and cloud hosting the storage and retrieval of screenshots.

Suretalent’s software has online components and cookies are required for full functionality. For more information on Collabshot’s cookie usage please see the section on Site Visitors. TopTracker is part of Suretalent’s main domain and information on the cookies set when you use TopTracker can be found on Suretalent’s Cookie Policy.

9. Events

We may collect Personal Data from you when you attend one of our events, for instance at business conferences and trade shows. The data we collect includes information that you voluntarily give to us, such as your business card or contact details. We will use this information to develop a business relationship and in a manner consistent with the purpose for which you gave the information.

Where required by applicable law (for example, if you are an individual in the EU), we will ask your consent before or when sending you marketing information by email. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.

10. Our Disclosure of Your Personal Data and Other Information

Suretalent is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties, as set forth below:

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Agents, Consultants and Other Service Providers

Suretalent, like many businesses, sometimes hires other companies to perform certain business-related functions. These parties include website analytics companies, providers of digital advertising services, our hosting and cloud computing service providers, providers of CRM, marketing and sales software solutions, providers of billing and processing payments functions, providers of background check services, fraud detection and prevention software, and interview and recruitment providers. By joining our network When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Pursuant to our instructions, these parties may access, process or store Personal Data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Legal Requirements

Suretalent may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Suretalent, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.