HireAction Privacy Policy

Last Modified: August 11, 2021

This Privacy Policy explains how HireAction, LLC (“HireAction” or “we”) collects and uses your personal information when you use the HireAction at www.hireaction.com (the “Site”) and our candidate referral and recruiting platform (the “Service”), as well as the choices you have regarding your personal information. Please read this Privacy Policy carefully.

By accessing this Site or the Service, you accept the practices and terms of this Privacy Policy. If you do not agree to them, please do not use the Site or the Service.

1. Collection of Personal Information

When you use our Services, we may collect or receive personal information about you to provide our services and operate our business. The types of personal information that we may collect about you are:

  1. Information You Provide to Us Directly
    1. Business User Profile Information – When you sign up for a HireAction account on behalf of a business user seeking or submitting job candidate referrals, we collect information about you including your name, company name, phone number, shipping address (where applicable), email address, and password. You may also set up a profile on the Service and submit additional information to be displayed on your profile such as a photo of you, and in the future you may be able to upload a short bio, links to your presence on social media sites, and other information that you think other users might want to know about you. The information that you submit for display in your profile, including any personal information, will be viewable by other users of the Service.
    2. Candidate Profile Information – When you sign up for a HireAction account as a candidate seeking employment, we collect information about you including your name, phone number, email address, and a resume, which may include education, work history, skills and experience. 
    3. Uploaded Content – As a registered business user, you may upload additional content to the Service such as job descriptions, salary information and referral bonus amounts. Any such content that you provide to the Service will be viewable by other users of the Service in accordance with the publication settings that you specify when uploading, posting or otherwise disclosing your content within the Service.
    4. Payment Information – When you pay for the Service, as further described in our Terms of Service, we collect additional information necessary to complete a payment transaction, including your name, credit card information and billing information.
    5. Surveys and Promotions – From time-to-time, we may invite you to participate in surveys, promotions or contests. If you participate, we request certain personal information such as your name and email address.
    6. Correspondence – If you correspond with us via email or via the Service, we will obtain the information that you submit to us. This includes information provided for support purposes.
  2. Information Collected Automatically

    We also may receive and store certain information about you and your device(s) automatically when you access or use our Site and Service. This information may include:
    1. Technical Information – We collect technical information associated with your activity on our Site and may include information related to your browser and operating system, IP address (the Internet address of your computer) unique device identifiers, and other information such as your device type.
    2. Usage Information – We collect information to better understand Site and Service usage. This may include the webpage that you were visiting before accessing our Site, the pages of our Site or features of Service you, use and when and for how long you use them.
    3. Site Preferences and Cookies – We collect information about your preferences to make your use of the Site and Service more productive through the use of cookies. Cookies are intended to make using the Service and this Site easier, including by saving your preferences. For details of how we use cookies, please review our Cookie Policy.
  3. Information Collected From Third-Party Services

    We implement certain third-party offerings in the Service, enabling such third parties to collect information about you or your online activities across different websites and over time through your use of the Service. This includes enrichment information in support of direct marketing campaigns. Information collected may include, but is not limited to, personal information such as demographic data, social media profiles, and contact information.

2. Use of Your Personal Information

We use the information we collect or receive about you for various purposes.

  1. To Provide You With Our Services

    We use your information to provide you the Service. For example, we use: business user profile information and candidate profile information to create and manage user accounts and to send you alerts and reminders; payment information to complete transactions with you; and uploaded content and correspondence to provide you with Service features and support.
  2. To Maintain, Improve, and Personalize the Services

    We use technical information and usage information for diagnostic and research purposes, and to administer our Service. We use your information to analyze and improve our Site and Services, including to provide our customers with a better user experience. We may also use your site preferences to help diagnose problems with the Site and Service, including to detect and prevent fraud and security incidents, and to improve and personalize the Service for you (e.g., by using cookies to deliver content tailored to your interests).
  3. To Promote the Services

    We may use the information you provide to us or that we collect about you to promote the Services, including to provide recommendations and other communications, and to show you advertisements that may be tailored to your interests. If you are a candidate seeking employment who is referred to the Service by a business that does not hire you within 60 days of referral, we may use your candidate profile information to contact you and to invite other clients to contact you about jobs that may be of interest to you. You may opt out the foregoing promotional uses of your information by informing us that you wish to opt out in the manner described in Section 6 below.
  4. To Fulfill Legal Requirements:

    We may use your personal information to fulfill obligations under applicable law, a court order or other legal process, such as: preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, HireAction or third party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
  5. For Our Business Purposes

    We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.

