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Submitted URL: http://links.andersonfrank.com/ls/click?upn=u001.4uohFat5ur5WmQgdeAw2cFZAw-2B9foS-2BU9qLnm6XWflCBb1bG0T6J4guZPb5yX6tWr3QO5fuFpK...
Effective URL: https://www.tenthrevolution.com/privacy-notice/
Submission: On August 29 via manual from US — Scanned from US
Effective URL: https://www.tenthrevolution.com/privacy-notice/
Submission: On August 29 via manual from US — Scanned from US
Form analysis 1 forms found in the DOM
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<legend style="width:unset;">Privacy Request Manager</legend>
<input type="hidden" id="ccpa_product_code" value="717">
<h4>Option 1: Submit a Web Form Request</h4>
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<td><label for="ccpa_first">First Name:</label></td>
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<option value="MO">Missouri</option>
<option value="MT">Montana</option>
<option value="NE">Nebraska</option>
<option value="NV">Nevada</option>
<option value="NH">New Hampshire</option>
<option value="NJ">New Jersey</option>
<option value="NM">New Mexico</option>
<option value="NY">New York</option>
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<option value="ND">North Dakota</option>
<option value="OH">Ohio</option>
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<option value="WA">Washington</option>
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<option value="WI">Wisconsin</option>
<option value="WY">Wyoming</option>
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<option value="Customer">Customer</option>
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<option value="Job Applicant">Job Applicant</option>
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<option value="Ad/Email Recipient">Ad/Email Recipient</option>
<option value="Other">Other</option>
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<td align="left" colspan="2"><input type="checkbox" id="ccpa_request_type1" value="tell_me"><label for="ccpa_request_type1"> Tell me more about the data you collect, share and/or sell</label></td>
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<tr>
<td align="left" colspan="2"><input type="checkbox" id="ccpa_request_type2" value="do_not_sell"><label for="ccpa_request_type2"> Do not sell or share my personal information (if applicable)</label></td>
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<tr>
<td align="left" colspan="2"><input type="checkbox" id="ccpa_request_type3" value="delete"><label for="ccpa_request_type3"> Delete my personal information</label></td>
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<tr>
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</tr>
<tr>
<td align="left" colspan="2"><input type="checkbox" id="ccpa_request_type6" value="opt_me_out_of_automated_decisions"><label for="ccpa_request_type6"> Opt me out of automated decision making (if applicable)</label></td>
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<tr>
<td align="left" colspan="2"><input type="checkbox" id="ccpa_request_type7" value="limit_use_of_my_information"><label for="ccpa_request_type7"> Limit the use of my sensitive personal information (if applicable)</label></td>
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<tr>
<td align="left"><input type="checkbox" id="ccpa_other_checkbox"><label for="ccpa_other"> Other:</label></td>
<td align="left"><input id="ccpa_other" size="35"></td>
</tr>
<tr>
<td colspan="2">
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</td>
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<tr>
<td colspan="2" class="affirm-and-submit"> By clicking "Affirm & Submit" you affirm the information above is accurate and acknowledge that we may need to verify your identity and your state of residence to determine if we can fulfill
your request. </td>
</tr>
<tr>
<td colspan="2">
<b><span id="ccpa_error" style="display: none">Error:
Please complete all form fields, check at least one request box and solve the Captcha to submit.</span></b>
</td>
</tr>
<tr>
<td colspan="2">
<b><span id="ccpa_success" style="display: none; background-color:#9df2a8; font-style:italic;color:black;">You
have successfully submitted your request.</span></b>
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<td colspan="2">
<input type="submit" id="ccpa_submit" value="Affirm & Submit">
</td>
</tr>
<tr>
<td colspan="2">
<br>
<h4>Option 2: Call Toll Free</h4> Or call us toll free at <a href="tel:18664678688" role="link">1-866-I-OPT-OUT</a> (1-866-467-8688) and enter Service Code 717#. <br>
</td>
</tr>
<tr style="padding: 0; margin: 0">
<td style="padding: 0; margin: 0" colspan="2" height="4" align="right">
<h6 style="padding: 15px 0 0; margin: 0; text-align:
left; font-style: italic; font-weight: 400;">Privacy request management by <a href="https://www.ccpatollfree.com" role="link">CCPAtollfree.com</a></h6>
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* Wellbeing Matters
* Sustainability Matters
* TRG Cares
* Our awards
* Digital Revolution Awards
* Services
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* Contract
* Train talent
* Deploy talent
* Other services
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* Mentor Me
* Salary benchmarking
* Careers
* The TRG experience
* Success stories
* Join TRG
* Insights
* News and media
* Blog
* Tech’s Leading Women
* Contact
Menu
* Culture
* Our story
* Our brands
* Our values
* Our team
* People & Planet
* Diversity Matters
* Wellbeing Matters
* Sustainability Matters
* TRG Cares
* Our awards
* Digital Revolution Awards
* Services
* Find talent
* Permanent
* Contract
* Train talent
* Deploy talent
* Other services
* Women in Tech
* Mentor Me
* Salary benchmarking
* Careers
* The TRG experience
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TENTH REVOLUTION GROUP PRIVACY NOTICE
EFFECTIVE DATE: 25 MARCH, 2018
LAST UPDATED: 15 JULY, 2024
TABLE OF CONTENTS
* I. Introduction
* II. Who are we?
* III. Who does this Privacy Notice protect?
* IV. What information will we collect?
* V. Why do we process your Personal Data?
* VI. Who do we send your Personal Data to?
* VII. What will TRG do if my Personal Data is breached?
* VIII. Will my Personal Data be transferred to another country?
* IX. How long will TRG store my Personal Data for?
* X. Sending TRG Personal Data over the internet
* XI. How we collect and aggregate information about visitors to our Websites
* XII. Technology and Tools
* United Kingdom Addendum
* European Economic Area & Swiss Addendum
* Singapore Addendum
* United States of America Addendum
* California Consumer Privacy Act, California Privacy Rights Act, Colorado
Privacy Act, Connecticut Act Concerning Personal Data Privacy and Online
Monitoring, Iowa Consumer Data Protection Act, Utah Consumer Privacy Act, and
the Virginia Consumer Data Protection Act Disclosures
* Australia and New Zealand Addendum
* Canada Addendum
* Japan Addendum
I. INTRODUCTION
Your privacy is important. This Privacy Notice (the “Privacy Notice”) together
with its addendums, our Terms of Use and any other documents referred to in this
Privacy Notice or the Terms of Use explains how we comply with applicable
privacy requirements and sets out minimum standards for how we deal with all
personal data that we collect from you, or that you provide to us including via
this w^debsite and any other websites using the tenthrevolution.com domain or
Tenth Revolution Group-branded applications of Frank Recruitment Group Services
Limited and its Affiliates as defined below (collectively, the “Websites”). The
Tenth Revolution Group is a trademark and brand owned by Frank Recruitment Group
Services Limited (“Tenth Revolution Group, ” “we” “us” “our” “TRG”). TRG has
many affiliates including Nigel Frank International Limited, Mason Frank
International Limited, Frank Recruitment Group UK Services Limited, Frank
Recruitment Group Services USA Ltd., Frank Recruitment Group Inc., Frank
Recruitment Group Services Inc., Frank Recruitment Group Private Limited
(Singapore), Frank Consulting Services Private Limited (Singapore), Frank
Recruitment Group Pty Limited (Australia), Frank Recruitment Group GmbH
(Germany), Frank Recruitment Group K.K. (Japan), Frank Recruitment Group Sp
Zo.o. (Poland), Frank Recruitment Group Poland Sp Zo.o. (Poland), Frank
Recruitment Group BV (Netherlands), Frank Recruitment Group S.L. (Spain), Frank
Consulting Services S.L. (Spain), Frank Recruitment Group Sarl (Switzerland),
Frank Recruitment Group Inc. /Groupe de Recrutement Frank Inc. (Canada), Frank
Consulting Services SAS (France), Frank Recruitment Group SRL (Italy), Tenth
Revolution Consulting Services SRL (Italy), and businesses operated by our group
under the brand names including Frank Recruitment Group (FRG), Nigel Frank,
Mason Frank, Nelson Frank, Jefferson Frank, Revolent, Tenth Revolution Group,
Anderson Frank, Washington Frank, TRG Technology Consulting, Digital Revolution
Awards, and Dynamic Jobs.
This Privacy Notice sets out the basis on which we collect, store, use and
disclose personal data we receive in writing, through our Websites, or through
the cloud talent solution services that we provide. It therefore applies to
personal data that you provide to TRG telephonically, electronically (including
email) and in person.
This information may be updated from time to time, and should be read in the
context of any additional specific information such as that provided in privacy
policies applicable to specific businesses or local areas as displayed on the
relevant Website or distributed to you from time to time.
This Privacy Notice also informs you how we obtain and use information gained by
us through your use of the Websites, including by using “cookies” and third
party vendors.
Please read the following carefully to understand our views and practices
regarding your personal data, how we will treat it and your rights.
This Privacy Notice applies to TRG globally. The first part of the policy is
general and applies globally. The second of the Privacy Notice is comprised of
country-specific addendums, and where applicable, TRG will handle Personal Data
relying on certain exemptions under local law. Please be sure to check the
addendums below to see if there is one that applies to your country or local
jurisdiction. In the event of a conflict between the general part of this
Privacy Notice and an addendum, the addendum prevails.
II. WHO ARE WE?
Tenth Revolution Group is the world’s leading provider of technology talent
solutions. Our mission and purpose is to solve the tech skills gap and change
people’s lives. Through our portfolio of specialist brands including Nigel Frank
International, Mason Frank International, Washington Frank, Anderson Frank,
Nelson Frank, FRG Technology Consulting, Jefferson Frank and Revolent, we find,
train, and deploy tech talent, giving businesses access to the skills they need
to digitally transform their operations and empower people to build a rewarding
career in tech. If you want to contact TRG or any of its group companies, please
click here.
You can contact TRG’s Chief Privacy Officer (“CPO”) by emailing
privacy@tenthrevolution.com or by sending written correspondences here:
Frank Recruitment Group Services Limited
The St. Nicholas Building
St. Nicholas Street
Newcastle-Upon-Tyne
Tyne & Wear U.K. NE1 1RF
Attn: Chief Privacy Officer
Your TRG Personal Data is governed by this Privacy Notice unless you interact
with us through Revolent or Digital Revolution Awards, which are governed by one
of the following individual privacy notices:
1. For Revolent’s privacy notice, click here.
2. For Digital Revolution Awards privacy notice, click here.
III. WHO DOES THIS PRIVACY NOTICE PROTECT?
This Privacy Notice protects individuals throughout the world who access our
Websites or receive recruitment services, or participate in awards competitions
from us. In addition to candidates who are looking for a new or different job or
career, this also includes individuals who are employed by an actual, former or
prospective TRG client. An TRG “client” is one of (a) a business that TRG has
contracted with to provide recruitment or is in the process of doing so, (b) a
business that TRG may solicit with the intention of providing recruitment or (c)
a business to whom TRG may provide relevant IT market information. Additionally,
TRG acts as the data controller for Personal Data (as defined below) obtained
concerning those protected under this Section III.
IV. WHAT INFORMATION WILL WE COLLECT?
Some of the data that we collect and receive from you is personal data which
means that it is information that could personally identify you (“Personal Data”
or “PII”). The Personal Data that we may collect from all users of our Websites
and users of our recruitment services may include any of the following:
• Your name;
• Your gender;
• Contact details e.g. street address, email address, cell (or mobile) or home
telephone numbers;
• Work Experience;
• Job Title;
• Professional Certifications;
• Education & Qualifications;
• Skills;
• Career History;
• Salary Range;
• Right to work status \ citizenship;
• Other information relevant to help us provide recruitment services;
• References from past employers; and
• IP address
A. For Contract Candidates Only (individuals who are employed by, consult with
and/or own an entity recruited by TRG to provide contract or temporary technical
professional services to an TRG client (or an TRG client’s client))
In addition to the Personal Data listed above, TRG may collect the following
from you:
• Tax details and proof of payment and submission;
• Commercial insurance information; and
• Bank and payment details.
While this information may relate to your company or your employer rather than
being your Personal Data, we have listed this information for transparency.
If your provision of Personal Data to TRG is necessary to enter into a contract
with your company or your employer, your failure to provide us with accurate
Personal Data may result in TRG not being able to offer or render recruitment
services to you, your company or your employer.
V. WHY DO WE PROCESS YOUR PERSONAL DATA?
Generally, we use your Personal Data for our business and activities, and in our
efforts to expand and improve our business. Examples include:
A. All users of the Websites and/or our services
• To provide our recruitment services to you, your employer or your company;
• To facilitate the recruitment process, including but not limited to:
o Qualifying and submitting candidates;
o For clients, negotiating TRG terms of business;
o Arranging interviews and obtaining feedback;
o Negotiating compensation packages; and
o Providing post placement follow up.
• Where permitted by applicable law and unless you tell us otherwise, we (or a
third party to whom we have provided your Personal Data under part VI below of
this Privacy Notice) may send you emails, SMS messages, or text messages
(standard SMS or text message rates may apply);
• To assess data about you against vacancies which we judge may be suitable for
you;
• To enable you to submit your CV/resume to TRG, apply online (including through
the Websites) for jobs or to subscribe to alerts about jobs we think may be of
interest to you;
• To enable us to develop and market other products and services and where you
have consented to being contacted for such purposes;
• To improve our customer service and to make our services more valuable to you
(including tailoring the Websites when you log on to enrich your personal online
experience);
• To send you electronically or by post surveys, reports, TRG event details,
promotions, offers, networking and client events and general information about
relevant industry sectors which we think might be of interest to you, where you
have consented to being contacted for such purposes (and we will provide you
with an opportunity to opt out);
• To identify you, and respond to and process your requests for information and
provide you with a product or service;
• To amend records to remove personal information;
• To use your information on a pseudonymized basis to monitor compliance with
our equal opportunities policy, other TRG policies and any legal or compliance
requirements;
• To use your information on a pseudonymized basis to create marketing materials
such as a salary survey; and
• To carry out our obligations arising from any contracts entered into between
you and us, and for other everyday business purposes that involve use of
Personal Data.
B. Actual or Prospective Candidates
• To help find you or your company a job;
• To contact you (permanent hire candidates), your employer or your company
(contract candidates) about jobs that TRG is filling or may fill for TRG
clients;
• To provide you or your company with information about the job market;
• To communicate with you (permanent hire candidates), your employer or your
company (contract candidates) after you or it has started a job to make sure all
is going well or to remedy, or attempt to remedy, any problems;
• To answer any questions you have about a job or the job market;
• To fulfill any aspect of your employer’s or your company’s contract with TRG
(for contract candidates only);
• To collect any money due, or allegedly due, to TRG or any TRG client (or TRG’s
client’s client);
• To obtain or inquire about any property (including computers and confidential
business information) owned, or allegedly owned, by TRG or any TRG client (or
TRG’s client’s client);
• To determine if an TRG client or other entity (or their respective affiliates)
to whom TRG presented you has (a) employed you or (b) retained you or any entity
(i) that employed you or (ii) that retained you or (iii) in which you have a
financial interest;
• To establish, exercise or defend any legal claims; and
• To assist you (permanent hire candidates), your employer or your company
(contract candidates) if you are dissatisfied or dislike the job, or any aspect
of it.
C. Individuals who work for TRG clients (i.e. a “client contact”)
• To fill an open vacancy at your company or employer;
• To contact you about candidates for jobs with whom TRG has a relationship;
• To provide you with information about the job market;
• To communicate with you after your company or employer has hired/retained an
TRG candidate to make sure all is going well and to remedy, or attempt to
remedy, any problems;
• To negotiate and fulfil any aspect of your company’s or employer’s contract
with TRG;
• To answer any questions you have about a job or a candidate or your company’s
or employer’s contract with TRG;
• To resolve any issue with the issuance, payment, collection or enforcement of
an TRG invoice;
• To collect any property owned by TRG or any TRG candidate;
• To establish, exercise or defend any legal claims.
D. Individuals who participate in awards’ competitions
a) To provide our awards’ competition services to you;
b) To facilitate the awards’ competition process, including but not limited to:
o Publishing contest rules;
o Collecting, qualifying and submitting participants, contest applications,
judges, and winners;
o Facilitating the acceptance, rejection, or delivery of contest awards;
o Providing post award follow up.
VI. WHO DO WE SEND YOUR PERSONAL DATA TO?
A. All users of the Websites and/or our services
• To third parties where we have retained them to provide services that we or
you have requested or that TRG clients have requested including references,
qualifications and background reference checking services and to verify the
details you have provided from third party sources.
• To third parties to provide data storage, CV/resume parsing, data cleansing
and marketing services to TRG where such third parties have agreed to maintain
the confidentiality of, and to protect, your Personal Data in accordance with
applicable law.
• To third parties to assist with credit control and payment management
• To third parties, regulatory or law enforcement agencies if we believe in good
faith that we are required by law to disclose it in connection with the
detection of crime, the collection of taxes or duties, in order to comply with
any applicable law or order of a court of competent jurisdiction, in connection
with legal proceedings or other similar cause or circumstance.
• To TRG affiliates, whose locations can be found at
https://www.tenthrevolution.com/contact . These entities will process your
Personal Data in accordance with this Privacy Notice.
• In the event of a sale, merger, liquidation, receivership or transfer of all
or substantially all of the assets, or a controlling interest in the equity, of
TRG (or any of its group companies) provided that such counterparty(ies) to any
such transaction agrees to adhere to the terms of this Privacy Notice (or a
similar document) and applicable law.
B. Actual or Prospective Candidates
• To TRG clients in order for them to determine if you (permanent hire
candidate) or your company or employer (contract candidate) are or may be
qualified to fill a vacancy.
• To third parties that you authorize us to send your personal data to such as
“umbrella” companies, insurance brokers and insurance carriers;
• For contract candidates, to third parties under contract with TRG who may
serve as your employer or with whom your company may enter into a contract;
• To third parties to determine if an TRG client or other entity (or their
respective affiliates) to whom TRG presented you has (a) employed you or (b)
retained you or any entity (i) that employed you or (ii) that retained you or
(iii) in which you have a financial interest.
C. Individuals who work for TRG clients (i.e. a client contact)
1) To candidates in the course of providing your company or employer with
recruiting services and to further the recruitment process.
• To third parties where we have retained them to provide services that you have
requested including candidate skill tests and other testing.
