Privacy policy for Leoforce, LLC and its Global subsidiaries

Who are we?

Leoforce, LLC and its subsidiaries (“Leoforce” or “We“) are the leader in People Intelligence. We develop technology that empowers talent acquisition professionals to truly understand people. We’re the company behind Arya, the world’s first and foremost AI recruiting advisor. Arya, our proprietary tool, is a web-based workforce management solution platform that provides an intelligent recruiting solution and employment content management system for recruiters, staffing companies, employers, and/or candidates. Designed to be a recruiter’s best friend, Arya layers artificial intuition on top of predictive analytics and proprietary machine learning models so that you can focus on what you do best – building quality relationships with ideal candidates. We are principally based out of the United States of America and India and have customers based globally across all geographies.

What Personal Data do we collect?

Visitors Data – We collect Personal Data of visitors who reach our website and enquire about our services or send an inquiry about our services or request for our product demo. Such individuals are collectively termed as `Visitor‘ We collect Personal Data like your location, website browsing patterns, content download requests, and IP address. Please see our Website Terms of Use https://leoforce.com/website-terms-of-use/ and Cookie Policy https://leoforce.com/cookie-policy  for additional information about the data we collect when you visit one of our websites.

Prospect Data – We collect Personal Data of contacts at organizations that may be interested in knowing more about our products and services. Such individuals are collectively termed as `Prospect‘ We collect Personal Data like name, email address, job title, phone number, company name, social network addresses, and copies of communications. This information may be disclosed directly by the prospect by filling out a request for content or contact, completing a survey, registering for a live or virtual event, or other methods. Leoforce gathers Personal Data from several sources, including publicly available sources such as websites and government records, contributions from our customers, third-party data providers, or telephone interviews.

Candidate Data – We collect Personal Data of candidates or individuals who have posted their professional profiles on social platforms, websites, etc. Such individuals are collectively termed as `Candidate‘ We collect Personal Data such as name, location, employer, employer location, job title, employment dates, previous employers, education, social profile URLs, and other data made public by individuals (collectively termed as “Profile Data“). Profile Data are collected from many sources, including publicly available sources such as social media platforms, job boards, and third-party partners. We also collect additional Personal Data such as the phone numbers and email addresses of Candidates whose Profile Data matches customers’ requirements from various sources, including contact providers.

Customer Data – We collect Personal Data of individuals belonging to customer organizations with service provisioning contracts or agreements with Leoforce. We collect Personal Data such as name, company name, title, phone number, email address, and any Personal Data based on agreed contracts or agreements.

Employee/Consultant/Contractor Data – We collect Personal Data of employees, consultants, and contractors who work for or on behalf of Leoforce. We collect Personal Data like name, date of birth, address, phone number, email address, nationality, profession, passport details, SSN, personal information about spouse, parents, children, gender, age, religion, marital status, visa details, bank account, credit card details, education, experience, photograph, drivers’ license, work permit, insurances, work experience, and electronic identification data.

“Personal Data” means any information relating to an identified or identifiable natural person (“data subject” or “you” or “your”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, an online identifier, or to one or more factors specific to the data subject’s physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. We may use your Personal Data based on legitimate interest, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of Personal Data. Sensitive Personal Data is generally only collected from employees of Leoforce as (a) required by law or (b) for employment purposes and will be used strictly for such purposes.

What do we do with the Personal Data we collect? How do we use Personal Data?

If you are a Visitor or Prospect:

We collect your Personal Data, analyze it to understand your business needs, and use it to send general communications and marketing content to you about our product and services.

 If you are a Candidate:

We collect your Personal Data, store it in our candidate database and provide it to prospective customers interested in your profile. We identify you as a potential candidate for a job position with one or more of our customers.

 If you are a Customer:

We collect your Personal Data to fulfill our contractual obligations with you, provide you with customer support. We also use your Personal Data to reply to requests submitted through a contact form; develop new content, features, and functionality; collect and manage your consent; record your requests and the communication between you and Leoforce regarding your Personal Data.

 If you are an Employee:

We collect your Personal Data to perform reference and background checks. These checks include relevant criminal and credit history; pre-employment test results; post-offer medical examination information and results, including drug test results; voluntary self-disclosed information regarding minority, veteran, and disability status; and Personal Data you provide during the hiring process.

How long do we store the Personal Data?

