Effective April 8, 2020
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Phenom People participates in and has certified its compliance with the EU-U.S. and the Swiss-U.S. Privacy Shield Framework. Phenom People is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
Phenom People is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Phenom People complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Phenom People is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Phenom People may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
About Phenom People and the information Phenom People collects
Your PII collected by Phenom People
The opt-in subscribe form collects PII that you voluntarily choose to share with Phenom People, such as your name, email address, and phone number. You may always choose not to provide such PII; however, this may limit Phenom People ability to provide you with a specific service or particular content.
PII used by Phenom People clients
Phenom People works with employers and other companies (“Clients”) to provide the Phenom People Service. Information about your use of the Service and visits to the Site may be used by Phenom People and Clients. Your PII is only shared with the specific Client for which you visited and to which you subscribed.
When you download and use your Services, we will automatically collect information on the type of device you use, operating system version and the device identifier (or “UDID”).
We collect your location-based information for the purpose of matching your job search criteria. If you no longer wish to allow us to track your location-based information within the platform you may turn this off at the device level, however you will no longer be able to use parts of our service if you do so.
Information related to data collected for our clients
Phenom People collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contact by one of our Clients that user our service, please contact the Client that you interact with directly. We may transfer PII to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Access and retention of data controlled by our clients
Phenom People acknowledges that you have the right to access your personal information. Phenom People has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Phenom People’s Client (the data controller). If the Client requests Phenom People to remove the data, we will respond to their request within 30 days.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Phenom People will retain and use this PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
As is true of most web sites and apps, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically collected data to PII.
We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browsers “help” file.
We set a persistent cookie to store your password, so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our site.
If you reject cookies, you may still use our site, but your ability to use some areas of our site, will be limited. For example, you cannot register for the Talent Community to receive future email alerts when jobs of interest to you become available.
Third party cookies and other tracking technologies
Our third-party partners employ images and scripts, that help them better manage content on our site. They do not tie the information gathered to our user’s PII.
Third Parties, with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity, use Flash cookies to collect and store information.
Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here: http://www.macromedia.com/support/ documentation/en/flashplayer/help/settings_manager.html
We use Local Storage, such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
We partner with a third party to track candidate movement through the career site. This is not for advertisement.
Use of PII by Phenom People
Use of your PII by Phenom People clients
Clients (contracted employers) using Phenom People Services to attract job seekers may receive or access your PII in conjunction with their use of the Services. You may at any time choose to opt out of receiving further communication from Phenom People. However, even if Phenom People blocks further use of your contact information, Phenom People cannot prevent employers who have obtained previously your PII from Phenom People from contacting you directly. Phenom People recommends contacting the employer directly if you wish to opt out of further communication.
We use your information to match you with our Clients, allow you to request a demo, complete a job application, and to contact you regarding any inquiries you have.
Disclosure of your PII, Phenom People communications content, data and information
We will share your PII with third parties only in the ways that are described in this privacy statement. We do not sell your PII to third parties.
We may provide your PII to companies that provide services to help us with our business activities such as resume parsing, sending emails or SMS text messages through the platform, live help feature or offering customer service. These companies are authorized to use your PII only as necessary to provide these services to us.
We may provide your PII
- as required by law, such as to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and to comply with a subpoena, or similar legal process
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
- if Phenom People Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your PII, as well as any choices you may have regarding your PII, to any other third party with your prior consent to do so.
Also, certain technical processing of messages and their content may be required to: (1) send and receive messages; (2) conform to connecting networks’ technical requirements; (3) conform to the limitations of the Service; or (4) conform to other similar requirements.
This Site has industry standard security measures in place to protect the loss, misuse and integrity of the information under Phenom People control. Although Phenom People makes good faith efforts to store the information collected by the Service in a secure operating environment that is not available to the public, Phenom People cannot guarantee complete security. You acknowledge that you provide your PII at your own risk.
The security of the PII collected is of the utmost importance to Phenom People. Phenom People takes all commercially reasonable steps to secure your PII. Reasonable physical, electronic, and managerial procedures to safeguard the information we collect has been implemented and is updated periodically as deemed necessary by Phenom People. With this in mind, Phenom People limits access to PII to only those employees and contractors who need access in order to perform their duties.
When you enter sensitive information or personal information within our platform, we encrypt the transmission of that information using secure socket layer technology (SSL).
If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Social media (features) and widgets
Facebook connect or other open ID provider
You can log in to our platform using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities within our platform to your profile page to share with others within your network.
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
Compromise of PII
Other websites or links
This Website contains links to other websites. Phenom People is not responsible for the privacy practices or the content of such websites.
You may elect not to receive future communications from Phenom People. If you are a registered User, please open the email you received from Phenom People and click on the unsubscribe link. If you prefer to have your account removed permanently, please email your request to email@example.com.
Use limitation disclosure
Phenom People will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Phenom People will provide individuals with reasonable mechanisms to exercise their choices.
