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PRIVACY POLICY




PRIVACY POLICY

YOUR PRIVACY IS IMPORTANT TO US

Apex Systems (“the Company”, “we”, “our” or “us”) is committed to protecting the
privacy and security of your personal information. This Privacy Policy describes
how the Company may collect, use, disclose, and safeguard personal information
that we may collect about you through our websites, and via offline means such
as during interactions with our corporate suppliers and customers, via trade
shows or other offline interactions, where applicable. This Privacy Policy also
tells you about your rights and choices with respect to your personal
information, and how you can reach us to exercise your rights and get answers to
your questions.  Our privacy practices with respect to personal information
about our employees and contractors, past and present, are addressed through
other internal company policies and procedures, and are outside the scope of
this Policy.

 1.  Information We Collect About You
 2.  How We Collect Your Personal Information
 3.  How We Use Your Personal Information
 4.  Disclosures of Your Personal Information
 5.  Disclosures of Your Personal Information
 6.  Data Security
 7.  Retention Period
 8.  Your Rights in Relation to Your Personal Information
 9.  Other Important Information
 10. California Information Sharing Disclosure
 11. Contact Us

1. Information We Collect About You
We collect, maintain, and use different types of personal information in the
context of our relationship or potential relationship with you. The following
provides examples of the type of information that we collect from you and how we
use the information.

Context Categories of Information Primary Purpose for Collection and Use of
Information Commercial Information We collect basic identifying information such
as your name, title, employer, and contact information such as your work and/or
personal email address, and telephone numbers (including your mobile number). We
have a legitimate interest in communicating with our clients concerning normal
business administration such as projects, services, and billing.  We have a
legitimate interest in fulfilling our contract with you for the provision of
services. Client Information  We collect the name, and contact information, of
our clients and their employees with whom we may interact.   We have a
legitimate interest in contacting our clients and communicating with them
concerning normal business administration such as projects, services, and
billing. Cookies and First Party Tracking We use cookies and web beacons, clear
GIF, pixels, internet tags, and other similar tracking technologies
(collectively “tracking technologies”) to monitor how you interact with our
websites. This may include which links you click on, information that you type
into our online forms, or identifying information about your device or browser.
For more information relating to the use of such tools, review the “Cookie and
Similar Tracking Technologies” section below. We have a legitimate interest in
making our website operate efficiently, providing account related
functionalities, understanding how you interact with our websites to better
improve them, and maintaining security standards. We also have a legitimate
interest in detecting and preventing fraud. Cookies and Third Party Tracking We
collect information about your internet or other network activity including your
device identifier, Internet Protocol (IP) address, mobile ad identifier, or
similar unique identifiers, so that we can provide advertising about products
and services tailored to your interests on our websites, or on other websites.
For more information relating to the use of such tools, review the “Cookie and
Similar Tracking Technologies” section below. We have a legitimate interest in
engaging in behavior-based advertising. CCTV Recording and Photographs Your
image which may be recorded on CCTV or by our sign in system when you visit our
premises.  We have a legitimate interest in protecting our customers, our
premises, assets, and business partners from crime. We operate CCTV security and
sign in systems in a number of our premises and parking lots which record images
for security. Email Interconnectivity If you receive email from us, we use
certain tools to capture data related to when you open or interact with our
messages. We have a legitimate interest in understanding how you interact with
our communications to you. Feedback/Support If you provide us feedback or
contact us for support we will collect your name and e-mail address, as well as
any other content that you send to us, in order to reply. We have a legitimate
interest in receiving, and acting upon, your feedback or issues. Mailing List
When you sign up for one of our mailing lists we collect basic identifying and
contact information such as your name, email address or postal address. We have
a legitimate interest in identifying unique visitors, and in understanding how
users interact with us on their mobile devices. Mobile Devices We may collect
information from your mobile device such as unique identifying information
broadcast from your device when visiting our websites. We have a legitimate
interest in identifying unique visitors, and in understanding how users interact
with us on their mobile devices. Supplier Relationship Management We collect
certain contact and related business information (name, email address,
professional contact information) when you or your organization provides us with
certain products or services. In some instances, we may collect certain
background or screening information to the extent needed and in accordance with
applicable law. We have a legitimate interest in administering our relationship
with our suppliers and performing our contract with your organization. We also
use such information to administer and maintain our relationship with your
organization. Social Media Information We may collect, as a result of using
third party social media plugins, widgets, or other tools, information related
to your social media usage as it relates to our websites.  We have a legitimate
interest in sharing our social media pages with you.   
  Web Logs We collect information, including your browser type, operating
system, Internet Protocol (IP) address, domain name, click-activity, referring
website, and/or a date/time stamp for visitors. We have a legitimate interest in
monitoring our networks and the visitors to our websites.
 