• To third parties to determine if an TRG client or other entity (or their
respective affiliates) to whom TRG presented a candidate has (a) employed the
candidate or (b) retained the candidate or any entity (i) that employed the
candidate or (ii) that retained the candidate or (iii) in which the candidate
has a financial interest.
VII. WHAT WILL TRG DO IF MY PERSONAL DATA IS BREACHED?
TRG has put in place reasonable technical, administrative and physical
safeguards intended to prevent a breach of your Personal Data. That being said,
TRG cannot guarantee that your Personal Data will not be breached.
A breach can take many forms, including, without limitation, the loss of your
Personal Data or the unauthorized access to, disclosure, modification, copying
and transfer of your Personal Data.
Once TRG becomes aware of the breach, TRG will take reasonable steps to isolate
the breach, stop the breach, determine the root cause, determine the Personal
Data breached, fix the root cause and determine if notice to you and/or the
appropriate government agency(ies) is required. TRG will comply with all
applicable law in reacting to, and dealing with, a breach of Personal Data.
If you believe, for any reason, that your Personal Data has been breached while
in TRG’s care, custody or control, please email TRG immediately at
privacy@tenthrevolution.com.
If TRG obtains your Personal Data from someone other than you, this Privacy
Notice includes all information required under applicable law except that TRG
shall not provide you with this information if you already possess this
information, providing you with such information is against (or not mandatory
under) applicable law, is subject to an obligation of professional secrecy,
proves impossible, would involve a disproportionate effort or would render
impossible or seriously impair the achievement of the objectives of the
processing, in which case, TRG shall take appropriate measures to protect your
rights, freedoms and legitimate interests. If you have any questions, please
contact TRG at privacy@tenthrevolution.com.
VIII. WILL MY PERSONAL DATA BE TRANSFERRED TO ANOTHER COUNTRY?
Yes, TRG may transfer your Personal Data to the categories of third parties
described in this Privacy Notice, some of whom are located outside of the
country in which you provided your Personal Data to TRG or the country of
collection.
If so, TRG will take reasonable steps to ensure that your Personal Data is
protected and treated in accordance with this Privacy Notice and local
applicable law. The countries where TRG may transfer your Personal Data will
have varying levels of data security practices and laws, some of which may be
less stringent or protective than your country. TRG will use all reasonable
efforts to require that any of its suppliers and vendors who receive your
Personal Data are contractually bound to (a) keep your Personal Data
confidential and (b) take, at a minimum, reasonable efforts to maintain the
privacy and security of your Personal Data.
Under certain circumstances, TRG may share your Personal Data with one or more
of its group companies who may be located in a country other than yours or other
than the country in which TRG collected your Personal Data. In such cases, TRG
will comply with applicable laws and its Intercompany Data Processing Agreements
(“DPAs”). The DPAs are incorporated by reference into this Privacy Notice.
IX. HOW LONG WILL TRG STORE MY PERSONAL DATA FOR?
We are required by applicable law to store your Personal Data for as long as is
necessary to comply with our legal, regulatory and contractual obligations. This
period of time will vary based on the law in your country and in the country
where TRG stores your Personal Data.
In addition, TRG will keep your Personal Data for the identified purposes until
it reasonably believes that it no longer needs it, that there is no reasonable
chance that you, your employer or your company will do business with TRG, and
there is no reason to believe that we will need the Personal Data for any
special circumstances such as the issuance or defence of legal proceedings,
audit, investigation or collections.
X. SENDING TRG PERSONAL DATA OVER THE INTERNET
Your Personal Data is held on servers hosted by us, our internet services
providers or third party vendors with whom TRG has a contract. The transmission
of information via the internet is not completely secure. Although we will take
the efforts set forth in the Privacy Notice to protect your Personal Data, we
cannot guarantee the security of any data transmitted through or to our
Websites. Any transmission of data by you to us over the internet is at your own
risk.
XI. HOW WE COLLECT AND AGGREGATE INFORMATION ABOUT VISITORS TO OUR WEBSITES
We also collect information about the way job seekers and visitors use the
Websites in order to improve our services, to understand our users better, and
to determine aggregate trends, most popular pages, etc. By using the Websites,
you agree that we may share de-identified aggregate data with selected third
parties to assist with these purposes. We may also undertake marketing profiling
to help us identify candidates, clients, or jobs which may be of interest to
you. We may process Personal Data that you submit to us through the Websites
under one or more of the permissible bases for processing Personal Data set
forth in the Privacy Notice.
XII. TECHNOLOGY AND TOOLS
Like many companies, we use technology and tools that tell us when a computer or
device has visited or accessed our content. Those tools include services from
search engines and other companies that help us to tailor our products and
services to better suit our customers and potential customers. Search engines
provide facilities to allow you to indicate your preferences in relation to the
use of those tools in connection with computers and other devices controlled or
used by you.
We also set out further information below about Cookies and Web Beacons.
A. What are cookies?
A “cookie” is a piece of information that is stored on your computer’s hard
drive and which records your navigation of a website so that, when you revisit
that website, it can present tailored options to you based upon the stored
information about your last visit. You can normally alter the settings of your
browser to prevent acceptance of cookies. Cookies are used are many, many
websites, including TRG’s Websites.
B. How do we use cookies and plug-ins?
We use “cookies” and plug ins to: (1) make the Websites function properly and as
a user would normally expect of a commercial website, (2) monitor Website user
traffic patterns and Website usage.; and (3) help us to advertise to you jobs we
think you, your company or your employer will be interested in. Our use of these
tools helps us to understand how our users use our Websites so that we can
develop and improve the design, layout and functionality of the Websites and to
provide more efficient and relevant services to you.
C. There are different kinds of cookies with different functions.
The cookies we use are explained below:
1. Session cookies: these are only stored on your computer during your web
session. They are automatically deleted when the browser is closed. They usually
store an anonymous session ID allowing you to browse a website without having to
log in to each page. They do not collect any information from your computer.
2. Persistent cookies: a persistent cookie is one stored as a file on your
computer, and it remains there when you close your web browser. The cookie can
be read by the website that created it when you visit that website again.
3. Strictly necessary cookies: these cookies are essential to enable you to use
the Websites effectively and therefore cannot be turned off. Without these
cookies, the services available to you on our Websites cannot be provided. These
cookies do not gather information about you that could be used for marketing or
remembering where you have been on the internet.
4. Performance cookies: these cookies enable us to monitor and improve the
performance of our Websites. For example they allow us to count visits, identify
traffic sources and see which parts of the Websites are most popular. These
cookies do not collect information that identifies a visitor, as all information
these cookies collect is anonymous and is only used to improve how our Websites
work.
5. Functional cookies: these cookies allow our Websites to remember choices you
make (such as your user name, language or the region you are in) and provide
enhanced features. These cookies can also be used to remember changes you have
made to text size, font and other pages of our Websites that you can customise.
They may also be used to provide services you have requested such as viewing a
video or commenting on a blog.
6. Personalisation cookies: the TRG Websites use personalisation cookies to help
us to advertise jobs that we think may be of interest to you. These cookies are
persistent and mean that when you log in, or return to, the particular TRG
Website, you may see advertising for jobs that are similar to jobs that you have
previously browsed.
7. Targeting cookies: These cookies may be set through our site by our
advertising partners. They may be used by those companies to build a profile of
your interests and show you relevant adverts on other sites.
For information on how to reject these cookies, see Section E below.
D. Cookies and Plug-ins set by TRG or Third Parties used by TRG
In addition to our various branded Privacy Preference Centers (see the blue
shield in the bottom left-hand corner of your screen), below are tables listing
the cookies that you may encounter on our Websites and the purpose for which we
use each one and the duration that the cookie remains in place (unless you take
action to reject the cookie). TRG may update these tables and its Privacy
Preference Centers from time to time. Most of the cookies on our Websites are
set by third parties. TRG works with several third parties to provide services
which help us to keep the Websites tailored to your needs. Some of these vendors
use cookies to help them deliver these services.
Our developers are working hard on creating an interactive cookie table to
improve your experience. For now, please see the following table below.
Host Cookie Description Type ⇅ Duration tenthrevolution.com _ga_xxxxxxxxxx Used
by Google Analytics to identify and track an individual session with your
device. Performance Cookies 729 Days pi.pardot.com lpv661413 This domain is
owned by Pardot, a marketing automation platform which provides lead generation
services to businesses. Functional Cookies 0 Days www.facebook.com This domain
is owned by Facebook, which is the world’s largest social networking service.
As a third party host provider, it mostly collects data on the interests of
users via widgets such as the ‘Like’ button found on many websites. This is
used to serve targeted advertising to its users when logged into its services.
In 2014 it also started serving up behaviourally targeted advertising on other
websites, similar to most dedicated online marketing companies. Targeting
Cookies and Web beacons (Tracking pixels) SESSION tenthrevolution.com
_gat_UA-155270382-1 This is a pattern type cookie set by Google Analytics, where
the pattern element on the name contains the unique identity number of the
account or website it relates to. It appears to be a variation of the _gat
cookie which is used to limit the amount of data recorded by Google on high
traffic volume websites. Performance Cookies 0 Days www.tenthrevolution.com
_gd############# This cookie contains no identifying information and is used for
diagnostic purposes by Impact Radius, a service we use to track signup
commissions for our affiliate program. We have categorized it under
Functionality because it is necessary for the operation of our affiliate
program. Performance Cookies 730 Days careers.tenthrevolution.com
_gd############# This cookie contains no identifying information and is used for
diagnostic purposes by Impact Radius, a service we use to track signup
commissions for our affiliate program. We have categorized it under
Functionality because it is necessary for the operation of our affiliate
program. Functional Cookies 730 Days onetrust.com _cfuvid This domain is owned
by OneTrust, a privacy management software which helps organizations achieve
compliance with global regulations. Strictly Necessary Cookies SESSION
linkedin.com lidc This domain is owned by LinkedIn, the business networking
platform. It typically acts as a third party host where website owners have
placed one of its content sharing buttons in their pages, although its content
and services can be embedded in other ways. Although such buttons add
functionality to the website they are on, cookies are set regardless of whether
or not the visitor has an active Linkedin profile, or agreed to their terms and
conditions. For this reason it is classified as a primarily tracking/targeting
domain. Functional Cookies 1 Days youtube.com VISITOR_INFO1_LIVE This cookie is
used as a unique identifier to track viewing of videos Performance Cookies 180
Days tenthrevolution.com _gat_UA-nnnnnnn-nn Google Analytics Cookies Targeting
Cookies and Web beacons (Tracking pixels) 0 Days www.youtube.com
TESTCOOKIESENABLED YouTube is a Google owned platform for hosting and sharing
videos. YouTube collects user data through videos embedded in websites, which is
aggregated with profile data from other Google services in order to display
targeted advertising to web visitors across a broad range of their own and other
websites. Targeting Cookies and Web beacons (Tracking pixels) 0 Days
tenthrevolution.com _fbp Used by Facebook to deliver a series of advertisement
products such as real time bidding from third party advertisers Targeting
Cookies and Web beacons (Tracking pixels) 90 Days careers.tenthrevolution.com
PHPSESSID PHP session cookie associated with embedded content from this domain.
Strictly Necessary Cookies SESSION youtube.com VISITOR_PRIVACY_METADATA YouTube
is a Google owned platform for hosting and sharing videos. YouTube collects user
data through videos embedded in websites, which is aggregated with profile data
from other Google services in order to display targeted advertising to web
visitors across a broad range of their own and other websites. Targeting Cookies
and Web beacons (Tracking pixels) 179 Days careers.tenthrevolution.com
OptanonAlertBoxClosed This cookie is set by websites using certain versions of
the cookie law compliance solution from OneTrust. It is set after visitors have
seen a cookie information notice and in some cases only when they actively close
the notice down. It enables the website not to show the message more than once
to a user. The cookie has a normal lifespan of one year and contains no personal
information. Strictly Necessary Cookies 364 Days www.tenthrevolution.com
OptanonAlertBoxClosed This cookie is set by websites using certain versions of
the cookie law compliance solution from OneTrust. It is set after visitors have
seen a cookie information notice and in some cases only when they actively close
the notice down. It enables the website not to show the message more than once
to a user. The cookie has a one year lifespan and contains no personal
information. Strictly Necessary Cookies 362 Days t.co muc_ads This domain is
owned by Twitter. It is used as a URL shortening service, which allows Twitter
to collect data on how links are shared. Targeting Cookies and Web beacons
(Tracking pixels) 729 Days careers.tenthrevolution.com drift_campaign_refresh
This is the session identifier token. It is used to tie the visitor on your
website with a current website session within the Drift system. This is enables
session-specific features, such as popping up a messaging only once during a 30
minute session as to prevent a disruptive experience. Targeting Cookies and Web
beacons (Tracking pixels) 0 Days go.frankgroup.com pardot Performance Cookies 0
Days pi.pardot.com pardot This domain is owned by Pardot, a marketing automation
platform which provides lead generation services to businesses. Performance
Cookies 0 Days linkedin.com bcookie This domain is owned by LinkedIn, the
business networking platform. It typically acts as a third party host where
website owners have placed one of its content sharing buttons in their pages,
although its content and services can be embedded in other ways. Although such
buttons add functionality to the website they are on, cookies are set regardless
of whether or not the visitor has an active Linkedin profile, or agreed to their
terms and conditions. For this reason it is classified as a primarily
tracking/targeting domain. Functional Cookies 731 Days youtube.com YSC YouTube
is a Google owned platform for hosting and sharing videos. YouTube collects user
data through videos embedded in websites, which is aggregated with profile data
from other Google services in order to display targeted advertising to web
visitors across a broad range of their own and other websites. Targeting Cookies
and Web beacons (Tracking pixels) SESSION tenthrevolution.com driftt_aid This is
the anonymous identifier token. It is used to tie the visitor on your website
with the profile within the Drift system. This allows Drift to remember the
information that this site visitor has provided through the chat on subsequent
site visits. Targeting Cookies and Web beacons (Tracking pixels) 729 Days
twitter.com personalization_id This domain is owned by Twitter. The main
business activity is: Social Networking Services. Where twitter acts as a third
party host, it collects data through a range of plug-ins and integrations, that
is primarily used for tracking and targeting. Targeting Cookies and Web beacons
(Tracking pixels) 730 Days www.linkedin.com bscookie This domain is owned by
LinkedIn, the business networking platform. It typically acts as a third party
host where website owners have placed one of its content sharing buttons in
their pages, although its content and services can be embedded in other ways.
Although such buttons add functionality to the website they are on, cookies are
set regardless of whether or not the visitor has an active Linkedin profile, or
agreed to their terms and conditions. For this reason it is classified as a
primarily tracking/targeting domain. Functional Cookies 731 Days
tenthrevolution.com drift_aid This is the anonymous identifier token. It is used
to tie the visitor on your website with the profile within the Drift system.
This allows Drift to remember the information that this site visitor has
provided through the chat on subsequent site visits. Targeting Cookies and Web
beacons (Tracking pixels) 729 Days frank-group.involve.me lvapp_session
Functional Cookies 0 Days www.tenthrevolution.com OptanonConsent This cookie is
set by the cookie compliance solution from OneTrust. It stores information about
the categories of cookies the site uses and whether visitors have given or
withdrawn consent for the use of each category. This enables site owners to
prevent cookies in each category from being set in the users browser, when
consent is not given. The cookie has a normal lifespan of one year, so that
returning visitors to the site will have their preferences remembered. It
contains no information that can identify the site visitor. Strictly Necessary
Cookies 362 Days careers.tenthrevolution.com OptanonConsent This cookie is set
by the cookie compliance solution from OneTrust. It stores information about the
categories of cookies the site uses and whether visitors have given or withdrawn
consent for the use of each category. This enables site owners to prevent
cookies in each category from being set in the users browser, when consent is
not given. The cookie has a normal lifespan of one year, so that returning
visitors to the site will have their preferences remembered. It contains no
information that can identify the site visitor. Strictly Necessary Cookies 364
Days linkedin.com AnalyticsSyncHistory This domain is owned by LinkedIn, the
business networking platform. It typically acts as a third party host where
website owners have placed one of its content sharing buttons in their pages,
although its content and services can be embedded in other ways. Although such
buttons add functionality to the website they are on, cookies are set regardless
of whether or not the visitor has an active Linkedin profile, or agreed to their
terms and conditions. For this reason it is classified as a primarily
tracking/targeting domain. Functional Cookies 30 Days tenthrevolution.com _gid
This cookie name is associated with Google Universal Analytics. This appears to
be a new cookie and as of Spring 2017 no information is available from Google.
It appears to store and update a unique value for each page visited._gid
Performance Cookies 1 Days linkedin.com li_sugr This domain is owned by
LinkedIn, the business networking platform. It typically acts as a third party
host where website owners have placed one of its content sharing buttons in
their pages, although its content and services can be embedded in other ways.
Although such buttons add functionality to the website they are on, cookies are
set regardless of whether or not the visitor has an active Linkedin profile, or
agreed to their terms and conditions. For this reason it is classified as a
primarily tracking/targeting domain. Targeting Cookies and Web beacons (Tracking
pixels) 89 Days careers.tenthrevolution.com visitor_id##### This is a cookie
pattern that appends a unique identifier for a website visitor, used for
tracking purposes. Targeting Cookies and Web beacons (Tracking pixels) 3649 Days
pardot.com visitor_id##### This is a cookie pattern that appends a unique
identifier for a website visitor, used for tracking purposes. Performance
Cookies 3650 Days go.frankgroup.com visitor_id##### This is a cookie pattern
that appends a unique identifier for a website visitor, used for tracking
purposes. Performance Cookies 3650 Days tenthrevolution.com _ga This cookie name
is associated with Google Universal Analytics – which is a significant update to
Google’s more commonly used analytics service. This cookie is used to
distinguish unique users by assigning a randomly generated number as a client
identifier. It is included in each page request in a site and used to calculate
visitor, session and campaign data for the sites analytics reports. By default
it is set to expire after 2 years, although this is customisable by website
owners._ga Performance Cookies 730 Days linkedin.com UserMatchHistory This
domain is owned by LinkedIn, the business networking platform. It typically acts
as a third party host where website owners have placed one of its content
sharing buttons in their pages, although its content and services can be
embedded in other ways. Although such buttons add functionality to the website
they are on, cookies are set regardless of whether or not the visitor has an
active Linkedin profile, or agreed to their terms and conditions. For this
reason it is classified as a primarily tracking/targeting domain. Functional
Cookies 30 Days linkedin.com li_gc This domain is owned by LinkedIn, the
business networking platform. It typically acts as a third party host where
website owners have placed one of its content sharing buttons in their pages,
although its content and services can be embedded in other ways. Although such
buttons add functionality to the website they are on, cookies are set regardless
of whether or not the visitor has an active Linkedin profile, or agreed to their
terms and conditions. For this reason it is classified as a primarily
tracking/targeting domain. Performance Cookies 727 Days pardot.com
visitor_id661413-hash This is a cookie pattern that appends a unique identifier
for a website visitor, used for tracking purposes. Performance Cookies 3650 Days
careers.tenthrevolution.com visitor_id661413-hash This is a cookie pattern that
appends a unique identifier for a website visitor, used for tracking purposes.