Access to PII
If your PII changes or if you no longer desire our service, you may correct, delete inaccuracies, or modify it by emailing us at firstname.lastname@example.org. We will respond to your access request within 30 days.
We will retain your information (including geo-location data) for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We collect your phone number in order to allow users of our platform to send SMS messages to candidates. These messages include individual messaging (such as that between a recruiter and a candidate regarding an individual position or general questions about the company), or campaigns such as new job alerts, career fair promotions and job application status updates.
SMS Code Terms of Service
1. When you opt-in to the service, we will send you an SMS message to confirm your signup.
2. You can cancel the SMS service at any time. Just text "STOP" to 39522. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us.
If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.
3. If at any time you forget what keywords are supported, just text "HELP" to 39522. After you send the SMS message "HELP" to us, we will respond with instructions on how to use our service as well as how to unsubscribe.
We are able to deliver messages to the following mobile phone carriers:
Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile.
Minor Carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless).
5. As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive no more than one message per day per campaign. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
For all questions about the services provided by this short code, you can send an email to firstname.lastname@example.org.
Part 2: Applicable Only to Users Located in California and Nevada
Privacy Notice for CA and NV residents
If you are a California or Nevada resident you have certain rights related to the collection, use and disclosure of your personal information under the California Consumer Privacy Act of 2018 (“CCPA”) and Nevada 220. “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
Collection, Use, and Disclosure of PI
As previously stated in our privacy statement, we may hold data on you in our role as a service provider to a client company, and we may hold data about you on our own behalf. We collect, use and disclose the following personal information as identified under each category of personal information, for business purposes identified and with the third parties identified below:
Identifiers: Name, postal address, online identifier, internet protocol address, email address, phone number.
Commercial information. Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information. Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
Audio and Video: If you visit our facilities that employ CCTV, we may capture your likeness on video as you pass through secured areas.
Professional or employment-related information: Resume information if you apply for a job with us, and your current job role and employer if you work for a company doing business with us.
Education information: Resume information if you apply for a job with us.
Sources of Personal Information
We have collected the above categories and types of personal information directly from individuals through our website or during customer support contact, directly from our business customers, and through business documents such as our contracts and other shared documents.
Use of Personal Information
We may use your personal information for the following business purposes: provide service to our business customers, fulfill your requests, conduct business together, protect our legal interests, abide by our legal obligations, protect the security of our systems and facilities, analyze our business and web site performance, and market to you (with your consent).
Disclosure of Personal Information
We may disclose your personal information with third parties for a business purpose. These third parties include analytics providers and other service providers under contract to us. These service providers are prohibited from using your personal information except at our direction. We may also disclose your personal information to government entities or other third parties associated with legal or tax requirements, or in the case of a merger or acquisition.
Sale of Personal Information
We have not sold the personal information of CA or NV residents in the preceding twelve months. We do not sell the personal information of minors under the age of 16 years of age. This fact notwithstanding, you can opt out of data sale by emailing a request to that effect to: email@example.com.
Your Rights as a California Resident
If you are a California resident you may have some or all of the rights described below with respect to the personal information we have collected, sold or disclosed about you as a consumer. If you wish to exercise these rights pertaining to personal information we may hold on you as a service provider to a client company, please direct your request(s) to that company. To exercise your rights pertaining to personal information we may hold on our own behalf, please see the section below regarding how to make any of the requests identified below.
Right to Know and Right to Request Information
You may have the right to request that we disclose what personal information we collect, use, disclose or sell. You have the right to request information about the personal information we’ve collected about you within the last twelve months. You may request to know if we have collected, sold or shared with third parties for a business purpose the following information:
- The categories of personal information we have collected about you;
- The categories of sources of personal information we collected about you;
- Our business or commercial purpose for collecting or selling personal information about you;
- The categories of third parties with whom we share personal information;
- The specific pieces of personal information we have collected about you;
- Whether we have sold your personal information and if so the categories of personal information that each category of recipient purchased; and
- Whether we have disclosed your personal information for a business purpose and if so, the categories of personal information that each category of recipient received.
You may request this information no more than two times per year.
Right to Request Deletion
You have the right to request that we delete your personal information Under certain circumstances we may be unable to delete your personal information; for example, to comply with legal obligations, or to complete a business transaction that you have requested.
Right to Non-Discrimination
You have a right not to receive discriminatory treatment for exercising your privacy rights as identified in this section of the privacy notice as conferred by the CCPA.
To exercise the rights above you may make the request in the following ways:
- Using the online form here;
When you submit a request, we will verify your request and identity. You may designate an authorized agent to make a request to know or a request to delete your personal information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly. We will deny any requests from agents that do not submit proof of authorization.
Changes to this policy
We may update this privacy statement to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
- Phenom People, Inc.
- 300 Brookside Avenue
- Building 18, Suite 200
- Ambler, PA 19002