 

2. How We Collect Your Personal Information
We collect your personal information in the following ways, pursuant to
applicable law: 

Directly From You, when you apply for our services, attend trade shows and
industry events, engage with our websites, transact business with us, register
for an account, contact us, respond to a survey, sign up to receive emails,
and/or postal mailings.  If you provide us a mobile phone number, you agree to
receive text messages from the Company. Text messages may be sent to notify you
of a position or keep you updated on activities relevant to your application
process, which may include reminders.

Through Our Use of Cookies and Other Automatic Data Collection Technologies,
when you visit our websites, open or click on emails we send you, or interact
with our advertisements. We or third parties we work with automatically collect
certain information using technologies such as cookies, web beacons, clear GIF,
pixels, internet tags, web server logs, and other data collection tools.

Through On Premise and Other Offline Technologies.  In some cases, we record
customer service calls for quality assurance. We also use Closed Circuit
Television or CCTV in our locations for safety, security, fraud, loss
prevention, and operational purposes. 

From Third Parties, including business partners, our affiliates, data analytics
providers, third parties that we have partnered with for marketing or other
purposes, or other publicly available sources. 

3. How We Use Your Personal Information
In addition to the purposes and uses described above, we use your personal
information for the following purposes:

 * To provide services to your business or employer;
 * To respond to inquiries related to support, employment opportunities, or
   other requests;
 * To send marketing and promotional materials, including information relating
   to our services;
 * To comply with laws or regulations to which the Company is subject;
 * To comply with our contractual obligations;
 * To conduct research and analytics related to our websites and services,
   including combining any or all of the information that we collect or obtain;
 * To detect and prevent fraud or crime;
 * To enforce, exercise, or defend legal claims;
 * To detect, investigate, prevent, or take action regarding possible malicious,
   deceptive, fraudulent, or illegal activity, including fraudulent
   transactions, attempts to manipulate or violate our policies, procedures, and
   terms and conditions, security incidents, and harm to the rights, property,
   or safety of us and our customers, employees, or others; and
 * For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your
information, in many situations we have more than one purpose. Our collection
and processing of your information is based in different contexts upon your
consent, our need to perform a contract, our obligations under law, and/or our
general interest in conducting our business. Note that this Privacy Policy may
be updated to notify you of additional purposes for which we process your
personal information.

4. Disclosures of Your Personal Information
In addition to the specific situations discussed elsewhere in this policy, we
may disclose your personal information in the following situations:

 * Affiliates. We may disclose information to our corporate affiliates (e.g.,
   parent company, sister companies, subsidiaries, joint ventures, or other
   companies under common control) in the course of our normal business
   operations. 
 * Business Transactions. If another company acquires, or plans to acquire, any
   part of our company, business, or our assets, or similar corporate
   restructuring activities, we will also disclose information to that company,
   including at the negotiation stage.
 * Legal or Regulatory Requests and Investigations. We may disclose information
   in response to subpoenas, warrants, or court orders, or in connection with
   any legal process, or to comply with relevant laws or regulations. We may
   also need to disclose your personal information with tax authorities, courts,
   regulators, the police and other governmental authorities where we are
   required or permitted to do so by law. 
 * Other Disclosures with Your Consent. We may ask to disclose your information
   to other unaffiliated third parties who are not described elsewhere in this
   Privacy Policy.
 * Protection of the Company or Others. We may disclose your information in
   order to establish or exercise our rights, to defend against a legal claim,
   to investigate, prevent, or take action regarding possible illegal
   activities, suspected fraud, safety of person or property, or a violation of
   our policies.
 * Third-Party Service Providers. We may disclose your information with service
   providers. Among other things, service providers may help us to administer
   our website, provide technical support, and assist in the fulfillment of
   services.
 * De-identified Personal Information. We may disclose or use aggregated or
   de-identified data for any lawful purpose. De-identified information is
   generally not considered to be Personal Information under applicable laws.

5. Data Security
No method of transmission over the Internet, or method of electronic storage, is
fully secure.  While we maintain reasonable physical, technical and procedural
safeguards that are designed to protect your personal information against
unauthorized access, use, or disclosure, we cannot guarantee the security of
your personal information. In the event that we are required by law to inform
you of any privacy or security event relating to your personal information we
may notify you electronically, in writing, or by telephone, if permitted to do
so by law.