Targeting Cookies and Web beacons (Tracking pixels) 3649 Days go.frankgroup.com
visitor_id661413-hash This is a cookie pattern that appends a unique identifier
for a website visitor, used for tracking purposes. Performance Cookies 3650 Days
E. How to reject cookies
If you don’t wish to receive cookies that are not strictly necessary to perform
basic features of our Websites, you may choose to opt out of them by selecting
the blue shield in the bottom left-hand corner of any of the Websites, called
“Privacy Preference Center”.
Note that most web browsers will accept cookies, but if you would rather that we
did not collect data in this way you can choose to accept or reject some or all
cookies in your browser’s privacy settings. Rejecting all cookies means that
certain features of the Website(s) cannot then be provided to you and
accordingly you may not be able to take full advantage of all our Websites’
features. Each browser is different, so check the “Help” menu of your browser to
learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them or
change cookies’ settings, please refer to aboutcookies.org
(http://www.allaboutcookies.org/). You will also find details on how to delete
cookies from your computer. Find out how to manage cookies on popular browsers:
• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari
To find information relating to other browsers, visit the browser developer’s
website.
To opt out of being tracked by Google Analytics across all websites, visit
http://tools.google.com/dlpage/gaoptout.
F. Web Beacons
TRG may use or include web beacons in emails or other electronic communications
that TRG sends to you. We use web beacons to help us analyze the effectiveness
of our communications to you. For example, we may use web beacons to understand
when and if you opened our email, how many times you opened the email, if you
have forwarded the email to another email address, or if you clicked on a link
in an email that we sent to you. The web beacons do not collect or give us your
PII but they do provide information to us about your actions after receiving a
communication from us. If you would like to stop receiving emails with web
beacons from us, you may unsubscribe by clicking the “Unsubscribe” link in the
email. However, you may receive auto generated emails from TRG after you create
an account on the Websites or take some other affirmative action on the Websites
which contain web beacons but do not contain an “Unsubscribe” link. In those
cases, just simply email privacy@tenthrevolution.com if you would like to stop
receiving emails from TRG with web beacons.
Also, TRG works with third parties to help manage online advertising who embed
web beacons in online job postings and job advertisements that TRG requests
these third parties to post online. One such third party that we use is
Broadbean. These web beacons allow Broadbean to obtain information such as the
IP address of the computer that downloaded the page on which the beacon appears,
the URL of the page on which the beacon appears, the time the page containing
the beacon was viewed, the type of browser used to view the page, and the
information in cookies set by a third party that Broadbean uses such as Google
Analytics. These files enable Google Analytics to recognize a unique cookie on
your web browser, which in turn enables Broadbean to learn which advertisements
bring users to our Websites or websites on which Broadbean placed our
advertisements. The cookie on your web browser was placed by Broadbean, or by
another advertiser who works with Google Analytics. With both cookies and web
beacon technology, the information that Google Analytics (either directly, see
cookie/plug-in chart above) or Broadbean collects and shares with us is
anonymous and not personally identifiable. It does not contain your name,
address, telephone number, or email address. For more information about Google
Analytics, including information about how to opt out of these technologies, go
to www.google-analytics.com. For more information about web beacons and cookies
placed by Broadbean, please click https://www.broadbean.com/uk/privacy-policy/.
XIII. Links to other websites
Please note that clicking on links and banner advertisements and RSS (Rich Site
Summary) feeds may result in your transfer to another website, where data
privacy practices may be different than described in this Privacy Notice. It is
your responsibility to check other website privacy notices and policies to
ensure that you are happy for your personal information, including Personal
Data, to be used in accordance with those third parties’ privacy notices and
policies. We accept no responsibility for, and have no control over, third party
websites, links, adverts or RSS feeds or information that is submitted to or
collected by third parties.
XIV. Changes to our Privacy Notice
We reserve the right to change this Privacy Notice from time to time by updating
this Privacy Notice on our website. Any changes to this Privacy Notice or any of
its addendums will be posted on this Website so you are always aware of what
information we collect, how we use it, and under what circumstances, if any, we
disclose it. We encourage you to check this Website frequently for updates. Your
continued use of this Website or any TRG services shall constitute your
acceptance of the revised Privacy Notice.
TRG will interpret and enforce this Privacy Notice in accordance with all
applicable law.
The effective date of this Privacy Notice is March 25, 2018. This Privacy Notice
was updated on March 25, 2018; October 4, 2018; April 15, 2019; July 10, 2019;
January 1, 2020; April 20, 2020; May 18, 2020, October 8, 2020, February 18,
2021, May 12, 2021, June 30, 2021, July 9, 2021, July 16, 2021, September 13,
2022 April 3, 2023, November 1, 2023, December 15, 2023, March 1, 2024, April 4,
2024, April 18, 2024, May 15, 2024 and June 30, 2024.
This Privacy Notice was last updated on July 15 2024.
UNITED KINGDOM ADDENDUM
I. Who is TRG’s Supervisory Authority for Data Protection Purposes?
TRG has designated the UK Information Commissioner’s Office (“ICO”) as the
supervisory authority for purposes of Data Protection Act of 2018 (“DPA 2018”)
and UK General Data Protection Regulation (“UK GDPR”).This addendum applies to
the United Kingdom only.
II. How do we lawfully process your data?
In order to process your Personal Data lawfully TRG must have a legal basis to
do so. TRG relies on three main legal basis for processing your Personal Data:
• where we obtain your affirmative consent to use your Personal Data in this
way;
• where we have a legitimate interest in processing your Personal Data, which we
have balanced against your rights and freedoms and concluded that our processing
is justifiable; or
• where our handling of your Personal Data is necessary for us to perform the
obligations under your company’s or employer’s contract with TRG (inapplicable
to candidates for permanent hire).
We may rely on one or more legal bases to process your Personal Data.
A. All users of the Websites and/or our services
Legitimate Interests: TRG uses Personal Data that we collect for the following
general purposes in the performance of our legitimate interests as a business:
to provide the services to our candidates and clients; to enhance their
experience, to improve our services and to contact candidates and clients.
B. Actual or Prospective Candidates
Consent: If you, whether on your own behalf (permanent hire candidate) or on
behalf of your company or your employer (contract hire candidate), would like to
receive general marketing and other communications from us, you will have the
option to affirmatively check a box consenting to TRG processing your Personal
Data for this purpose. TRG may also ask you via email, text message or SMS
(standard SMS or text message rates may apply), or telephone for your
affirmative consent to receive marketing and other communications from us.
Legitimate interest: TRG has a legitimate interest in processing your Personal
Data in order to fill a job, to provide you (permanent hire candidate) or your
company or your employer (contract hire candidate) with other products and
services to help you in your career and to market its products and services to
you in order to grow our business, to demonstrate our knowledge of the
marketplace and relevant technologies and to enhance the standing and
recognition of our brands. TRG also has legitimate interest to process your
Personal Data if you apply for, or seek further information about, a job posted
on one of the Websites or a job advertised by TRG on a job board, social media
site or other forums.
Necessary for the performance of a contract: TRG can process your Personal Data
in the performance of its contract with your company or employer.
C. Individuals who work for TRG clients (i.e. a client contact)
Consent: If you would like to receive general marketing and other communications
from us, you will have the option to affirmatively check a box consenting to TRG
processing your Personal Data for this purpose. TRG may also ask you via email,
text message or SMS (standard SMS or text message rates may apply), or telephone
for your affirmative consent to receive marketing and other communications from
us.
Legitimate Interest: TRG has a legitimate interest in processing your Personal
Data in order to fill a vacancy at your company or employer, and provide you
with other products and services relevant to your company or employer and to
market its products and services to you in order to grow our business, to
demonstrate our knowledge of the marketplace and relevant technologies and to
enhance the standing and recognition of our brands. TRG also has legitimate
interest to process your Personal Data if you seek or obtain further information
about TRG or an TRG candidate.
Necessary for the performance of a contract: TRG can process your Personal Data
in the performance of its contract with your company or employer.
With respect to actual or prospective client contacts and candidates, if TRG
obtains your Personal Data from someone other than you, TRG shall inform you of
the identity and contact details of the person or entity from whom TRG obtained
your Personal Data, whether TRG obtained your Personal Data from publicly
available sources, the categories of Personal Data that TRG obtained and, if TRG
is processing your Personal Data based on its legitimate interest (see Section
III below), the nature of TRG’s legitimate interest. TRG shall provide you with
the information listed in this paragraph by the earlier of (1) forty-five (45)
days (for candidates) or ninety (90) days (for client contacts) after TRG
obtains your Personal Data or (2) if TRG uses your Personal Data to communicate
with you, the first time that TRG communicates with you.
TRG shall not provide you with the information described in the paragraph
immediately above if you already possess this information, providing you with
such information is against applicable law, is subject to an obligation of
professional secrecy, proves impossible, would involve a disproportionate effort
or would render impossible or seriously impair the achievement of the objectives
of the processing, in which case, TRG shall take appropriate measures to protect
your rights, freedoms and legitimate interests.
III. Your Special Rights under Data Protection Laws
A. Do I have a right to be erased (forgotten)?
Yes. You have the right to request that TRG deletes or removes your Personal
Data where there is no compelling reason for us to continue to process it. You
can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com.
Please note that your right to erasure is not absolute. TRG will remove your
Personal Data when:
1. the Personal Data is no longer necessary in relation to the purpose for which
TRG originally collected and/or processed it;
2. if TRG is processing your Personal Data on the basis of your consent and you
withdraw consent;
3. you object to the processing of your Personal Data and there is no overriding
legitimate interest for us to continue to process it;
4. the Personal Data was unlawfully processed; and
5. the Personal Data must be erased to comply with a legal obligation.
TRG can refuse to comply with an erasure request in the following limited
circumstances:
(a) to exercise TRG’s right of freedom of expression and information;
(b) to comply with a legal obligation or for the performance of a public
interest task;
(c) for archiving purposes in the public interest, scientific research,
historical research or statistical purposes; or
(d) for the establishment, exercise or defence of legal claims.
If we remove your Personal Data per your request for erasure, then we will
confirm this with you.
If we have disclosed any of your Personal Data to a third party and you submit
an erasure request to us, then we will inform (1) you about the recipients and
(2) any such third parties of your erasure request unless doing so is impossible
or involves disproportionate efforts.
We will respond to your erasure request without undue delay. Please note that,
for your and TRG’s protection, we cannot respond to an erasure request until we
have verified the identity of the person making the request. This verification
process may extend the response timeframes set forth in this paragraph.
B. Do I have a right of access to a copy of my Personal Data?
Yes. You have the right to:
• obtain confirmation that your Personal Data is being processed;
• a copy of your Personal Data being processed;
• the purposes of the processing;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom TRG has disclosed your
Personal Data; and
• the criteria TRG uses to determine how long it will store your Personal Data.
You can exercise this right by sending an email to TRG at
privacy@tenthrevolution.com.
This right is in place to ensure that you are aware of and can verify the
lawfulness of the processing. In most cases, we will provide you with a copy of
your Personal Data free of charge. However, we may charge you a reasonable fee
if your request is manifestly unfounded, excessive or repetitive. With respect
to unfounded, excessive or repetitive requests, in rare cases, TRG may refuse to
respond to your request but will explain the reason(s) for its refusal to you
without undue delay and within one month of its receipt of your request. If TRG
so refuses, you have the right to file a complaint with the ICO and to seek a
judicial remedy.
If you submit your access request to TRG electronically, TRG will provide you
with its response, and a copy of your Personal Data (if applicable) via email or
other commonly used electronic form.
If TRG did not collect your Personal Data from you, TRG will inform you about
the source from which it obtained your Personal Data. Your right of access does
not adversely affect your right of erasure (forgotten) and right of
rectification, both of which are described in this Privacy Notice.
Generally, TRG will provide you with a copy of your Personal Data without undue
delay and within one month of its receipt of your request, provided that TRG may
extend this time period for up to two additional months if your request is
complex or numerous. If TRG exercises this extension of time, TRG will inform
you of its decision to exercise the extension within one month of its receipt of
your request, and will explain the reason(s) for the extension. If your request
is large or complex, TRG may ask you to specify the particular information or
category of information you seek.
Please note that, for your and TRG’s protection, TRG cannot respond to an access
request until it verifies the identity of the person making the request for your
Personal Data. This verification process may extend the response timeframes set
forth in the paragraph above.
C. Do I have a right to object to the processing of my Personal Data, including
the processing of my Personal Data by TRG for direct marketing?
Yes, you have a right to object to the processing of your Personal Data where:
• TRG’s processing is based on its legitimate interest; or
• where TRG is using your Personal Data to directly market to you.
You can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com.
If TRG receives an objection request from you for reasons unrelated to direct
marketing, TRG will stop processing your Personal Data unless we can show
compelling legitimate ground(s) for the processing which override your
interests, rights and freedoms or for the establishment, exercise or defence of
any legal claims.
If TRG receives an objection request from you for reasons related to direct
marketing, we will stop processing your Personal Data.
If you receive a direct marketing communication from TRG and you do not wish to
receive future direct marketing communications from TRG, you may request to
unsubscribe from future marketing communications by sending TRG an email at
privacy@tenthrevolution.com. In addition, if the direct marketing communication
you received was via email, you can click the “Unsubscribe” link at the bottom
of the email, fill out the required form and TRG will process your unsubscribe
request. Please allow up to ten (10) business days for your unsubscribe request
to take effect.
D. Do I have a right to restrict processing of my Personal Data?
Yes, you have a right to restrict, the processing of your Personal Data. You can
exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com. When you exercise this right, TRG may continue to
store your Personal Data but cannot further process it. TRG will cease
processing your Personal Data in the following circumstances:
1. when you file a rectification request with TRG (see the “Do I have a right to
have any inaccurate or incomplete Personal Data rectified?” section below) in
accordance with this Privacy Notice and applicable law. The restriction shall
remain in place until such time as TRG has verified the accuracy of the Personal
Data that is the subject of your rectification request;
2. where TRG is processing your Personal Data based on its legitimate interest
and you file a notice with TRG objecting to the processing of your Personal Data
(see the “Do I have a right to object to the processing of my Personal Data?”
section above) in accordance with this Privacy Notice and applicable law, TRG
will cease processing your Personal Data until such time as TRG has made a
determination as to whether its legitimate grounds for continued processing
override your reasons for objecting to the processing;
3. when the processing is unlawful and you do not seek or want erasure and you
file a restriction request with TRG in accordance with this Privacy Notice and
applicable law instead; and
4. if TRG no longer needs the Personal Data and you require the data to
establish, exercise or defend a legal claim.
While the processing of your Personal Data is restricted, TRG may continue to
process such data by storing it, processing it with your consent or processing
it for the establishment, exercise or defence of legal claims.
TRG will inform you if it decides to lift a restriction on processing.
If TRG has disclosed any of your Personal Data to a third party and you submit a
request to restrict processing, TRG will inform (1) you about the recipients if
you so request and (2) any such third parties of your restriction request unless
doing so is impossible or involves disproportionate efforts.
TRG will act on your restriction request in accordance with this Privacy Notice
without undue delay. Please note that, for your and TRG’s protection, TRG cannot
act on a restriction request until it verifies the identity of the person making
the request. This verification process may extend the timeframe in which TRG
acts on your restriction request.
E. Do I have a right to Personal Data portability?
Yes. You can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com. This right exists to allow you to obtain and use
your Personal Data for your own purposes across different services. Under this
right, you can move, copy or transfer your Personal Data from TRG to another
data controller.
This right applies where TRG is processing your Personal Data with your consent
or for the performance of a contract. It also applies if we process your
Personal Data by automated means. If your portability request concerns someone
other than you, TRG will have to consider whether providing or porting the
Personal Data would prejudice the other person’s or people’s rights.
Generally, TRG will respond to your portability request without undue delay and
within one month of its receipt of your request, provided that TRG may extend
this time period for up to two additional months if your request is complex or
numerous. If TRG exercises this extension of time, TRG will inform you of its
decision to exercise the extension within one month of its receipt of your
request, and will explain the reason(s) for the extension. Where technically
feasible, you may request that TRG transmit your Personal Data to another data
controller.
F. Do I have a right to object to decision been taken by automated means?
If TRG uses automated (i.e. non-human) methods to process your Personal Data to
make decisions that could potentially have a damaging legal or similarly
significant effect on you (each, an “Automated Decision”), you have the right
not to be subject to the Automated Decision. This right is inapplicable to any
Automated Decision made by TRG that is necessary for entering into or the
performance of a contract between you and TRG, is authorized by law or is based
on your explicit consent.
If TRG makes any Automated Decisions to which this right applies, TRG will
ensure that you are able to obtain human intervention, express your point of
view and obtain an explanation of the decision and challenge it.
If TRG engages in “profiling” by automated means, TRG will ensure that
appropriate safeguards are in place including (1) ensuring that the processing
is fair and transparent by providing you with meaningful information about the
logic involved and the significance and consequences of the outcome of the
decision, (2) using appropriate mathematical or statistical procedures for the
profiling, (3) implementing appropriate technical and organizational measures to
enable inaccuracies to be corrected and minimize the risk of errors and (4)
securing the Personal Data in a way that is proportionate to the risk to your
interests and rights and prevents discriminatory effects.
G. Do I have a right to have any inaccurate or incomplete Personal Data
rectified?
Yes. You can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com.
Generally, TRG will respond to your rectification request within one month of
its receipt of your request, provided that TRG may extend this time period for
up to two additional months if your request is complex. In rare cases, TRG may
refuse to respond to your request but will explain the reason(s) for its refusal
to you within one month of its receipt of your request. If TRG so refuses, you
have the right to file a complaint with the ICO and to seek a judicial remedy.