If you are a Visitor or Prospect:

We store your Personal Data for as long as needed to support our business relationships, record and manage communication and privacy preferences, or until we receive a request to stop processing or delete your data. Visitors or Prospects may visit our preferences page located here: https://go.leoforce.com/opt-in.

If you are a Candidate, Employee, or Customer:

We retain Personal Data we collect from you when we have your consent or an existing legally binding agreement to provide services to you or receive services from you.  When we do not have your consent or an existing, legally binding agreement, we will delete your Personal Data. Suppose it is not possible to delete your Personal Data, for example, because your Personal Data has been stored in backup archives. In that case, we will securely store your Personal Data and isolate it from any further processing until deletion is possible. If required by law, we will retain the Personal Data as long as it is necessary for the purpose for which it was collected.

Our lawful basis of processing your Personal Data:

Leoforce processes your Personal Data based on the legitimate interest of the company and its customers only if:

  • The data subject has given consent to the processing of their Personal Data for one or more specific purposes
  • Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract
  • Processing is necessary for compliance with a legal obligation to which Leoforce is subject
  • Processing is necessary for the purposes of the legitimate interests pursued by Leoforce or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of Personal Data, in particular where the data subject is a child.

With whom, where, and why do we share your Personal Data?

If you are a Visitor or Prospect:
  • We share your Personal Data internally with Leoforce employees who require access to such Personal Data to fulfill their roles and responsibilities within Leoforce.
  • We share your Personal Data with third parties that provide Leoforce with necessary services such as analytics, web hosting, data augmentation, and communication under a binding agreement with Leoforce.
  • We may share your Personal Data with subsidiary companies and their employees based outside the United States of America so that they may conduct supporting activities that assist Leoforce services.
  • We share your Personal Data as required by law.
  • We share your Personal Data with law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process.
If you are a Candidate:
  • We share your Personal Data internally with Leoforce employees who require access to such Personal Data to fulfill their roles and responsibilities within Leoforce.
  • We share your Personal Data with entities with suitable recruitment opportunities for you and with whom we have a legally binding agreement.
  • We share your Personal Data with third parties that provide Leoforce with necessary services such as analytics, web hosting, data augmentation, and communication under a binding agreement with Leoforce.
  • We may share your Personal Data with subsidiary companies and their employees based outside the United States of America so that they may conduct supporting activities that assist Leoforce services.
  • We share your Personal Data as required by law.
  • We share your Personal Data with law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process.
If you are a Customer:
  • We share your Personal Data internally with Leoforce employees who require access to such Personal Data to fulfill their roles and responsibilities within Leoforce.
  • We may share your Personal Data with subsidiary companies and their employees based outside the United States of America so that they may conduct supporting activities that assist Leoforce services.
  • We share your Personal Data as required by law.
  • We share your Personal Data with law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process.
If you are an Applicant/Employee:
  • We share your Personal Data internally with Leoforce employees who require access to such Personal Data to fulfill their roles and responsibilities within Leoforce.
  • We share your Personal Data with third parties that provide Leoforce with necessary services such as credit reporting agencies, payroll providers, benefits plan administrators under a binding agreement with Leoforce.
  • We may share your Personal Data with subsidiary companies and their employees based outside the United States of America so that they may conduct supporting activities that assist Leoforce services.
  • We share your Personal Data as required by law.
  • We share your Personal Data with law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process.

What are your rights to Personal Data?

If you are Visitor, Prospect or Candidate, or Applicant/Employee:

You have the right to request that Leoforce:

  • Provide you with access to your Personal Data
  • Rectify or correct your Personal Data
  • Erase your Personal Data
  • Restrict your Personal Data processing, including refraining from selling it or otherwise providing it to any third parties

You also have the right:

  • To object to processing
  • To data portability
  • To file a complaint with the appropriate supervisory authority in your country, if any

The preceding rights may be subject to certain limitations pursuant to applicable law.
Use the contact details referenced below to make all such requests.

FOR CALIFORNIA RESIDENTS

This Notice was created pursuant to the California Consumer Privacy Act (“CCPA”).