Some of our websites may permit you to create an account.  When you do you will
be prompted to create a password. You are responsible for maintaining the
confidentiality of your password, and you are responsible for any access to or
use of your account by someone else that has obtained your password, whether or
not such access or use has been authorized by you.  You should notify us of any
unauthorized use of your password or account by using one of the methods listed
below under “Contact Information.”

6. Retention Period
We retain information about you and your relationship with us for as long as is
needed to fulfill our legitimate business purposes outlined in this Policy. The
specific periods for which we keep information about you vary depending on the
nature of the information, why we need it, and whether the personal information
is de-identified. We also consider the minimum necessary retention period
prescribed by applicable laws, recommended by industry standards, and stated in
contracts and other legal obligations.

7. Your Rights in Relation to Your Personal Information
Depending on your location, you may have the following rights with regard to
your personal information:

 * Notification of Employment Opportunities. You may choose to provide us with
   your email address for the purpose of allowing us to send employment or
   candidate opportunities to you. You can stop receiving these emails by
   following the unsubscribe instructions in e-mails that you receive. If you
   decide not to receive these emails, we may still send you service related
   communications.
 * Request access to your personal information. You have the right to request
   access to personal information we hold about you. Specifically, you have the
   right to request access to information about the categories of personal
   information concerned and categories of recipients to whom the personal
   information has been or will be disclosed, and the sources from which we
   receive that personal information among other information. You generally have
   the right to receive this personal information, in a structured, commonly
   used, and machine-readable format so you can transmit this personal
   information to another entity.
 * Request correction or deletion of your personal information. You may request
   that we correct your personal information that is inaccurate or incomplete or
   delete your personal information. There may be instances where applicable law
   or regulatory requirements allow or require us to refuse a deletion request.
   For example, we may keep your personal information as needed to comply with
   our legal obligations, resolve disputes, and/or enforce any of our
   agreements.
 * Revocation Of Consent.  If you revoke your consent for the processing of
   personal information then we may no longer be able to provide you services.
   In some cases, we may limit or deny your request to revoke consent if the law
   permits or requires us to do so, or if we are unable to adequately verify
   your identity. You may revoke consent to processing (where such processing is
   based upon consent) by contacting us at the address described below.
 * Opt-Out of the Sale or Sharing of Personal Information. Subject to certain
   exceptions, California residents have the right to opt out of the
   "sale"/”sharing” of their personal information. It may be considered a
   “sale”/”sharing” of personal information under California law when we use
   services that help deliver our ads to you and may transfer personal
   information to business partners for their use. Making personal information
   (such as online/device identifiers, browsing activity, or geolocation)
   available to these third parties may be considered a “share” under California
   law. To opt out of the "sale"/”sharing” of your personal information as just
   described, please click the “Do Not Sell/Share My Personal Information” link
   at the bottom of our website
 * Automated Processing: We do not use any technology that makes a significant
   decision based solely on automated processing (i.e., without human
   intervention).  In the event we begin to use such technology, you have the
   right to object to that automated processing unless that decision is required
   or authorized by law.
 * Portability. You may have a right to ask us to provide your personal
   information to a third party.
 * Online Tracking. Some web browsers incorporate a “Do Not Track” (DNT) or
   similar feature that signals to websites that a visitor does not want to have
   his/her online activity and behavior tracked. Not all browsers offer a DNT
   option and there is currently no industry consensus for how to recognize or
   respond to a DNT signal. For these reasons, we do not currently respond to
   DNT signals. We will endeavor to recognize commercially recognized opt out
   signals (e.g., Global Privacy Control). Recognition of this signal will only
   take place with respect to the device and/or browser that communicates the
   signal.
 * Right of Non-Discrimination/Retaliation: We do not discriminate against
   individuals who exercise any of their rights described in this Privacy
   Policy, nor do we retaliate against individuals who exercise these rights
 * Right to Restrict Use of your Sensitive Personal Information. You may have
   the right to request the restriction of processing of your sensitive personal
   information in certain instances.  At the current time, however, we do not
   use or disclose sensitive personal information for purposes other than those
   described in this Policy and these uses cannot be limited under applicable
   law.
 * SMS/Text Messages. If you provide us a mobile phone number, you will receive
   a single text message from us to confirm your enrollment in SMS/text
   messaging. You will not be enrolled to receive SMS unless you confirm. By
   consenting, you certify, warrant and represent that the telephone number you
   provided to us is your contact number and understand that consent is not a
   condition to apply for a job. Text messages will be sent to notify you of a
   position or keep you updated on activities relevant to your application
   process, which may include reminders.  You can opt out of SMS or text
   messages by sending ‘STOP’, ‘END’, ‘CANCEL’, ‘UNSUBSCRIBE’, or ‘QUIT’ to the
   number you receive the message from.  Once you confirm, you will receive a
   ‘STOP’ confirmation reply.  You agree that SMS or text messages may be
   delivered using an automatic texting system. As always, message and data
   rates may apply for any SMS or text messages sent to you from us. We do not
   claim or guarantee availability or performance of the SMS service, including
   liability for transmission delays or message failures. 