If TRG has disclosed any of your Personal Data to a third party and you submit a
rectification request to TRG that TRG is going to honor, TRG will inform (1) you
about the recipients and (2) any such third parties of your rectification
request as well as any corrected Personal Data, unless doing so is impossible or
involves disproportionate efforts.
We will use reasonable endeavours to ensure that your Personal Data is
maintained and up to date.
H. What are my rights if the Security of my Personal Data is breached?
A breach of Personal Data (a “Breach”) means a breach of security leading to the
destruction, loss, alteration, unauthorized disclosure of, or access to, your
Personal Data for which we are responsible under applicable law.
If the Breach is likely to have a significant detrimental effect on your rights
and freedoms (such as resulting in discrimination, damage to reputation or
financial loss), TRG will notify the ICO without undue delay, and if feasible,
within one business day of TRG’s becoming aware of the Breach. TRG will assess
the determination of “significant detrimental effect” on a case by case basis.
If the Breach is likely to result in a “high risk” to your rights and freedoms,
TRG will notify you without undue delay. To be clear, the threshold requiring
TRG to notify you of a Breach is higher than the threshold requiring TRG to
notify the ICO of a Breach so it is possible that TRG will notify the ICO of a
Breach but not you. TRG will assess the determination of “high risk” on a case
by case basis.
Any Breach notice issued by TRG will contain, where possible, (1) the categories
and approximate number of individuals and Personal Data records effected by the
Breach, (2) the name and contact details of the Information System Manager
(“ISM”) (or other TRG contact representative if TRG does not have a ISM at the
time that TRG issues the Breach notice), (3) a description of the likely
consequences of the Breach, (4) a description of the measures that TRG has
taken, and may take, to stop the Breach and, where appropriate, to mitigate the
adverse effects of the Breach and (5) recommendations on actions you can take to
protect yourself in light of the Breach.
I. Will my Personal Data be transferred outside the UK?
TRG may transfer your Personal Data to third parties described in this Privacy
Notice who are located outside of the UK. If so, TRG will take reasonable steps
to ensure that your Personal Data is protected and treated in accordance with
this Privacy Notice and local applicable law. Some of the countries outside the
UK where your Personal Data may be transferred will be on the ICO’s list of
countries that it has deemed to have adequate security controls in place (the
“Approved List”). Given the European Court of Justice’s decision in Data
Protection Commissioner v. Facebook Ireland and Maximilian Schrems, Case
C-311/18 (July 16, 2020) (“Schrems II”) , and absent consent from the Data
Subject (or any other reason provided in UK GDPR Article 49(1)(b)-(f) as may be
amended from time to time), if TRG transfers your Personal Data to processors
(which could be external third party vendors or suppliers) that store, transfer,
process, or control your Personal Data in a country not on the Approved List or
not in the UK (“Third Countries”), then TRG shall determine whether each
processor (and each subprocessor that a processor has provided TRG formal notice
of) can store, transfer, process, or control the Personal Data solely within the
UK, or a country on the Approved List.
(a) If TRG determines that the processor (and each subprocessor that a processor
has provided TRG formal notice of) can store, transfer, process, or control the
Personal Data solely within a country on the Approved List or in the UK, we will
require such processor (and will require the processor to require each of its
applicable subprocessors) to do so.
(b) If TRG determines that the processor (and each subprocessor that a processor
has provided TRG formal notice of) cannot store, transfer, process, or control
the Personal Data in a country on the Approved List or in the UK, then:
(i) TRG will require such processor (and will require the processor to require
each of its applicable subprocessors) to be bound by the model clauses
promulgated by the ICO under S119A(1) Data Protection Act 2018, including but
not limited to the International Data Transfer Addendum to the EU Commission
Standard Contractual Clauses VERSION B1.0, as in force 21 March 2022, any
successor versions thereto, and any other valid transfer mechanism promulgated
by the ICO (collectively for this Addendum, “Model Clauses”). When relying on
the Model Clauses, TRG shall (a) monitor the laws and regulations of Third
Countries for the adequate protections of UK. Data Subjects as required by the
UK GDPR or other local laws and regulations; and (b) terminate the storage,
transfer, processing , or control of Personal Data by a processor (or a
subprocessor where the process has informed TRG of the country in which such
subprocessor is processing your Personal Data) when (i) such laws and
regulations of Third Countries are incompatible with the UK GDPR or other local
laws and regulations, or (ii) access to Personal Data is requested by the public
authorities of Third Countries and such access is lawful under the laws of the
Third Countries but is prohibited under the UK GDPR or other local laws and
regulations. If the events described in III(I)(b)(i)(b)(i) or (ii) occur, TRG
will confer with the appropriate supervisory authority regarding appropriate
actions to safeguard your Personal Data.
(c) TRG shall also require the processor (and will require each processor to
require its applicable subprocessors) to determine whether each processor or
subprocessor can store, transfer, process, or control the Personal Data solely
within the UK, or a country on the Approved List.
1. If processor (or its applicable subprocessors) can store, transfer, process,
or control the Personal Data solely within the UK, or a country on the Approved
List, then TRG shall contractually require the processors (and require processor
to require its subprocessors to) do so.
2. If processor (or its applicable subprocessors) must store, transfer, process,
or control the Personal Data in a Third Country, then TRG shall require its
processors (and require processor to require its subprocessors to) to be bound
by the Model Clauses. When relying on the Model Clauses, TRG shall contractually
require such processors (and shall also require processors to require their
subprocessors) to agree to (a) monitor the laws and regulations of Third
Countries for the adequate protections of UK Data Subjects as required by the UK
GDPR or other local laws and regulations; and (b) terminate the transfer,
processing, or control of Personal Data when (i) such laws and regulations of
Third Countries are incompatible with the UK GDPR or other local laws and
regulations, or (ii) access to Personal Data is requested by the public
authorities of Third Countries and such access is lawful under the laws of the
Third Countries but is prohibited under the UK GDPR or other local laws and
regulations. If the events described in III(I)(c)(2)(b)(i) or (ii) occur with
respect to your Personal Data (and if TRG has formal notice that the events
described in III(I)(c)(2)(b)(i) or (ii) have occurred), TRG will confer with the
appropriate supervisory authority regarding appropriate actions to safeguard
your Personal Data.
Under certain circumstances, TRG may share your Personal Data with one or more
of its group companies who may be located in a Third Country. In such cases, TRG
will comply with its DPAs. The DPAs are incorporated by reference into this
Addendum.
J. How long will TRG store my Personal Data for?
We are required by law to store your Personal Data for as long as is necessary
to comply with our legal, regulatory and contractual obligations.
With respect to UK GDPR (and similar laws), we will store and process your
Personal Data that we obtain via: (i) your consent, until the earlier of (a) the
purpose for which we obtained such information has been fully accomplished or
(b) you inform us that you have withdrawn your consent; (ii) our legitimate
interest until the earlier of (a) your Personal data is no longer necessary for
the purpose for which it is being processed, or (b) TRG concludes that your
rights and freedoms outweigh our right to process your Personal Data; and (iii)
our necessity for the performance of a contract, until the termination or
expiration of the contract including the termination or expiration of TRG’s and
your employer’s or company’s duties or obligations that survive any such
termination or expiration.
Furthermore, we will store your Personal Data in special circumstances related
to the issuance or defense of legal proceedings, outstanding invoices or in
connection with any investigation by or of a government authority.
K. What Protections do I have if TRG transfers my Personal Data to the U.S.?
If TRG transferred any of your data to the U.S. you have the protections of the
Model Clauses and the UK Extension to the EU-U.S. Data Privacy Framework. Frank
Recruitment Group Inc., a Delaware corporation, is TRG’s primary affiliate and
operating company in the United States (“TRG US Parent”). TRG US Parent has a
subsidiary, Frank Recruitment Group Services Inc., also a Delaware corporation
(“TRGS US Sub,” collectively with TRG US Parent, “TRG US”).
TRG US and TRG US Sub participates in the UK Extension to the EU-U.S. Data
Privacy Framework (“UK Ext. DPF”) as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal information
transferred from the United Kingdom, as applicable to the United States in
reliance on UK Ext. DPF. TRG US and TRG US Sub has certified to the Department
of Commerce that it adheres to the UK Ext. DPF Principles with respect to such
information. If there is any conflict between the terms in this Privacy Notice
and the UK Ext. DPF Principles, the UK Ext. DPF Principles shall govern. To
learn more about the UK Ext. DPF program, and to view evidence of our
participation, please visit the U.S. Department of Commerce’s Data Privacy
Framework website.
This Privacy Notice only applies to Personal Data within the scope of the TRG
US’s UK Ext. DPF participation. TRG US’s contractual clauses for its clients are
in the United States of America Addendum below.
TRG US’s UK Ext. DPF participation covers Personal Data regarding:
(1) current, former, and prospective employees in connection with the employment
relationship which is covered by a separate, employee only, Privacy Notice that
has been made available to TRG US employees;
(2) Personal Data regarding client contacts and candidates (temp and perm), such
as the sale and delivery of recruitment services and the administration of the
client and candidate relationship; and
(3) Personal Data regarding third parties (such as service providers and
independent contractors) and their personnel and employees, in connection with
recruitment services and the provision and performance of technical professional
services to client and, where applicable, their end customers and the management
and administration of the business relationships with such third parties.
Our participation does not cover any disclosure of an individual’s Personal Data
to a third party who processes the Personal Data for its own purposes when the
disclosure is made at the request of the individual.
TRG US disclose Personal Data to third party service providers in connection
with the operation of their respective businesses, including their provision of
services to clients and candidates. TRG US ascertain that these third party
service providers provide at least the same level of privacy protection as is
required by the UK Ext. DPF Principles. TRG US may be liable if both
(a) third parties fail to meet these obligations and (b) TRG US is responsible
for the event giving rise to the damage.
TRG US are subject to the investigatory and enforcement powers of the United
States Federal Trade Commission. TRG US may be required to disclose Personal
Data to law enforcement, regulatory or other government agencies, or to other
third parties, in each case to comply with legal, regulatory, or national
security obligations or requests.
Any questions or complaints concerning TRG US’s UK Ext. DPF compliance, or
requests to access, correct, amend, delete, or limit the use or disclosure of
Personal Data (opt out) may be directed to privacy@tenthrevolution.com. If TRG
US has not been able to satisfactorily resolve the issue, then you may raise it
with the Information Commissioner’s Office. Under certain conditions,
individuals may have the possibility to engage in binding arbitration through
the UK Ext. DPF Panel. To find out more about individual binding arbitration,
please visit the U.S. Department of Commerce’s Data Privacy Framework Annex 1.
In compliance with the UK Ext. DPF. Tenth Revolution Group US commits to
cooperate and comply respectively with the advice of the panel established by
the UK Information Commissioner’s Office (ICO) with regard to unresolved
complaints concerning our handling of personal data received in reliance on the
UK Ext. DPF.
Should your complaint relate to TRG US’s failure to comply with its UK Ext. DPF
commitments and remains unresolved and you reside in the UK, then you should
contact the Information Commissioner’s Office Wycliffe House Water Lane Wilmslow
Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) Fax: 0162 552 4510 Or via below
link : https://ico.org.uk/make-a-complaint/
ICO regional offices
Scotland
Information Commissioner’s Office
45 Melville Street
Edinburgh
EH3 7HL
Tel: 0303 123 1115
Email: scotland@ico.org.uk
Wales
Information Commissioner’s Office
2nd floor
Churchill House
Churchill way
Cardiff
CF10 2HH
Tel: 0330 414 6421
Email: wales@ico.org.uk
Northern Ireland
Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB
Tel: 028 9027 8757 or 0303 123 1114
Email: ni@ico.org.uk
EUROPEAN ECONOMIC AREA & SWISS ADDENDUM
This Addendum applies to the European Economic Area (“EEA”) and Swiss residents.
I. Who are TRG’s Supervisory Authorities and European Union Representative for
Data Protection Purposes?
TRG’s EEA Lead Supervisory Authority under GDPR Chapter 6 is the Autoriteit
Persoonsgegevens (AP) within the Kingdom of the Netherlands (“EEA LSA”). Our
European Union Representative for purposes of GDPR Article 27 is Frank
Recruitment Group Netherlands B.V. (“EU Rep.”). TRG’s Switzerland Lead
Supervisory Authority is the Swiss Federal Data Protection and Information
Commissioner (“FDPIC”). For this Addendum, the EEA LSA and the FDPIC shall
collectively be referred to as “LSA.”
II. How do we lawfully process your data?
In order to process your Personal Data lawfully TRG must have a legal basis to
do so. TRG relies on three main legal basis for processing your Personal Data:
• where we obtain your affirmative consent to use your Personal Data in this
way;
• where we have a legitimate interest in processing your Personal Data, which we
have balanced against your rights and freedoms and concluded that our processing
is justifiable; or
• where our handling of your Personal Data is necessary for us to perform the
obligations under your company’s or employer’s contract with TRG (inapplicable
to candidates for permanent hire).
We may rely on one or more legal bases to process your Personal Data
A. All users of the Websites and/or our services
Legitimate Interests: TRG uses Personal Data that we collect for the following
general purposes in the performance of our legitimate interests as a business:
to provide the services to our candidates and clients; to enhance their
experience, to improve our services and to contact candidates and clients.
B. Actual or Prospective Candidates
Consent: If you, whether on your own behalf (permanent hire candidate) or on
behalf of your company or your employer (contract hire candidate), would like to
receive general marketing and other communications from us, you will have the
option to affirmatively check a box consenting to TRG processing your Personal
Data for this purpose. TRG may also ask you via email, text message or SMS
(standard SMS or text message rates may apply), or telephone for your
affirmative consent to receive marketing and other communications from us.
Legitimate interest: TRG has a legitimate interest in processing your Personal
Data in order to fill a job, to provide you (permanent hire candidate) or your
company or your employer (contract hire candidate) with other products and
services to help you in your career and to market its products and services to
you in order to grow our business, to demonstrate our knowledge of the
marketplace and relevant technologies and to enhance the standing and
recognition of our brands. TRG also has legitimate interest to process your
Personal Data if you apply for, or seek further information about, a job posted
on one of the Websites or a job advertised by TRG on a job board, social media
site or other forums.
Necessary for the performance of a contract: TRG can process your Personal Data
in the performance of its contract with your company or employer.
C. Individuals who work for TRG clients (i.e. a client contact)
Consent: If you would like to receive general marketing and other communications
from us, you will have the option to affirmatively check a box consenting to TRG
processing your Personal Data for this purpose. TRG may also ask you via email,
text message or SMS (standard SMS or text message rates may apply), or telephone
for your affirmative consent to receive marketing and other communications from
us.
Legitimate Interest: TRG has a legitimate interest in processing your Personal
Data in order to fill a vacancy at your company or employer, and provide you
with other products and services relevant to your company or employer and to
market its products and services to you in order to grow our business, to
demonstrate our knowledge of the marketplace and relevant technologies and to
enhance the standing and recognition of our brands. TRG also has legitimate
interest to process your Personal Data if you seek or obtain further information
about TRG or an TRG candidate.
Necessary for the performance of a contract: TRG can process your Personal Data
in the performance of its contract with your company or employer.
With respect to actual or prospective client contacts and candidates, if TRG
obtains your Personal Data from someone other than you, TRG shall inform you of
the identity and contact details of the person or entity from whom TRG obtained
your Personal Data, whether TRG obtained your Personal Data from publicly
available sources, the categories of Personal Data that TRG obtained and, if TRG
is processing your Personal Data based on its legitimate interest (see Section
III below), the nature of TRG’s legitimate interest. TRG shall provide you with
the information listed in this paragraph by the earlier of (1) forty-five (45)
days (candidates) or ninety (90) days (for client contacts) after TRG obtains
your Personal Data or (2) if TRG uses your Personal Data to communicate with
you, the first time that TRG communicates with you.
TRG shall not provide you with the information described in the paragraph
immediately above if you already possess this information, providing you with
such information is against applicable law, is subject to an obligation of
professional secrecy, proves impossible, would involve a disproportionate effort
or would render impossible or seriously impair the achievement of the objectives
of the processing, in which case, TRG shall take appropriate measures to protect
your rights, freedoms and legitimate interests.
III. Your Special Rights under Data Protection Laws
A. Do I have a right to be erased (forgotten)?
Yes. You have the right to request that TRG deletes or removes your Personal
Data where there is no compelling reason for us to continue to process it. You
can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com.
Please note that your right to erasure is not absolute. TRG will remove your
Personal Data when:
1. the Personal Data is no longer necessary in relation to the purpose for which
TRG originally collected and/or processed it;
2. if TRG is processing your Personal Data on the basis of your consent and you
withdraw consent;
3. you object to the processing of your Personal Data and there is no overriding
legitimate interest for us to continue to process it;
4. the Personal Data was unlawfully processed; and
5. the Personal Data must be erased to comply with a legal obligation.
TRG can refuse to comply with an erasure request in the following limited
circumstances:
(a) to exercise TRG’s right of freedom of expression and information;
(b) to comply with a legal obligation or for the performance of a public
interest task;
(c) for archiving purposes in the public interest, scientific research,
historical research or statistical purposes; or
(d) for the establishment, exercise or defence of legal claims.
If we remove your Personal Data per your request for erasure, then we will
confirm this with you.
If we have disclosed any of your Personal Data to a third party and you submit
an erasure request to us, then we will inform (1) you about the recipients and
(2) any such third parties of your erasure request unless doing so is impossible
or involves disproportionate efforts.
We will respond to your erasure request without undue delay. Please note that,
for your and TRG’s protection, we cannot respond to an erasure request until we
have verified the identity of the person making the request. This verification
process may extend the response timeframes set forth in this paragraph.
B. Do I have a right of access to a copy of my Personal Data?
Yes. You have the right to:
• obtain confirmation that your Personal Data is being processed;
• a copy of your Personal Data being processed;
• the purposes of the processing;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom TRG has disclosed your
Personal Data; and
• the criteria TRG uses to determine how long it will store your Personal Data.
You can exercise this right by sending an email to TRG at
privacy@tenthrevolution.com.
This right is in place to ensure that you are aware of and can verify the
lawfulness of the processing. In most cases, we will provide you with a copy of
your Personal Data free of charge. However, we may charge you a reasonable fee
if your request is manifestly unfounded, excessive or repetitive. With respect
to unfounded, excessive or repetitive requests, in rare cases, TRG may refuse to
respond to your request but will explain the reason(s) for its refusal to you
without undue delay and within one month of its receipt of your request. If TRG
so refuses, you have the right to file a complaint with our LSA against either
our EU Rep. in the EEA or our Swiss entity in Switzerland and to seek a judicial
remedy.