We collect, and have collected within the preceding 12 months, the following categories of Personal Information (as defined in the California customer records law) about California residents, as listed in the CCPA:

Category 1 – Identifiers Identifiers such as name, alias, postal address, online identifier, Internet Protocol (IP) address, email address, account name, social security number, passport number, or other similar identifiers
Category 2 –

Customer Records Information

Personal information such as name, signature, social security number, address, telephone number, passport number, education, employment, employment history, and bank account number
Category 3 –

Characteristics of protected classifications under California or federal law

Characteristics of protected classifications under California or federal law, such as age, sex, disability status, citizenship, and marital status, to the extent required or permitted by applicable law
Category 4 –

Commercial information:

Commercial information, such as transaction information and purchase history

 

Category 5 –

Biometric information

None
Category 6 –

Internet or other electronic network activity information

Browsing history, search history, and information regarding a consumer’s interaction with an Internet website
Category 7 –

Geolocation data

 

None
Category 8 –

Audio, electronic, visual, thermal, olfactory, or similar information

 

Audio, electronic, visual, and similar information, such as photographs or audio and video recordings created in connection with our business activities;

 

Category 9 –

Professional or employment-related information

 

Professional or employment-related information, such as work history and prior employer, information relating to references, details of qualifications, skills and experience, and data necessary for benefits and related administration services;
Category 10 –

Education information

Information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 USC section 1232g, 34 CFR Part 99)

 

Category 11 –

Inferences

 

Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s Preferences or Behaviour or Attitudes or Intelligence or Abilities or Aptitudes

 

Leoforce may disclose your Personal Information under Category 9 with its Customers and Category 1, 2, 4, 6, 8, 9, and 10 with its Service Providers.

Please refer to What Personal Data do we collect? section in this Policy for information on the sources of these categories of Personal Information.

For information on what we do with your Personal Data, please refer to the What do we do with the Personal Data we collect? / How do we use Personal Data? section of this Policy.

For more information on the third parties to whom these categories of Personal Information are disclosed, please refer to the With whom, where, and why do we share your Personal Data? section of this Policy.

To request the disclosures and deletion of your Personal Information, please write an email to dpo@leoforce.com or call us at +1 919-800-0110. In most cases, Leoforce will verify your request by:

  • Confirming that you control the email address associated with your Personal Information;
  • Confirming that your description of your interactions with Leoforce matches our records. And
  • If you are requesting on someone else’s behalf, you must also submit signed proof of authorization and, if necessary, we may ask for additional information.

We will respond to your request consistent with applicable law.

 

Data security

While no data security system can fully protect Personal Data from unauthorized data breaches, Leoforce has implemented reasonable safeguards and controls, consistent with its legal obligations under local, state, and federal laws. Leoforce is committed to:

  • Seeking to safeguard all Personal Data that you provide to us
  • Seeking to ensure that it remains confidential and secure
  • Taking all reasonable steps to ensure that personal privacy is respected
    • We store our data in written or electronic form on our servers, computers, and various physical locations.
    • We maintain physical, electronic, and procedural safeguards to protect your Personal Data from misuse, unauthorized access or disclosure, and loss or corruption by computer viruses and other sources of harm.

We have put in place procedures to deal with any suspected data security breach. We will notify you and any applicable regulator or supervisory authority of a suspected breach where we are legally required to do so.

How can you exercise your rights?

To exercise your data protection rights, ask questions, or make a complaint, please contact Leoforce via email at dpo@leoforce.com or via postal mail at Leoforce, LLC, 500 W Peace St, Raleigh, NC 27603, or via phone at +1 919-800-0110. We will respond to your request as soon as practicable or within one month of receiving your request. We may request proof of identification to verify your request.

Children

The Leoforce website is not intended for use by children. Leoforce does not knowingly solicit or collect Personal Data from children under the age of 18. If you are under 18 years of age, you must obtain your parent or guardian’s consent to use the Leoforce website.

Changes to this commitment

We may change this Policy from time to time. The changes to this Policy may occur depending on the applicability of various data privacy laws and regulations to Leoforce and our continual efforts to comply with all such compliance obligations. This Policy has been revised to address the compliance obligations arising from General Data Protection Regulation (EU) and California Consumer Privacy Act and its related amendments. We will notify you of any material changes through a notification on our website. Wherever possible and applicable, we may also inform you about the Policy changes through other communication channels such as emails, notifications, etc. Changes to this Policy shall also be communicated as part of subsequent communications or marketing content sent to you. Any changes will become effective immediately after being posted.

Last Updated:  February 8, 2021

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