If you choose to assert any of these rights under applicable law, we will
respond within the time period prescribed by such law. Please note that many of
the above rights are subject to exceptions and limitations. Your rights and our
responses will vary based on the circumstances of the request. 

A person authorized to act on your behalf may make a verifiable request related
to your personal information. If you designate an authorized person to submit
requests to exercise certain privacy rights on your behalf, we will require
verification that you provided the authorized agent permission to make a request
on your behalf. 

Your verifiable request must: (i) provide sufficient information that allows us
to reasonably verify that you are the person about whom we collected personal
information or an authorized representative of that person; and (ii) describe
the request with sufficient detail that allows us to properly understand,
evaluate, and respond to it. We will only use personal information provided in a
verifiable consumer request to verify the requestor’s identity or authority to
make the request.

If you would like to exercise any of the above rights (to the extent these
rights are provided to you by law), you may:

 1. Call us at 1-800-536-1390; or
 2. In the U.S., submit your request online HERE.
 3. Outside of the U.S., submit your request online HERE.

8. Other Important Information
The following additional information relates to our privacy practices:

 * Transmission Of Information To Other Countries. As a multi-national company
   we transmit information between and among our affiliates.  As a result your
   information may be processed in a foreign country where privacy laws may be
   less stringent than the laws in your country.  Nonetheless, where possible we
   take steps to treat personal information using the same privacy principles
   that apply pursuant to the law of the country in which we first received your
   information. Specifically, we use European Union Model Clauses (“Model
   Clauses”) also known as Standard Contractual Clauses, to meet the adequacy
   and security requirements for data transferred from the EEA, Switzerland and
   the UK and for other international transfers of personal information as
   relevant.  By submitting your personal information to us you agree to the
   transfer, storage and processing of your information in a country other than
   your country of residence including, but not necessarily limited to, the
   United States.  If you would like more information concerning our attempts to
   apply the privacy principles applicable in one jurisdiction to data when it
   goes to another jurisdiction you can contact us using the contact information
   below.
 * Third Party Applications/Websites.  We have no control over the privacy
   practices of websites or applications that we do not own. 
 * Changes To This Privacy Policy. We may change our privacy policy and
   practices over time. To the extent that our policy changes in a material way,
   the policy that was in place at the time that you submitted personal
   information to us will generally govern that information unless we receive
   your consent to the new privacy policy. Our privacy policy includes an
   “effective” and “last updated” date. The effective date refers to the date
   that the current version took effect. The last updated date refers to the
   date that the current version was last substantively modified.
 * Minors. This site is not intended for use by children under the age of 13,
   and we do not knowingly collect or use any personal information from such
   children.
 * Information for California Residents.  If you would like more information
   concerning the categories of personal information (if any) we disclose to
   third parties or affiliates for those parties to use for direct marketing
   please submit a written request to us using the information in the "Contact
   Information" section below.

Contact Information.  If you have any questions about this Privacy Policy,
please us contact us at MyPrivacy@apexsystems.com. If you are a resident of the
UK or the European Union, please contact us at MyPrivacyGDPR@apexsystems.com. If
you are not satisfied with our response, and are in the European Union, you may
have a right to lodge a complaint with your local supervisory authority.

Last Revised: January 1, 2023.


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Suite 200

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Apex Systems is an equal opportunity employer. We do not discriminate or allow
discrimination on the basis of race, color, religion, creed, sex (including
pregnancy, childbirth, breastfeeding, or related medical conditions), age,
sexual orientation, gender identity, national origin, ancestry, citizenship,
genetic information, registered domestic partner status, marital status,
disability, status as a crime victim, protected veteran status, political
affiliation, union membership, or any other characteristic protected by law.
Apex will consider qualified applicants with criminal histories in a manner
consistent with the requirements of applicable law. If you have visited our
website in search of information on employment opportunities or to apply for a
position, and you require an accommodation in using our website for a search or
application, please contact our Employee Services Department at
employeeservices@apexsystems.com (Do not submit resumes or solicit consultants
to this email address). UnitedHealthcare creates and publishes the Transparency
in Coverage Machine-Readable Files on behalf of Apex Systems.


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