If you submit your access request to TRG electronically, TRG will provide you
with its response, and a copy of your Personal Data (if applicable) via email or
other commonly used electronic form.
If TRG did not collect your Personal Data from you, TRG will inform you about
the source from which it obtained your Personal Data. Your right of access does
not adversely affect your right of erasure (forgotten) and right of
rectification, both of which are described in this Privacy Notice.
Generally, TRG will provide you with a copy of your Personal Data without undue
delay and within one month of its receipt of your request, provided that TRG may
extend this time period for up to two additional months if your request is
complex or numerous. If TRG exercises this extension of time, TRG will inform
you of its decision to exercise the extension within one month of its receipt of
your request, and will explain the reason(s) for the extension. If your request
is large or complex, TRG may ask you to specify the particular information or
category of information you seek.
Please note that, for your and TRG’s protection, TRG cannot respond to an access
request until it verifies the identity of the person making the request for your
Personal Data. This verification process may extend the response timeframes set
forth in the paragraph above.
C. Do I have a right to object to the processing of my Personal Data, including
the processing of my Personal Data by TRG for direct marketing?
Yes, you have a right to object to the processing of your Personal Data where:
• TRG’s processing is based on its legitimate interest; or
• where TRG is using your Personal Data to directly market to you.
You can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com.
If TRG receives an objection request from you for reasons unrelated to direct
marketing, TRG will stop processing your Personal Data unless we can show
compelling legitimate ground(s) for the processing which override your
interests, rights and freedoms or for the establishment, exercise or defence of
any legal claims.
If TRG receives an objection request from you for reasons related to direct
marketing, we will stop processing your Personal Data.
If you receive a direct marketing communication from TRG and you do not wish to
receive future direct marketing communications from TRG, you may request to
unsubscribe from future marketing communications by sending TRG an email at
privacy@tenthrevolution.com. In addition, if the direct marketing communication
you received was via email, you can click the “Unsubscribe” link at the bottom
of the email, fill out the required form and TRG will process your unsubscribe
request. Please allow up to ten (10) business days for your unsubscribe request
to take effect.
D. Do I have a right to restrict processing of my Personal Data?
Yes, you have a right to restrict, the processing of your Personal Data. You can
exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com. When you exercise this right, TRG may continue to
store your Personal Data but cannot further process it. TRG will cease
processing your Personal Data in the following circumstances:
1. when you file a rectification request with TRG (see the “Do I have a right to
have any inaccurate or incomplete Personal Data rectified?” section below) in
accordance with this Privacy Notice and applicable law. The restriction shall
remain in place until such time as TRG has verified the accuracy of the Personal
Data that is the subject of your rectification request;
2. where TRG is processing your Personal Data based on its legitimate interest
and you file a notice with TRG objecting to the processing of your Personal Data
(see the “Do I have a right to object to the processing of my Personal Data?”
section above) in accordance with this Privacy Notice and applicable law, TRG
will cease processing your Personal Data until such time as TRG has made a
determination as to whether its legitimate grounds for continued processing
override your reasons for objecting to the processing;
3. when the processing is unlawful and you do not seek or want erasure and you
file a restriction request with TRG in accordance with this Privacy Notice and
applicable law instead; and
4. if TRG no longer needs the Personal Data and you require the data to
establish, exercise or defend a legal claim.
While the processing of your Personal Data is restricted, TRG may continue to
process such data by storing it, processing it with your consent or processing
it for the establishment, exercise or defence of legal claims.
TRG will inform you if it decides to lift a restriction on processing.
If TRG has disclosed any of your Personal Data to a third party and you submit a
request to restrict processing, TRG will inform (1) you about the recipients if
you so request and (2) any such third parties of your restriction request unless
doing so is impossible or involves disproportionate efforts.
TRG will act on your restriction request in accordance with this Privacy Notice
without undue delay. Please note that, for your and TRG’s protection, TRG cannot
act on a restriction request until it verifies the identity of the person making
the request. This verification process may extend the timeframe in which TRG
acts on your restriction request.
E. Do I have a right to Personal Data portability?
Yes. You can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com. This right exists to allow you to obtain and use
your Personal Data for your own purposes across different services. Under this
right, you can move, copy or transfer your Personal Data from TRG to another
data controller.
This right applies where TRG is processing your Personal Data with your consent
or for the performance of a contract. It also applies if we process your
Personal Data by automated means. If your portability request concerns someone
other than you, TRG will have to consider whether providing or porting the
Personal Data would prejudice the other person’s or people’s rights.
Generally, TRG will respond to your portability request without undue delay and
within one month of its receipt of your request, provided that TRG may extend
this time period for up to two additional months if your request is complex or
numerous. If TRG exercises this extension of time, TRG will inform you of its
decision to exercise the extension within one month of its receipt of your
request, and will explain the reason(s) for the extension. Where technically
feasible, you may request that TRG transmit your Personal Data to another data
controller.
F. Do I have a right to object to decision been taken by automated means?
If TRG uses automated (i.e. non-human) methods to process your Personal Data to
make decisions that could potentially have a damaging legal or similarly
significant effect on you (each, an “Automated Decision”), you have the right
not to be subject to the Automated Decision. This right is inapplicable to any
Automated Decision made by TRG that is necessary for entering into or the
performance of a contract between you and TRG, is authorized by law or is based
on your explicit consent.
If TRG makes any Automated Decisions to which this right applies, TRG will
ensure that you are able to obtain human intervention, express your point of
view and obtain an explanation of the decision and challenge it.
If TRG engages in “profiling” by automated means, TRG will ensure that
appropriate safeguards are in place including (1) ensuring that the processing
is fair and transparent by providing you with meaningful information about the
logic involved and the significance and consequences of the outcome of the
decision, (2) using appropriate mathematical or statistical procedures for the
profiling, (3) implementing appropriate technical and organizational measures to
enable inaccuracies to be corrected and minimize the risk of errors and (4)
securing the Personal Data in a way that is proportionate to the risk to your
interests and rights and prevents discriminatory effects.
G. Do I have a right to have any inaccurate or incomplete Personal Data
rectified?
Yes. You can exercise this right, free of charge, by sending an email to TRG at
privacy@tenthrevolution.com.
Generally, TRG will respond to your rectification request within one month of
its receipt of your request, provided that TRG may extend this time period for
up to two additional months if your request is complex. In rare cases, TRG may
refuse to respond to your request but will explain the reason(s) for its refusal
to you within one month of its receipt of your request. If TRG so refuses, you
have the right to file a complaint with the LSA and to seek a judicial remedy.
If TRG has disclosed any of your Personal Data to a third party and you submit a
rectification request to TRG that TRG is going to honor, TRG will inform (1) you
about the recipients and (2) any such third parties of your rectification
request as well as any corrected Personal Data, unless doing so is impossible or
involves disproportionate efforts.
We will use reasonable endeavours to ensure that your Personal Data is
maintained and up to date.
H. What are my rights if the Security of my Personal Data is breached?
A breach of Personal Data (a “Breach”) means a breach of security leading to the
destruction, loss, alteration, unauthorized disclosure of, or access to, your
Personal Data for which we are responsible under applicable law.
If the Breach is likely to have a significant detrimental effect on your rights
and freedoms (such as resulting in discrimination, damage to reputation or
financial loss), TRG will notify the LSA without undue delay, and if feasible,
within one business day of TRG’s becoming aware of the Breach. TRG will assess
the determination of “significant detrimental effect” on a case by case basis.
If the Breach is likely to result in a “high risk” to your rights and freedoms,
TRG will notify you without undue delay. To be clear, the threshold requiring
TRG to notify you of a Breach is higher than the threshold requiring TRG to
notify the LSA of a Breach so it is possible that TRG will notify the LSA of a
Breach but not you. TRG will assess the determination of “high risk” on a case
by case basis.
Any Breach notice issued by TRG will contain, where possible, (1) the categories
and approximate number of individuals and Personal Data records effected by the
Breach, (2) the name and contact details of the ISM (or other TRG contact
representative if TRG does not have a ISM at the time that TRG issues the Breach
notice), (3) a description of the likely consequences of the Breach, (4) a
description of the measures that TRG has taken, and may take, to stop the Breach
and, where appropriate, to mitigate the adverse effects of the Breach and (5)
recommendations on actions you can take to protect yourself in light of the
Breach.
I. Will my Personal Data be transferred outside the EEA & Switzerland?
TRG may transfer your Personal Data to third parties described in this Privacy
Notice who are located outside of the EEA or Switzerland. If so, TRG will take
reasonable steps to ensure that your Personal Data is protected and treated in
accordance with this Privacy Notice and local applicable law. Some of the
countries outside Switzerland or EEA where your Personal Data may be transferred
will be on the EU Commission’s or Swiss Federal Data Protection and Information
Commission’s list of countries that it has deemed to have adequate security
controls in place (for this Addendum, the “Approved List”). Given the European
Court of Justice’s decision in Data Protection Commissioner v. Facebook Ireland
and Maximilian Schrems, Case C-311/18 (July 16, 2020) (“Schrems II”) as well as
the September 8, 2020 Swiss Federal Data Protection and Information
Commissioner’s Policy paper on the transfer of personal data to the USA and
other countries lacking an adequate level of data protection within the meaning
of Art. 6 Para. 1 Swiss Federal Act on Data Protection, and absent consent from
the Data Subject (or any other reason provided in GDPR Article 49(1)(b)-(f) or
Swiss law as may be amended from time to time), f TRG transfers your Personal
Data to processors (which could be external third party vendors or suppliers)
that store, transfer, process, or control your Personal Data in a country not on
the Approved List or not in Switzerland or EEA (for this Addendum, “Third
Countries”), then TRG shall determine whether each processor (and each
subprocessor that a processor has provided TRG formal notice of) can store,
transfer, process, or control the Personal Data solely within Switzerland EEA,
or a country on the Approved List.
(a) If TRG determines that the processor (and each subprocessor that a processor
has provided TRG formal notice of) can store, transfer, process, or control the
Personal Data solely within a country on the Approved List or in Switzerland or
EEA, we will require such processor (and will require the processor to require
each of its applicable subprocessors) to do so.
(b) If TRG determines that the processor (and each subprocessor that a processor
has provided TRG formal notice of) cannot store, transfer, process, or control
the Personal Data in a country on the Approved List or in Switzerland or EEA,
then:
(i) TRG will require such processor (and will require the processor to require
each of its applicable subprocessors) to be bound by the model clauses
promulgated by the European Commission as provided here (or any updated link
which the European Commission may supply from time to time) (for this Addendum,
the “Model Clauses”). When relying on the Model Clauses, TRG shall (a) monitor
the laws and regulations of Third Countries for the adequate protections of
Swiss or EEA Data Subjects as required by the GDPR or other local laws and
regulations; and (b) terminate the storage, transfer, processing , or control of
Personal Data by a processor (or a subprocessor where the process has informed
TRG of the country in which such subprocessor is processing your Personal Data)
when (i) such laws and regulations of Third Countries are incompatible with the
GDPR or other local laws and regulations, or (ii) access to Personal Data is
requested by the public authorities of Third Countries and such access is lawful
under the laws of the Third Countries but is prohibited under the GDPR or other
local laws and regulations. If the events described in III(I)(b)(i)(b)(i) or
(ii) occur, TRG will confer with the appropriate supervisory authority regarding
appropriate actions to safeguard your Personal Data.
(c) TRG shall also require the processor (and will require each processor to
require its applicable subprocessors) to determine whether each processor or
subprocessor can store, transfer, process, or control the Personal Data solely
within Switzerland, EEA, or a country on the Approved List.
1. If processor (or its applicable subprocessors) can store, transfer, process,
or control the Personal Data solely within Switzerland, EEA, or a country on the
Approved List, then TRG shall contractually require the processors (and require
processor to require its subprocessors to) do so.
2. If processor (or its applicable subprocessors) must store, transfer, process,
or control the Personal Data in a Third Country, then TRG shall require its
processors (and require processor to require its subprocessors to) to be bound
by the Model Clauses. When relying on the Model Clauses, TRG shall contractually
require such processors (and shall also require processors to require their
subprocessors) to agree to (a) monitor the laws and regulations of Third
Countries for the adequate protections of Swiss or EEA Data Subjects as required
by the GDPR or other local laws and regulations; and (b) terminate the transfer,
processing, or control of Personal Data when (i) such laws and regulations of
Third Countries are incompatible with the GDPR or other local laws and
regulations, or (ii) access to Personal Data is requested by the public
authorities of Third Countries and such access is lawful under the laws of the
Third Countries but is prohibited under the GDPR or other local laws and
regulations. If the events described in III(I)(c)(2)(b)(i) or (ii) occur with
respect to your Personal Data (and if TRG has formal notice that the events
described in III(I)(c)(2)(b)(i) or (ii) have occurred), TRG will confer with the
appropriate supervisory authority regarding appropriate actions to safeguard
your Personal Data.
Under certain circumstances, TRG may share your Personal Data with one or more
of its group companies who may be located in a Third Country. In such cases, TRG
will comply with its DPAs. The DPAs are incorporated by reference into this
Addendum.
J. How long will TRG store my Personal Data for?
We are required by law to store your Personal Data for as long as is necessary
to comply with our legal, regulatory and contractual obligations.
With respect to GDPR (and similar laws), we will store and process your Personal
Data that we obtain via: (i) your consent, until the earlier of (a) the purpose
for which we obtained such information has been fully accomplished or (b) you
inform us that you have withdrawn your consent; (ii) our legitimate interest
until the earlier of (a) your Personal data is no longer necessary for the
purpose for which it is being processed, or (b) TRG concludes that your rights
and freedoms outweigh our right to process your Personal Data; and (iii) our
necessity for the performance of a contract, until the termination or expiration
of the contract including the termination or expiration of TRG’s and your
employer’s or company’s duties or obligations that survive any such termination
or expiration.
Furthermore, we will store your Personal Data in special circumstances related
to the issuance or defense of legal proceedings, outstanding invoices or in
connection with any investigation by or of a government authority.
K. What Protections do I have if TRG transfers my Personal Data to the U.S.?
If TRG transferred any of your data to the U.S. you have the protections of the
EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework as
defined below and the Model Clauses as defined above. Frank Recruitment Group
Inc., a Delaware corporation, is TRG’s primary affiliate and operating company
in the United States (“TRG US Parent”). TRG US Parent has a subsidiary, Frank
Recruitment Group Services Inc., also a Delaware corporation (“TRGS US Sub,”
collectively with TRG US Parent, “TRG US”).
TRG US and TRG US Sub participates in the EU-U.S. Data Privacy Framework and the
Swiss-U.S. Data Privacy Framework(s) (“DPF”) as set forth by the U.S. Department
of Commerce regarding the collection, use, and retention of personal information
transferred from the European Union, EEA, and/or Switzerland, as applicable to
the United States in reliance on DPF. TRG US and TRG US Sub has certified to the
Department of Commerce that it adheres to the DPF Principles with respect to
such information. If there is any conflict between the terms in this Privacy
Notice and the DPF Principles, the DPF Principles shall govern.
To learn more about the DPF program, and to view evidence of our participation,
please visit the U.S. Department of Commerce’s Data Privacy Framework website.
This Privacy Notice only applies to Personal Data within the scope of the TRG
US’s DPF participation. TRG US’s contractual clauses for its clients are in the
United States of America Addendum below.
TRG US’s DPF participation covers Personal Data regarding:
(1) current, former, and prospective employees in connection with the employment
relationship which is covered by a separate, employee only, privacy policy that
has been made available to TRG US employees;
(2) Personal Data regarding client contacts and candidates (temp and perm), such
as the sale and delivery of recruitment services and the administration of the
client and candidate relationship; and
(3) Personal Data regarding third parties (such as service providers and
independent contractors) and their personnel and employees, in connection with
recruitment services and the provision and performance of technical professional
services to client and, where applicable, their end customers and the management
and administration of the business relationships with such third parties.
Our certifications do not cover any disclosure of an individual’s Personal Data
to a third party who processes the Personal Data for its own purposes when the
disclosure is made at the request of the individual.
TRG US disclose Personal Data to third party service providers in connection
with the operation of their respective businesses, including their provision of
services to clients and candidates. TRG US ascertain that these third party
service providers provide at least the same level of privacy protection as is
required by the DPF Principles. TRG US may be liable if both (a) third parties
fail to meet these obligations and (b) TRG US is responsible for the event
giving rise to the damage.
TRG US are subject to the investigatory and enforcement powers of the United
States Federal Trade Commission. TRG US may be required to disclose Personal
Data to law enforcement, regulatory or other government agencies, or to other
third parties, in each case to comply with legal, regulatory, or national
security obligations or requests.
Any questions or complaints concerning TRG US’s DPF participation, or requests
to access, correct, amend, delete, or limit the use or disclosure of Personal
Data (opt out) may be directed to privacy@tenthrevolution.com. If TRG US has not
been able to satisfactorily resolve the issue, then you may raise it with (1)
your data protection authority (see paragraph immediately below) or (2) the
International Centre for Dispute Resolution/American Arbitration Association
(“ICDR/AAA“) for non-HR related recourse, which can be contacted at
https://go.adr.org/dpf_irm.html. Under certain conditions, individuals may have
the possibility to engage in binding arbitration through the DPF Panel. To find
out more about individual binding arbitration, please visit U.S. Department of
Commerce’s Data Privacy Framework Annex 1.
In compliance with the DPF, TRG US commits to cooperate and comply respectively
with the advice of the panel established by the EU data protection authorities
(“SAs”) and the Swiss Federal Data Protection and Information Commissioner
(“FDPIC”) with regard to unresolved complaints concerning our handling of
personal data received in reliance on the DPF.
L. EEA residents. Should your complaint relate to TRG US’s failure to comply
with its DPF commitments and remains unresolved and you reside in the EEA, then
you should contact the SAs who act as an independent recourse mechanism to
settle all such disputes. Such complaints can be directed either to the EEA SAs
panel secretariat or individual EEA SAs.
Currently, the contact information relevant to the submission of the standard
complaint form is as follows: Commission Européenne, Directorate General
Justice, Directorate C (Fundamental Rights and Union Citizenship) of the
European Commission, Data Protection Panel, B-1049 Brussels, Belgium, Telephone:
(32-2) 299 11 11, Fax: (32-2) 298.80.94, email: ec-dppanel-secr@ec.europa.eu.
TRG’s Lead Supervisory Authority is Autoriteit Persoonsgegevens (AP) within the
Kingdom of the Netherlands and our European Union Representative is Frank
Recruitment Group Netherlands BV.
You can find the standard complaint form at
https://edps.europa.eu/data-protection/our-role-supervisor/complaints/edps-complaint-form_en.
The contact information for individual EU SAs can be found at:
http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm.
M. Swiss residents. Should your complaint relate to TRG US’s failing to comply
with our DPF commitments and remains unresolved and you reside in Switzerland,
then you should contact the FDPIC with whom TRG US has agreed to cooperate
regarding such disputes.
The contact information for the FDPIC can be found at:
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.
Under the EU-U.S. DPF, the following independent dispute resolution bodies
designated to address complaints will provide appropriate recourse free of
charge to the individual: (1) the panel established by SAs, (2) an alternative
dispute resolution provider based in the EU, or (3) an alternative dispute
resolution provider based in the United States.
Also, under the Swiss-U.S. DPF, the following independent dispute resolution
bodies designated to address complaints will provide appropriate recourse free
of charge to the individual: (1) the Commissioner of the FDPIC, (2) an
alternative dispute resolution provider based in Switzerland, or (3) an
alternative dispute resolution provider based in the United States.
SINGAPORE ADDENDUM
This Singapore Addendum shall prevail in the event of inconsistency between the
principles stated herein and those as described under the Privacy Statement.
1. Introduction To The Personal Data Protection Act 2012 as amended by the
Personal Data Protection Act Amendment 2020 (collectively, “PDPA”)
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not,
about an individual who can be identified from that data, or from that data and
other information to which an organisation has or is likely to have access.
1.2 We will collect your Personal Data in accordance with the PDPA. In general,
before we collect any Personal Data from you, we will notify you of the purposes
for which your Personal Data may be collected, used and/or disclosed, as well as
obtain your consent for the collection, use and/or disclosure of your Personal
Data for the intended purposes.
1.3 Your Personal Data may also be collected, used or disclosed if we have
assessed that to do so would be in our legitimate interests and beneficial to
the public. Before doing so, we will take steps to ensure that any adverse
effects that might arise for you have already been identified and eliminated,
reduced or mitigated.
2. Purposes For Collection, Use & Disclosure Of Personal Data
2.1 The Personal Data which we collect from you may be collected, used and/or
disclosed for the following purposes:
(a) facilitating, processing, dealing with, administering, and/or managing your
employment with TRG;
(b) processing and/or administering any consultations, negotiations, and an a
suitable placement within TRG;
(c) processing and/or administering requests for access and/or correction of
your Personal Data;
(d) processing your registration and/or participation for seminars, exhibitions,
and other events organized or co-organized by TRG;
(e) carrying out your instructions or responding to any enquiry given by (or
purported to be given by) you or on your behalf;
(f) conducting employee due diligence or other screening and personal
identification in accordance with laws, regulations or our risk management
procedures that may be required by law or that may have been put in place by us;
(g) to prevent or investigate any fraud, unlawful activity or omission or
misconduct, whether or not there is any suspicion of the aforementioned;
(h) complying with or as required by any applicable law, governmental or
regulatory requirements of any relevant jurisdiction, including meeting the
requirements to make disclosure under the requirements of any law binding on us
and/or for the purposes of any guidelines issued by regulatory or other
authorities, whether in Singapore or elsewhere, with which we are expected to
comply;
(i) complying with or as required by any request or direction of any
governmental authority, or responding to requests for information from public
agencies, ministries, statutory boards or other similar authorities. For the
avoidance of doubt, this means that we may/will disclose your Personal Data to
the aforementioned parties upon their request or direction; etc.
(collectively, the “Purposes”).
2.2 To conduct our business operations more smoothly, we may also be disclosing
the Personal Data you have provided to us to our third-party service providers,
agents and/or our affiliates or related corporations, which may be sited outside
of Singapore, for one or more of the above-stated Purposes. This is because such
third-party service providers, agents and/or affiliates or related corporations
would be processing your Personal Data on our behalf for one or more of the
above-stated Purposes.
3. Disclosure Of Your Personal Data To A Third Party
3.1 We respect the confidentiality of the Personal Data you have provided to us.
3.2 In that regard, we will not disclose any of your Personal Data to any third
parties without first obtaining your express consent permitting us to do so.
However, please note that we may disclose your Personal Data to third parties
without first obtaining your consent in certain situations, including, without
limitation, the following:
(a) cases in which the disclosure is required based on the applicable laws
and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests,
and if consent cannot be obtained in a timely way, provided that we shall, as
soon as may be practicable, notify you of the disclosure and the purposes of the
disclosure;
(c) cases in which the disclosure is necessary to respond to an emergency that
threatens the life, health or safety of yourself or another individual;
(d) cases in which there are reasonable grounds to believe that the health or
safety of yourself or another individual will be seriously affected and consent
for the disclosure of the data cannot be obtained in a timely way, provided that
we shall, as soon as may be practicable, notify you of the disclosure and the
purposes of the disclosure;
(e) cases in which the disclosure is necessary for any investigation or
proceedings;
(f) cases in which the Personal Data is disclosed to any officer of a prescribed
law enforcement agency, upon production of written authorization signed by the
head or director of that law enforcement agency or a person of a similar rank,
certifying that the Personal Data is necessary for the purposes of the functions
or duties of the officer; and/or
(g) cases in which the disclosure is to a public agency and such disclosure is
necessary in the public interest.
3.3 The instances listed above at paragraph 3.2 are not intended to be
exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse
the First and Second Schedules of the PDPA which is publicly available at
https://sso.agc.gov.sg/ .
3.4 In all other instances of disclosure of Personal Data to third parties with
your express consent, we will endeavour to provide adequate supervision over the
handling and administration of your Personal Data by such third parties, as well
as to provide for adequate forms of protection over such Personal Data.
3.5 Where Personal Data is transferred by us to any third parties outside of
Singapore, we will ensure that such transfers are compliant with the
requirements under the PDPA. In this regard, we will take such necessary
measures to ensure that such overseas recipients are bound by legally
enforceable obligations to ensure that these overseas recipients provide a
standard of protection to the Personal Data so transferred that is comparable to
the protection under the PDPA.
4. Request For Access And/Or Correction Of Your Personal Data
Access Request
4.1 An individual may request for us to provide access to Personal Data about
the individual that is in our possession or under our control as well as
information about the ways in which the Personal Data has been used or disclosed
by us within a year before the date of the request.
4.2 Unless an exception to the access request applies, we will respond to your
access request as soon as reasonably possible from the time the access request
is received. If we are unable to respond to an access request within thirty (30)
days after receiving the request, we shall inform you in writing within the
thirty (30) day period, of the reasonably soonest time in which we will respond.
Correction Request
4.3 An individual may also request for us to correct Personal Data that is in
our possession or under our control. Unless an exception to the correction
request applies, or we are satisfied on reasonable grounds that a correction
should not be made, we will endeavour to correct the Personal Data as soon as
practicable and send the corrected Personal Data to every other organisation to
which the Personal Data was disclosed by us within a year before the date the
correction was made. This is unless that other organisation does not need the
corrected Personal Data for any legal or business purpose.
4.4 Where we are unable to respond to a correction request within thirty (30)
days after receiving the request, we shall inform you in writing within the
thirty (30) day period, of the reasonably soonest time in which we will respond.
4.5 You may submit your access or correction request to the contact details
listed at paragraph 7.2 of this Singapore Addendum.
5. Request To Withdraw Consent
5.1 You may withdraw your consent for the collection, use and/or disclosure of
your Personal Data in our possession or under our control at any time by
submitting your request to the contact details listed at paragraph 7.2 of this
Singapore Addendum.
5.2 We will process your request as soon as practicable such a request for
withdrawal of consent being made, and will thereafter refrain from collecting,
using and/or disclosing your Personal Data in the manner stated in your request.
6. Administration And Management Of Personal Data
6.1 We will take appropriate measures to keep your Personal Data accurate,
complete and updated.
6.2 We will also take commercially reasonable efforts to take appropriate
precautions and preventive measures to ensure that your Personal Data is
adequately protected and secured. Appropriate security arrangements will be
taken to prevent any unauthorized access, collection, use, disclosure, copying,
modification, leakage, loss, damage and/or alteration of your Personal Data.
However, we cannot assume responsibility for any unauthorized use of your
Personal Data by third parties which are wholly attributable to factors beyond
our control.
6.3 We will also take commercially reasonably efforts to ensure that the
Personal Data in our possession or under our control is destroyed and/or
anonymized as soon as it is reasonable to assume that (i) the purpose for which
that Personal Data was collected is no longer being served by the retention of
such Personal Data; and (ii) retention is no longer necessary for any other
legal or business purposes.
7. Complaint Process
7.1 If you have any complaint or grievance regarding about how we are handling
your Personal Data or about how we are complying with the PDPA, we welcome you
to contact us with your complaint or grievance.
7.2 The contact details of Tenth Revolution Group’s Chief Privacy Officer
(“CPO”) are:
Frank Recruitment Group Services Limited
The St. Nicholas Building
St. Nicholas Street
Newcastle-Upon-Tyne
Tyne & Wear UK NE1 1RF
Attn: Chief Privacy Officer
Email: privacy@tenthrevolution.com
7.3 Where it is an email or a letter through which you are submitting a
complaint, your indication at the subject header that it is a PDPA complaint
would assist us in attending to your complaint speedily by passing it on to the
relevant department within TRG to handle. For example, you could insert the
subject header as “PDPA Complaint”.
7.4 We will certainly strive to deal with any complaint or grievance that you
may have speedily and fairly.
UNITED STATES OF AMERICA ADDENDUM
I. If you would like a copy of TRG’s US comprehensive information security
program, please email TRG’s CPO at privacy@tenthrevolution.com.
If TRG receives a “Do Not Track” signal or request from a web browser, TRG will
not honor such request or signal. TRG has taken this position in part to provide
you with a personalized and efficient experience on the Websites.
As discussed in this Privacy Notice, there are third parties who conduct
tracking on the Websites.
Information about web beacons used by TRG and third parties with whom it
contracts can be found in Section XII.F of the Privacy Notice above.
II. For information on TRG US’s compliance with the UK Extension, EU-U.S. and
Swiss-U.S. Data Privacy Frameworks, see the sections titled “What Protections do
I have if TRG transfers my Personal Data to the U.S.?” in the United Kingdom
Addendum and the European Economic Area and Switzerland Addendum above.
Additionally, U.S. law requires certain contracts entered into by TRG US contain
the rights, obligations and requirements set forth in Sections II(A) through
II(C) inclusive below (collectively, the “DPF Terms”). Accordingly, the
following DPF Terms, to which TRG reserves the right to revise from time to time
without notice, shall be incorporated by reference where these DPF Terms are
required in client contracts:
(A). In the event TRG US transfers to client or any of its affiliates, or
provides client or any of its affiliates with access to any Personal Data (as
defined for this Section II below) of European Union or Switzerland residents,
including employees of TRG or its affiliates and actual or prospective TRG
clients contacts or candidates, and client maintains, receives, has access to,
stores, uses or processes such Personal Data in the United States, client shall
comply with data protection, data security and confidentiality requirements at
least as strong as those set forth in the DPF Principles issued by the U.S.
Department of Commerce, as revised from time to time (collectively, the
“Principles”) During the term of such contracts and while client creates,
receives, maintains, stores, uses, processes or disseminates any Personal Data,
client shall:
1. use the Personal Data only for the specific and limited purposes intended in
the client contract including for recruitment purposes;
2. provide immediate written notice to either TRG US Parent or TRG US Sub as
applicable if (a) client determines that it can no longer meet its obligation to
provide the same level of protection of the Personal Data as is required by the
Principles, and in such case client shall cease processing the Personal Data or
(b) client becomes aware of any accidental or unlawful destruction of, or
accidental loss or alternation of or unauthorized disclosure or access to, any
Personal Data (a “Breach”) which notice shall include a description of the
quantity of Personal Data subject to the Breach, the approximate length and
duration of the Breach, the data subjects whose Personal Data was subject to the
Breach and a Breach remediation plan;
3. at its cost, employ its best efforts to stop, limit and remediate the Breach,
perform a “root cause” analysis of the Breach, employ its best efforts to
prevent the same or a similar Breach from reoccurring and keep TRG up to date on
all its efforts under this subsection II(A)(3);
4. implement appropriate technical and organizational measures to protect
Personal Data against a Breach;
5. not transfer any Personal Data to third parties without the data subject’s
prior written or email consent (which either TRG US Parent or TRG US Sub as
applicable shall attempt to obtain after receiving notice from client of its
need to transfer Personal Data to a third party);
6. assist TRG US in responding to data subjects exercising their rights under
the Principles;
7. act only on instructions from TRG US; and
8. either have in place an independent recourse mechanism to handle data subject
complaints that complies with the requirements of the Principles or make
available an equivalent mechanism.
(B) Upon the termination or expiration of the applicable client contract, client
shall, at TRG US’s option, return all Personal Data to either TRG US Parent or
TRG US Sub as applicable or permanently destroy all Personal Data (and all
copies and derivative works thereof) in its care, custody or control except for
any Personal Data that applicable law, if any, requires client to maintain
(“Archival Personal Data”). With respect to any Archival Personal Data, client’s
obligations and requirements under this Section II shall remain in full force
and effect for as long as such Archival Personal Data remains in client’s care,
custody or control.
(C) If client forwards or gives access to any of the Personal Data to any third
party at any time, including any subprocessor or controller of client, client
shall ensure that its written contract with such third party contains the Data
Privacy Framework Terms.
(D) For purposes of this Section II, the term “Personal Data” shall have the
same meaning ascribed to that term as in the Principles which can be found at
the EU-U.S. Data Privacy Framework as revised from time to time.
Generally, TRG voluntarily extends the same protections for residents of US
states that have comprehensive data privacy laws (including without limitation
California, Colorado, Connecticut, Iowa, Utah, and Virginia) to those residents
in US states without such laws. To the extent you reside in either, the
following disclosures may apply to you:
CALIFORNIA CONSUMER PRIVACY ACT, CALIFORNIA PRIVACY RIGHTS ACT, COLORADO PRIVACY
ACT, CONNECTICUT ACT CONCERNING PERSONAL DATA PRIVACY AND ONLINE MONITORING,
IOWA CONSUMER DATA PROTECTION ACT, UTAH CONSUMER PRIVACY ACT, AND THE VIRGINIA
CONSUMER DATA PROTECTION ACT DISCLOSURES
Our goal is to enable individuals and organizations to comply as easily as
possible with the California Consumer Privacy Act, California Privacy Rights
Act, Colorado Privacy Act, Connecticut Act Concerning Personal Data Privacy and
Online Monitoring, Iowa Consumer Data Protection Act, Utah Consumer Privacy Act,
and the Virginia Consumer Data Protection Act Disclosures (all collectively, the
“US State Data Privacy Laws”) requirement to protect the privacy and data of
consumers. As a recruitment service, we respect and protect your privacy and
security and are committed to following best practices to support this
principle.
Thanks for using TRG. Our goal is to enable individuals and organizations to
comply as easily as possible with the US State Data Privacy Laws’ requirement to
protect the privacy and data of consumers. As a recruitment service, we respect
and protect your privacy and security and are committed to following best
practices to support this principle.
We – meaning Tenth Revolution Group, which is a trademark and brand owned by
Frank Recruitment Group Services Limited and its subsidiaries, including without
limitation, Nigel Frank International Limited, Mason Frank International
Limited, Frank Recruitment Group UK Services Limited, Frank Recruitment Group
Services USA Ltd., Frank Recruitment Group Inc., Frank Recruitment Group
Services Inc., Frank Recruitment Group Private Limited (Singapore), Frank
Consulting Services Private Limited (Singapore), Frank Recruitment Group Pty
Limited (Australia; also registered in New Zealand), Frank Recruitment Group
GmbH (Germany), Frank Recruitment Group K.K. (Japan), Frank Recruitment Group Sp
Zo.o. (Poland), Frank Recruitment Group Netherlands BV (Netherlands), Frank
Recruitment Group S.L. (Spain), Frank Consulting Services S.L. (Spain), Frank
Recruitment Group Sarl (Switzerland), Frank Recruitment Group Inc. /Groupe de
Recrutement Frank Inc. (Canada), Frank Consulting Services SAS (France), Frank
Recruitment Group SRL (Italy), Tenth Revolution Consulting Services SRL (Italy)
and businesses operated by our group under the brand names including Frank
Recruitment Group (TRG), Nigel Frank, Mason Frank, Nelson Frank, Jefferson
Frank, Revolent, Tenth Revolution Group, Anderson Frank, Washington Frank, TRG
Technology Consulting, Digital Revolution Awards, and Dynamic Jobs
(collectively, “we,” “us,” “our,” or “TRG”) – prepared this Privacy Addendum to
help you understand our practices regarding the collection, use, and disclosure
of information we collect from you through Revolent’s web applications, our
websites that link to this Privacy Addendum, and any other services we provide
to our customers (collectively, “Services”).
By accessing or using the Services, you agree to this Privacy Addendum, our Do
Not Sell Notice, Privacy Notice, the Terms of Use.
I. Information from Children
TRG is not directed to children under the age of 13 and we do not knowingly
collect personally identifiable information from children under the age of 13.
If we learn that we have collected personally identifiable information of a
child under the age 13, we will take reasonable steps to delete such information
from our files as soon as is practicable. Please contact us at
privacy@tenthrevolution.com, fill the webform here, or give us a call at
1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 717 if you believe we
have any information from or about a child under the age of 13.
II. US State Data Privacy Law Disclosures
The US State Data Privacy Laws, require businesses subject to this law to
provide consumers residing in California, Colorado, Connecticut, Iowa, Utah, and
Virginia (“US State Data Privacy Law Consumer”) with certain rights regarding
their personal information and sensitive personal information.
At this time, we may sell or share your personal information, and depending on
the circumstances, your sensitive personal information, so the opt-out or opt-in
choices may apply. For more information, visit
www.tenthrevolution.com/legal/california-do-not-sell-my-personal-information/
Here’s a summary of rights for US State Data Privacy Law Consumers under the US
State Data Privacy Laws:
A. Your Right to Opt Out. You have the right to tell businesses that do sell or
share your personal information or sensitive personal information to third
parties (i.e. us) not to sell or share it at any time. Businesses that sell or
share your personal information or sensitive personal information to third
parties must also ensure that the third parties do not resell or reshare it
unless the business notified you explicitly and provided you with a chance to
opt out of resales. These opt-out rights apply to businesses that do not know
your age, or know you are older than 16. Additionally, we must also respect opt
outs made by your authorized agent if such authorized agent provides signed
written permission from you to do so.
B. Your Right to Opt In. If a business has actual knowledge that you are between
ages 13 and 16 (e.g., based information the business collects), businesses
cannot sell or share or allow resales or reshares of your personal information
or sensitive personal information without your affirmative authorization. If a
business has actual knowledge that you are younger than 13, it may not sell or
share, or allow resales or reshares of your personal information or sensitive
personal information without your parent or guardian’s affirmative
authorization. This is your right to opt in.
C. Your Right to Disclosures. You have the right to know:
1. A link to TRG’s “Do Not Sell My Personal Information” notice.
a) Please visit
www.tenthrevolution.com/legal/california-do-not-sell-my-personal-information/
2. A description of a consumer’s rights pursuant to US State Data Privacy Laws,
including CCPA Section 1798.120:
(a) Your Right to Opt Out. If you’re a US State Data Privacy Law Consumerand we
sell or share your information to third parties, you can tell us at any time not
to sell or share your personal information or sensitive personal information.
This right to opt-out applies if we do not know your age or if we know you are
older than age 16. Additionally, we must also respect opt outs made by your
authorized agent if such authorized agent provides signed written permission
from you to do so.
(b) Your Right to Opt In. If we have actual knowledge that you are between ages
13 and 16 (e.g., based information we collect, or because someone informed us),
we will never sell or share your personal information without your affirmative
authorization. If we have actual knowledge that you are younger than 13, we will
never sell or share your personal information or sensitive personal information
without your parent or guardian’s affirmative authorization. This is your right
to opt in.
(c) Do We Sell or Share Your Personal Information? At this time, we may sell or
share your personal information or sensitive personal information and you can
opt out at any time. If you opt out, or for children 16 and younger, if you have
not opted in, we will not sell or share your personal information or sensitive
personal information to third parties unless you expressly authorize us to do
so.
3. A description of a consumer’s rights pursuant to US State Data Privacy Laws,
including CCPA Section 1798.110: US State Data Privacy Law Consumers have the
right to request that we disclose to you:
(a) The categories of personal information it has collected about you.
(b) “Personal information” is information that identifies or relates to a
particular consumer or household including name, postal address, email address,
IP address, social security number, personal property records, purchasing
histories, biometric information, internet activity such as browsing or search
history, geolocation data, employment information, sensitive personal
information, education information and inferences drawn from this information,
in so far as it is not publicly available information. In addition to the above
types of personal information that we may collect, TRG may collect personal
information such as:
(i) Name;
(ii) Contact details e.g. street address, email address, telephone number;
(iii) Work Experience;
(iv) Job Title;
(v) Professional Certifications;
(vi) Education & Qualifications;
(vii) Skills;
(viii) Career History;
(ix) Salary Range;
(x) Right to work status/citizenship;
(xi) Other information relevant to help us provide technology talent creation
services;
(xii) References from past employers; and
(xiii) IP address.
(c) “Sensitive personal information” means: nonpublic personal information that
reveals:
(i) A consumer’s social security, driver’s license, state identification card,
or passport number;
(ii) A consumer’s account log-in, financial account, debit card, or credit card
number in combination with any required security or access code, password, or
credentials allowing access to an account;
(iii) A consumer’s precise geolocation;
(iv) A consumer’s racial or ethnic origin, religious or philosophical beliefs,
or union membership;
(v) The contents of a consumer’s mail, email, and text messages unless the
business is the intended recipient of the communication;
(vi) A consumer’s genetic data;
(vii) The processing of biometric information for the purpose of uniquely
identifying a consumer; and
(viii) Personal information collected and analyzed concerning a consumer’s
health; and
(ix) Personal information collected and analyzed concerning a consumer’s sex
life or sexual orientation.
4. The categories of third parties with whom the business shares personal
information and/or sensitive personal information.
(a) All users of the websites and/or our services
(i) To third parties where we have retained them to provide services that we or
you have requested or that TRG clients have requested including references,
qualifications and background reference checking services and to verify the
details you have provided from third party sources.
(ii) To third parties to provide data storage, CV/resume parsing, data cleansing
and marketing services to TRG where such third parties have agreed to maintain
the confidentiality of, and to protect, your personal information and/or
sensitive personal information in accordance with applicable law.
(iii) To third parties to assist with credit control and payment management.
(iv) To third parties, regulatory or law enforcement agencies if we believe in
good faith that we are required by law to disclose it in connection with the
detection of crime, the collection of taxes or duties, in order to comply with
any applicable law or order of a court of competent jurisdiction, in connection
with legal proceedings or other similar cause or circumstance.
(v) To TRG affiliates, whose locations can be found at
https://www.tenthrevolution.com/contact . These entities will process your
personal information and/or sensitive personal information in accordance with
the Privacy Addendum.
(vi) In the event of a sale, merger, liquidation, receivership or transfer of
all or substantially all of the assets, or a controlling interest in the equity,
of TRG (or any of its group companies) provided that such counterparty(ies) to
any such transaction agrees to adhere to the terms of the Privacy Addendum (or a
similar document) and applicable law.
(b) Actual or Prospective TRG Clients
(i) To TRG clients in order for them to determine if you are or may be qualified
to fill a vacancy.
(ii) To third parties that you authorize us to send your personal information
and/or sensitive personal information to such as your CV
(iii) To third parties to determine if an TRG client or other entity (or their
respective affiliates) to whom TRG presented you has (a) employed you or (b)
retained you or any entity (i) that employed you or (ii) that retained you or
(iii) in which you have an financial interest.
(c) Individuals who work for TRG clients (i.e. a client contact)
(i) To Contacts in the course of providing your company or employer with
recruiting services and to further the recruitment process.
(ii) To third parties where we have retained them to provide services that you
have requested including Freelancer skill tests and other testing.
(iii) To third parties to determine if an TRG client or other entity (or their
respective affiliates) to whom TRG presented a candidate has (a) employed the
candidate or (b) retained the candidate or any entity (i) that employed the
candidate or (ii) that retained the candidate or (iii) in which the candidate
has a financial interest.
5. The categories of sources from which the personal information and/or
sensitive personal information is collected.
(i) We collect personal information and/or sensitive personal information from
you actively when you enter it into our services (e.g., your name, your
CV/resume, etc.).
(ii) We collect personal information or sensitive personal information passively
when you access our services, to the extent your web browser provides this
information to our servers (e.g., your operating system) and also based on your
service usage (e.g., when and from what IP address you log on to our services,
which may reveal your precise geolocation).
(iii) We collect personal information when it is provided to us by either
yourself or a third party (for example, LinkedIn, Jobboard, CV databases, etc.).
6. The business or commercial purpose for collecting, selling, or sharing
personal information and/or sensitive personal information.
(a) Why do we process your personal information and/or sensitive personal
information?
(i) Generally, we use your personal information and/or sensitive personal
information for our business and activities, and in our efforts to expand and
improve our business. Examples include:
1. All users of the Websites and/or our services
(a) To provide our technology talent creation services to you, your employer or
your company;
(b) To facilitate the recruitment process, including but not limited to:
(i) Qualifying and submitting Candidates;
(ii) For clients, negotiating TRG terms of business;
(iii) Arranging interviews and obtaining feedback;
(iv) Negotiating compensation packages; and
(v) Providing post placement follow up.
(c) Where permitted by applicable law and unless you tell us otherwise, we (or a
third party to whom we have provided your Personal Data under part VI below of
this Privacy Notice) may send you emails, SMS messages, or text messages
(standard SMS or text message rates may apply);
(d) To assess data about you against vacancies which we judge may be suitable
for you;
(e) To third party vendors to assist us in hosting, managing and operating our
websites;
(f) To third party vendors who provide data analysis and data updating services
to us;
(g) To third party vendors who provide email and other communications related
services to us
(h) To enable you to submit your CV/resume to TRG, apply online (including
through the Websites) for jobs or to subscribe to alerts about jobs we think may
be of interest to you;
(i) To enable us to develop and market other products and services and where you
have consented to being contacted for such purposes;
(j) To improve our customer service and to make our services more valuable to
you (including tailoring the Websites when you log on to enrich your personal
online experience);
(k) To send you electronically or by post surveys, reports, TRG event details,
promotions, offers, networking and client events and general information about
relevant industry sectors which we think might be of interest to you, where you
have consented to being contacted for such purposes (and we will provide you
with an opportunity to opt out);
(l) To identify you, and respond to and process your requests for information
and provide you with a product or service;
(m) To amend records to remove personal information and/or sensitive personal
information;
(n) To use your information on an anonymized basis to monitor compliance with
our equal opportunities policy, other TRG policies and any legal or compliance
requirements;
(o) To use your information on an anonymized basis to create marketing materials
such as a salary survey; and
(p) To carry out our obligations arising from any contracts entered into between
you and us, and for other everyday business purposes that involve use of
personal information and/or sensitive personal information.
2. Actual or Prospective Candidates
(a) To help find you a job;
(b) To contact you about jobs that TRG is filling or may fill for TRG clients;
(c) To provide you or your company with information about the job market;
(d) To communicate with you (permanent hire candidates), your employer or your
company (contract candidates) after you or it has started a job to make sure all
is going well or to remedy, or attempt to remedy, any problems;
(e) To answer any questions you have about a job or the job market;
(f) To fulfill any aspect of your Employment Agreement or Contract of Employment
with TRG;
(i) To third party vendors who provide customer relationship management database
services to us;
(ii) To third party vendors who provide data analysis and data updating services
to us
(iii) To third party vendors who provide document execution, transmission and
storage services to us
(iv) To third party vendors who provide email and other communications related
services to us
(g) To collect any money due, or allegedly due, to TRG or any TRG client (or
TRG’s client’s client);
(h) To obtain or inquire about any property (including computers and
confidential business information) owned, or allegedly owned, by TRG or any TRG
client (or TRG’s client’s client);
(i) To determine if an TRG client or other entity (or their respective
affiliates) to whom TRG presented you has (a) employed you or (b) retained you
or any entity (i) that employed you or (ii) that retained you or (iii) in which
you have an financial interest;
(j) To establish, exercise or defend any legal claims; and\
(k) To assist you (permanent hire candidates), your employer or your company
(contract candidates) if you are dissatisfied or dislike the job, or any aspect
of it.
3. Individuals who work for TRG clients (i.e. a “client contact”)
(a) To fill an open vacancy at your company or employer;
(b) To contact you about candidates for jobs with whom TRG has a relationship;
(c) To provide you with information about the job market;
(i) To third party vendors who provide customer relationship management database
services to us;
(ii) To third party vendors who provide data analysis and data updating services
to us;
(iii) To third party vendors who provide document execution, transmission and
storage services to us;
(iv) To third party vendors who provide email and other communications related
services to us;
(d) To communicate with you after your company or employer has hired/retained an
TRG candidate to make sure all is going well and to remedy, or attempt to
remedy, any problems;
(e) To negotiate and fulfil any aspect of your company’s or employer’s contract
with TRG Group;
(f) To answer any questions you have about a job or a candidate or your
company’s or employer’s contract with TRG;
(g) To resolve any issue with the issuance, payment, collection or enforcement
of an TRG invoice;
(h) To collect any property owned by TRG or any TRG candidate;
(i) To third parties to determine if a TRG client or other entity (or their
respective affiliates) to whom TRG presented a candidate has (a) employed the
candidate or (b) retained the candidate or any entity (i) that employed the
candidate or (ii) that retained the candidate or (iii) in which the candidate
has a financial interest; and
(J) To establish, exercise or defend any legal claims.
7. The specific pieces of personal information and/or sensitive personal
information it has collected about that consumer.
(a) Please email us at privacy@tenthrevolution.com, fill out the webform here,
or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code
717 to request this information. Before we can respond to your request, we’ll
need to verify your identity.
8. A description of a consumer’s rights pursuant to US State Data Privacy Laws,
including CCPA Section 1798.115:
(a) If we sell or share your personal information and/or sensitive personal
information or disclose it for a business purpose, you have the right to know:
(i) The categories of personal information or sensitive personal information
that the business collected about the consumer.
(aa) See Section 3 4) above (e.g., web log data, registration data, resume/CV
data, etc.).
(ii) The categories of personal information and/or sensitive personal
information that the business sold about the consumer and the categories of
third parties to whom the personal information and/or sensitive personal
information was sold, by category or categories of personal information for each
third party to whom the personal information and/or sensitive personal
information was sold or shared.
(aa) See Sections 3 4), 3 5) and 3 6) above.
(iii) The categories of personal information that the business disclosed about
the consumer for a business purpose.
(aa) See Section 3 6) above.
(b) If we sell or share your personal information or disclose it for a business
purpose, you have the right to request that we disclose to you (1) the
categories of personal information and/or sensitive personal information that we
collected about you, (2) the categories of personal information and/or sensitive
personal information we sold or shared about you and the categories of third
parties to whom we sold it, by category of personal information and/or sensitive
personal information for each third party to whom we sold or shared your
personal information and/or sensitive personal information and (3) the
categories of personal information and/or sensitive personal information that
the business disclosed about the consumer for a business purpose. We are
required to verify your identity before providing you with this information if
the information would constitute your personal information and/or sensitive
personal information.
To exercise these important rights, please: mail us at
privacy@tenthrevolution.com or call us toll free at 1-866-I-OPT-OUT
(1-866-467-8688) and enter Service Code 717 to request this information. Before
we can respond to your request, we’ll need to verify your identity.
(c) If we sell or share your personal information and/or sensitive personal
information to a third party or disclose it for a business purpose, we are
required to disclose:
(i) The category or categories of consumers’ personal information and/or
sensitive personal information we sold or shared, or if we have not sold or
share your personal information and/or sensitive personal information, we shall
disclose that fact.
(aa) If we sell or share your personal information and/or sensitive personal
information, it will be in the form of your CV/resume, anonymized or
pseudonymized.
(ii) The category or categories of consumers’ personal information and/or
sensitive personal information it has disclosed for a business purpose, or if
the business has not disclosed the consumers’ personal information or sensitive
personal information for a business purpose, it shall disclose that fact.
(aa) We rely on vendors to operate our infrastructure, and accordingly for each
category of personal information and/or sensitive personal information that we
disclosed above as a category that we collect, we disclose it to one of our
third-party vendors for a business purpose (i.e. to develop, market, provide and
support our business services). Those categories are: web log data, registration
data, payment data, service usage data, customer content, consumer content and
marketing data.
(d) If we sell or share your personal information and/or sensitive personal
information to a third party, it is not allowed to resell or reshare it unless
we notified you explicitly and provided you with a chance to opt out.
(aa) We do not allow third parties to whom we sell or share your personal
information and/or sensitive personal information to resell or reshare the
personal information and/or sensitive personal information, so no opt-out
choices apply. See https://www.tenthrevolution.com/privacy-notice/#ccpa for
details.
9. A description of a consumer’s rights pursuant to US State Data Privacy Laws,
including CCPA Section 1798.125:
(a) Businesses, including us, may not discriminate against you because you
exercised any of your consumer privacy rights such as by: (1) denying you goods
or services; (2) charging you different prices or rates for goods or services,
including via discounts or other benefits or penalties; (3) providing you a
different level or quality of goods or services or (4) suggesting that you will
receive a different price or rate for goods or services or a different level or
quality of goods or services. Businesses may however discriminate where any
difference is reasonably related to the value provided to you by your data.
(b) Businesses, including us, may offer you financial incentives, including
payments as compensation, for the collection, sale or deletion of your personal
information and/or sensitive personal information. If we offer any incentives we
will (1) notify you about them in our privacy policy and in any
California-specific descriptions of consumer privacy rights we post and (2) only
enroll you in them with you opt-in consent after disclosing all material
incentive program terms to you. Incentive programs may never be unjust,
unreasonable, coercive, or usurious.
(i) We do not currently offer any financial incentives.
10. A description of a consumer’s rights pursuant to US State Data Privacy Laws,
including CCPA Section 1798.105:
(a) You have the right to request that we delete any personal information and/or
sensitive personal information about you that we have collected. Before we
delete any information, we’ll need to verify your identity. If we delete your
information, we’ll also instruct our vendors (aka service providers) to delete
it. The US State Data Privacy Laws do not obligate us to delete information
under all circumstances, including where we need the information to provide our
services to you, to detect security incidents, to identify errors in our
services, or to comply with legal obligations. If you request that we delete
information, we’ll let you know if we are deleting it or if we are not deleting
it based on exemptions provided by the applicable US State Data Privacy Laws.
11. One or more designated methods for submitting requests (at minimum, a
toll-free telephone number):
(a) You may submit any consumer privacy requests by emailing us at
privacy@tenthrevolution.com, fill out the webform below, or by calling us toll
free at 1-866-I-OPT-OUT (1-866-467-8688) and entering Service Code 717. Before
we can respond to your request, we’ll need to verify your identity.
III. Your Right to Data Deletion. You have the right to request that we delete
any personal information and/or sensitive personal information about you that we
have collected. Before we delete any information, we’ll need to verify your
identity. If we delete your information, we’ll also instruct our vendors (aka
service providers) to delete it. The US State Data Privacy Laws do not obligate
us to delete information under all circumstances, including where we need the
information to provide our services to you, to detect security incidents, to
identify errors in our services, or to comply with legal obligations. If you
request that we delete information, we’ll let you know if we are deleting it or
if we are not deleting it based on exemptions provided by the US State Data
Privacy Laws. You may also delete personal information and/or sensitive personal
information by using our services dashboard as described above.
IV. Your Anti-Discrimination Rights. Businesses may not discriminate against you
exercising any of your consumer privacy rights such as by: (1) denying you goods
or services; (2) charging you different prices or rates for goods or services,
including via discounts or other benefits or penalties; (3) providing you a
different level or quality of goods or services or (4) suggesting that you will
receive a different price or rate for goods or services or a different level or
quality of goods or services. Businesses may however discriminate where any
difference is reasonably related to the value provided to you by your data. We
will not discriminate against you in any way for exercising your privacy rights.
V. Your Rights Regarding Financial Incentives. Businesses may offer you
financial incentives, including payments as compensation for the collection,
sale or deletion of your personal information and/or sensitive personal
information. In this case a business must: (1) notify you about the incentives
in its Privacy Addendum and in any California-specific descriptions of consumer
privacy rights it posts and (2) only enroll you in them only with your opt-in
consent after disclosing all material incentive program terms. Incentive
programs may never be unjust, unreasonable, coercive, or usurious. We do not
currently offer any financial incentives.
VI. Designated methods for submitting requests. We offer three ways to express
your privacy preferences: the following interactive web form, our email at
privacy@tenthrevolution.com, and the toll free phone number below (You may use
the webform below even if you are not a California resident).
Show/Hide privacy manager.
Privacy Request Manager
OPTION 1: SUBMIT A WEB FORM REQUEST
First Name: Last Name: Email: State of Residence: Other Alabama Alaska Arizona
Arkansas California Colorado Connecticut Delaware District Of Columbia Florida
Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine
Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska
Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota
Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota
Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming
I am a: Customer Employee Job Applicant Vendor Ad/Email Recipient Other Tell me
more about the data you collect, share and/or sell Do not sell or share my
personal information (if applicable) Delete my personal information Send me a
copy of my personal information Correct my personal information Opt me out of
automated decision making (if applicable) Limit the use of my sensitive personal
information (if applicable) Other:
By clicking "Affirm & Submit" you affirm the information above is accurate and
acknowledge that we may need to verify your identity and your state of residence
to determine if we can fulfill your request. Error: Please complete all form
fields, check at least one request box and solve the Captcha to submit. You have
successfully submitted your request.
OPTION 2: CALL TOLL FREE
Or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code
717#.
PRIVACY REQUEST MANAGEMENT BY CCPATOLLFREE.COM
VII. Changes to Privacy Addendum
Any information that we collect is subject to the Privacy Addendum in effect at
the time such information is collected. We may, however, revise the Privacy
Addendum from time to time. If a revision is material, as determined solely by
us, we will notify you, for example via email. The current version will always
be posted to our Privacy Addendum.
If you have any questions about this Privacy Addendum, or wish to exercise any
of your privacy rights, please contact us at privacy@tenthrevolution.com or at
any of the methods described above.
AUSTRALIA AND NEW ZEALAND ADDENDUM
I. For users accessing the Websites or using our services in Australia or New
Zealand, we comply with Australian and New Zealand privacy requirements
including for Australia: the Privacy Act 1988 (Cth), Privacy Principles, the
Spam Act 2003 (Cth) and Regulations 2021, and the Do Not Call Register Act 2006
(Cth); for New Zealand, the Privacy Act 2020, the Privacy Regulations 2020,
Information Privacy Principles, and Unsolicited Electronic Messages Act 2007;
and for Australia and New Zealand, any other applicable state/territory privacy
laws or industry codes (collectively, the “AUSNZ Privacy Laws”).
II. We will deal with your Personal Data (which has the same meaning as
“Personal Information” under the AUSNZ Privacy Laws in accordance with those
laws, namely any information from which your identity is apparent or can be
reasonably ascertained.
III. Residents of Australia or New Zealand accessing and using the Websites or
services are notified that:
A. in addition to your respective countries, your Personal Data will be held
and/or processed overseas including in the United States, Canada, United
Kingdom, Netherlands, Germany, France, Switzerland, Italy, Spain, Japan or
Singapore where our offices are located and other countries in which we may open
offices in the future. We may also disclose your personal information to others,
like our consultants, agents, contractors and service providers, and those that
act as data processors, auditors or external advisers, and may be held and
processed in other countries including without limitation those listed at the
beginning of this subsection “A”;
B. If we use your Personal Data to contact you and you would prefer us not to,
or if you indicate a preference for a method of communication, please let us
know and we will do our best to respect your preference. When your choice is to
continue to deal with us, we take it that you agree to and consent to us using
your Personal Information in these ways, providing we follow the system and
approach we explain in this Privacy Notice and comply with the applicable law.
Where we do not have your Personal Information, we are not able to contact you,
process your requests or provide our services to you; and
C. the governing law for the purposes of the Terms of Use and Privacy Notice,
and any matters relating to them, including all disputes, will be governed, for
Australia by the laws of New South Wales, Australia, and for New Zealand, for
the law of New Zealand. You unconditionally submit to the non-exclusive
jurisdiction of the courts having jurisdiction there.
IV. You may wish to contact us to request access to your Personal Information,
to seek to correct it or to make a complaint about privacy. Our contact details
for Australia and New Zealand are set out below:
Frank Recruitment Group Pty Ltd
Level 18
120 Spencer Street
Melbourne, Victoria 3000
Australia
Email: privacy@tenthrevolution.com
We will respond to your request for access to Personal Information we hold about
you as soon as we reasonably can, including if we are unable to provide you with
access (such as when we no longer hold the information).
We do not impose any charge for a request for access, but we may charge you a
reasonable fee for our costs associated with providing you with access and
retrieval costs.
For complaints about privacy, we will establish in consultation with you a
reasonable process, including timeframes, for seeking to resolve your complaint.
CANADA ADDENDUM
I. Introduction
This Canada Addendum (“Canada Addendum”), in addition to the forgoing Privacy
Notice, sets out the basis on which all “Personal Information” (“Personal
Information” means information about an identifiable individual, including but
not limited to sensitive Personal Information), that Frank Recruitment Group
Inc. / Group de Recruitement Frank Inc. and its affiliated entities and their
respective representatives trading under the TRG brand (collectively for the
purposes of this Canada Addendum, “TRG,” “we,” “our,” or “us”) collects from
you, or that you provide to us via the Websites (as defined elsewhere in the
Privacy Notice) will be processed by us in Canada. If there is a conflict
between the Privacy Notice and this Canada Addendum, the Canada Addendum
controls with respect to Canadian users of our Websites. Please read the
following carefully to understand our views and practices regarding your
Personal Information in Canada and how we will treat it. All capitalized/defined
terms not defined herein are defined elsewhere in the Privacy Notice.
II. Canadian Privacy Law and Privacy Principles
TRG is committed to maintaining the confidentiality, security, and accuracy of
your Personal Information in accordance with applicable Canadian federal and
provincial law, including but not limited to the Canadian Personal Information
Protection and Electronic Documents Act (“PIPEDA”), Canada’s Anti-Spam
Legislation, SC 2010 c 23 (“CASL”), and the data privacy laws of Canada’s
provincial counterparts including but not limited to the British Columbia
Personal Information Protection Act, SBC 2003 c 63 (“BC PIPA”), Alberta Personal
Information Protection Act, SA 2003 c P-6.5 (“AB PIPA”), and Quebec Act
respecting the Protection of Personal Information in the Private Sector, CQLR c
P-39.1 (“Quebec Private Sector Act”) to govern our activities as they relate to
the use of your Personal Information. As part of this commitment, we follow the
ten privacy principals established under the PIPEDA. These principals are as
follows:
• Principle One: Accountability
TRG is responsible for the Personal Information it controls. TRG has designated
its Chief Privacy Officer (privacy@tenthrevolution.com) as responsible and
accountable for compliance with the Canadian Privacy Principles and other
applicable Canadian data privacy law.
• Principle Two: Identifying Purpose
TRG must identify the purposes for which Personal Information is used,
collected, and disclosed before or at the time we collect Personal Information.
TRG demonstrates its compliance by making the Privacy Notice and this Canada
Addendum available to individuals, among other actions.
• Principle Three: Consent
Your knowledge and consent are required for the collection, use or disclosure of
your Personal Information, except where inappropriate or permitted by Canadian
law. Depending on the level of sensitivity of the Personal Information, this
consent may be implied or expressed; however, wherever commercially feasible,
TRG shall attempt to obtain express consent. Consent to our use of your Personal
Information can be withdrawn at any time by sending an email requesting same to
privacy@tenthrevolution.com.
• Principle Four: Limited Collection
TRG must collect Personal Information by fair and lawful means and limit its
collection of Personal Information to those details reasonably necessary for the
purposes identified. Accordingly, TRG does not collect your race, ethnicity, or
health Personal Information nor do we use Canadian Social Insurance Numbers (or
a foreign equivalent) to identify or organize the information we hold, and will
not record it if you submit it.
• Principle Five: Limiting Use, Disclosure and Retention
We may only use or disclose Personal Information for the purpose for which it
was collected unless you have otherwise consented, or when it is required or
permitted by law. We may only retain your Personal Information for the period of
time required to fulfill the purpose for which it was collected (taking into
account our statutory and contractual obligations to retain information).
• Principle Six: Accuracy
We shall maintain your Personal Information in as complete, accurate and
up-to-date form as is necessary to fulfill the purpose for which we are to use
it. Please inform us if any of your information changes by contacting us at
privacy@tenthrevolution.com so that we can make any necessary changes.
• Principle Seven: Safeguarding Information
We must protect your Personal Information by following security safeguards that
are appropriate to the sensitivity level of the Personal Information. For
example, we have a document minimization process in our office to prevent
inadvertent disclosures of your Personal Information. We also physically lock
our offices after business hours to avoid/prevent unauthorized access.
• Principle Eight: Openness
We are required to make information available to you that is specific and
easy-to-understand concerning TRG’s policies and practices that apply to the
management of your Personal Information. A key method of making such information
available is via this Canada Addendum, via our website.
• Principle Nine: Access
Upon request to privacy@tenthrevolution.com, we shall inform you of the use,
disclosure, and existence of your Personal Information, and shall give you
access to it. You may verify the completeness and accuracy of your Personal
Information, and may request amendments to your Personal Information for these
reasons, if appropriate. Contact us at the email address above. We will attempt
to respond to requests for summary information within 30 days of receipt. If you
send us a more detailed request (typically these require archival or other
retrieval costs), we may take longer to respond and you may be subject to our
normal disbursement and professional fees to the highest extent permitted by
applicable law.
• Principle Ten: Challenging Compliance
Direct any complaints, suggestions, enquiries or questions respecting our
privacy practices, compliance, or these principles by contacting
privacy@tenthrevolution.com.
III. May We Deny Access To Your Personal Information?
Your right to access your Personal Information is not absolute. We may deny
access to your Personal Information when:
• required by applicable law;
• such Personal Information relates to existing or anticipated legal proceedings
against you or was generated as a result of a dispute resolution mechanism
(whether arbitration, mediation, court cases, or similar proceedings);
• when granting you access would have an unreasonable impact on other people’s
privacy, security or proprietary information;
• to protect our rights and property; or
• where the request is frivolous or vexatious or generates costs which are
prohibitively expensive.
We shall explain to you in writing why we deny a request for access to, or
refuse a request to correct your Personal Information.
IV. How To Ask A Question Or File A Complaint
TRG has a Chief Privacy Officer who may be contacted to answer any comments or
questions about this Canada Addendum, including where to file a complaint.
Please forward your communications to:
E-mail: privacy@tenthrevolution.com
Telephone: +44 20 733 0865
Address:
Frank Recruitment Group Inc. / Group de Recruitement Frank Inc.
d/b/a FRG
The St. Nicholas Building
St. Nicholas Street
Newcastle-Upon-Tyne
Tyne & Wear U.K. NE1 1RF
Attn: Chief Privacy Officer
Attention: Chief Privacy Officer
V. Sending Us Information Over The Internet
With respect to CASL, by using our Websites or Services, you hereby expressly
consent to receiving, during and after our business relationship, electronic
messages from TRG, including via emails and through social media, providing
information to you including newsletters, updates, alerts, other publications,
news and communications, other information of interest to you and/or information
on our services. You can withdraw this consent or modify your preferences as to
the types of electronic messages which you wish to receive from us, at any time,
simply by notifying us at privacy@tenthrevolution.com or by using the
unsubscribe mechanism on any of our electronic messages.
VI. Location of Personal Information and Transfers of Personal Information
Outside Canada
Your Personal Information is stored on various servers, including our own, and
those maintained by our third party service providers who help us provide our
services to you. These servers may be located outside of Canada. Accordingly, by
providing us Your Personal information, you explicitly consent to our transfer
of your Personal Information to countries outside of Canada. If you do not wish
for your Personal Data to be transferred outside of Canada, do not provide your
Personal Information to us. You have rights to access and rectification of your
Personal Information, among other rights, which you may invoke as otherwise
described in this Canada Addendum or this Privacy Notice. When we transfer your
Personal Information outside of Canada, we take commercially reasonable and
legally required measures with data importers as is reasonably necessary for the
protection of such Personal Information, which may include entering into
contractual clauses or data protection/security agreements as appropriate. As
required by the Quebec Private Sector Act, in general, our server is located in
the United Kingdom; our customer relationship database provider keeps its main
server in Germany and its disaster recovery server in United Kingdom; our word
processing and office program, email, and cloud storage provider has its main
servers in the United Kingdom and the European Union; and another cloud storage
provider has its main server in Ireland. For more details about your specific
Personal Information and where it is located, please contact
privacy@tenthrevolution.com.
VII. What If I Do Not Agree With This Canada Addendum?
Please do not submit any Personal Information to us if you do not agree to our
processing of your Personal Information as described herein in this Canada
Addendum.
VIII. Changes to this Canada Addendum
We reserve the right to change this Canada Addendum and Privacy Notice from time
to time by updating this Canada Addendum on our website or updating the Privacy
Notice as described above. Any changes to this Canada Addendum and Privacy
Notice will be posted on this Website so you are always aware of what
information we collect, how we use it, and under what circumstances, if any, we
disclose it. We encourage you to check this Website frequently for updates. Your
continued use of this Website or any TRG services shall constitute your
acceptance of the revised Canada Addendum.
TRG will interpret and enforce this Canada Addendum in accordance with all
applicable law. This Canada Addendum was last updated on July 16, 2021.
JAPAN ADDENDUM
Frank Recruitment Group
株式会社（以下「当社」といいます）は、個人情報保護法および当社の個人情報保護体制に則り、登録者の個人情報の適切な管理に努めます。
Frank Recruitment Group K.K (hereinafter referred to as “TRG“) will endeavor to
properly manage the handling of personal information of registrants based on the
Act on the Protection of Personal Information and the Company’s personal
information protection framework.
ここでいう個人情報とは、当社に提供する個人（以下「本人」という）に関する情報で、氏名、住所、生年月日、電話番号、メールアドレス、その他の記述の組み合わせにより本人を特定できる情報をいいます。
Personal information is the information of the individual (hereinafter referred
to as “person”) provided to and, which is the information received by the person
who entered the name, entry, date of birth, telephone number, email address, and
other versions.
個人情報の収集・利用目的
皆さまからお預かりした個人情報は、以下の目的にのみ利用いたします。
Purpose of collection and use of personal information
Personal information entrusted to you will be used only for the following
purposes.
1. 人材派遣又は有料職業紹介等における最適な仕事のご案内・仕事に関するご連絡、及び契約締結に関する業務。
Guidance on optimal work in contract or perm, contact for introduce job details
and work related to contract conclusion.
2. 提供していただいた本人の個人情報は、就職や転職のために、第三者である求人企業に提供するため。
To provide the personal information of the person provided to a third-party to
company for applied to company.
3. 当社のサービス向上を目的として、意見、要望、情報の提供をお願いするために、個人情報を利用する場合。
We may use personal information to request opinions, requests, and information
for the purpose of improving our service.
上記以外の目的で利用する場合は、事前にお知らせし同意を得たうえで利用いたします。
If we use it for purposes other than the above, we will inform you in advance
and obtain your consent before using it.
個人情報の利用、提供について
About the use and provision of personal information
当社は収集目的の範囲内で個人情報を委託する場合があります。
We may entrust personal information within the scope of the purpose of
collection.
また、以下の場合を除き、本人の同意を得ずに第三者に提供をすることはいたしません。
In addition, except in the following cases, we will not provide it to a third
party without the consent of the person.
・ 人の生命、身体又は財産の保護のために必要がある場合であり、本人の同意を得ることが困難な時。
・ 公衆衛生の向上又は児童の健全な育成の推進のために特に必要のある場合であり、本人の同意を得ることが困難な時。
・
国の機関若しくは地方公共団体又はその委託を受けた者が法令の定める事務を遂行することに対して協力する必要があり、本人の同意を得ることにより当該事務の遂行に支障を及ぼすおれがある時。
・ 法令に基づく場合。
・ 合併その他の事由による事業の承継に伴って個人情報の提供が必要な場合。
・ When it is necessary to protect the life, body or property of a person and it
is difficult to obtain the consent of the person.
・ When it is particularly necessary to improve public health or promote the
sound development of children, and it is difficult to obtain the consent of the
person.
・ It is necessary for a national institution or a local public body or a person
entrusted with it to cooperate in carrying out the affairs stipulated by laws
and regulations, and obtaining the consent of the person will hinder the
performance of the affairs. At one point.
・ When required by law.
・ When it is necessary to provide personal information due to business
succession due to merger or other reasons.
個人情報の取り扱いについて
Handling of personal information
ご提供いただいた個人情報は、適切に取り扱います。
またご本人は、当社に個人情報を提供することは任意ですが、もしご提供をいただけなかった場合は、当社はご登録やサービスをお断りする場合がございます。
We will handle the personal information you provide appropriately.
In addition, the person is voluntary to provide personal information to us, but
if we do not provide it, we may refuse registration or service.
個人情報に関する苦情・相談 に関する苦情・相談及び開示等の請求について
及び開示等の請求についてお預かりした個人情報に関する苦情・相談につきましては、速やかに対応させていただきます。
Complaints about personal information / complaints about consultations /
requests for consultations and disclosures, etc. and requests for disclosures,
etc. We will promptly respond to complaints / consultations regarding personal
information that we have received.
お預かりした個人情報につきまして、利用目的の通知、開示、訂正、追加、削除、利用停止をご希望の場合は、ご本人であることを確認させていただいた上で速やかに対応いたします。
If you wish to notify, disclose, correct, add, delete, or suspend the use of
your personal information, we will promptly respond after confirming your
identity.
お気軽にお問い合わせください
Please feel free to contact us on:
Tenth Revolution Group株式会社への個人情報に関するお問い合わせ窓口
TEL：03-4571-1146
E メール privacy@tenthrevolution.com
※本同意書の効力、適用、解釈にあたっては、日本国法が適用されるものとします。
制定日 2024年04月03日
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