3. Sharing of Your Personal Information

We may disclose personal or other information collected about you through the Site or the Service as follows:

  1. Authorized Users of the Service: In furtherance of providing the Service, HireAction may disclose certain information collected about you through the Service to other users of the Service authorized to receive such information.
  2. Service Providers: We may disclose information that we collect about you to third-party contractors who perform services for HireAction in connection with the Site and/or the Service or to complete or confirm a transaction that you conduct with us. We contractually require any affiliates and these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. As noted, information about you collected by third-party services integrated with the Site or the Service will be disclosed to such third parties.
  3. In Aggregate: We may disclose the results of aggregated data about you and other users without restriction. In these situations, we do not disclose to these entities any information that could be used to personally identify you.
  4. Corporate Transaction: We may disclose information about you as part of a merger, acquisition or other sale or transfer of all or substantially all of HireAction’s assets or business (or a potential corporate transaction).
  5. When Required by Law: We may disclose information about you to the government or to third parties under certain circumstances when legally obligated to do so. We reserve the right to release information collected through the Service or this Site to law enforcement, public authorities or other government officials as deemed necessary in our sole discretion.
  6. Enforce our Terms: We may disclose any information that we believe is necessary to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of HireAction, our employees, our users, or others.
  7. With Your Consent: We may disclose information for any other purpose with your consent.

4. Security of Your Information

The security of your information is important to us. To help protect the privacy of data we collect through the Service, we employ measures intended to be consistent with commercially reasonable industry practices for security and encryption in data transmission and storage. However, you should keep in mind that the Site and the Service are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. We process payments securely using an industry-accepted payment gateway, and do not store any billing information on our own servers. Please also be aware that despite our efforts to ensure the security of your information, we cannot guarantee that your information will be 100% secure.

Please note that protecting your personal information is also your responsibility. We urge you to take precautions to protect your information online, such as using a lengthy password which is a combination of letters and numbers. If you have reason to believe that the security of your account might have been compromised (for example, your password has been leaked), or if you suspect someone else is using your account, please let us know immediately.

5. Data Retention

HireAction will retain your personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy. Please be aware that we may also be required to retain your personal information for legal and accounting reasons. In addition, for our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, fraud prevention, troubleshooting and agreement enforcement, or in other cases where we reasonably believe that we have a legitimate reason to do so.

6. Your Rights

We believe that privacy is a right for every user, and we therefore provide you with a set of rights that you can exercise.

  1. Right to Know – You have the right to know the personal information we collect, use, disclose, and sell about you. This includes the right to know the categories of personal information that we have collected; the categories of sources; the business or commercial purposes for which we process your personal information; and the categories of recipients with whom we have shared your personal information; whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of third party recipient; and whether we’ve sold your personal information, and if so, the categories of personal information received by each category of third party recipient.
  2. Right to Access – You have the right to receive your personal information in a structured, commonly used and machine-readable format and the right to transmit your personal information to another service provider without hindrance from HireAction.
  3. Right to Delete – You have the right to request that we delete any personal information we have collected from you or maintain about you. We may nonetheless save personal information when permitted by applicable law including, without limitation, when the information is needed for a legal purpose or as required under our Terms of Service.
  4. Right to Update and Correct – If you are a registered user you may modify and correct certain of your personal information. This includes the addition or removal of certain personal information (except your name, email address, username and password, which we require of all users to maintain their accounts), as well as your preferences for the types of communications you receive from us.
  5. Right to Opt-Out of the Sale – HireAction does not sell or rent any of your personal information to third parties in exchange for money, including that of minors under the age of sixteen, however, the following may nonetheless be deemed a “sale” under applicable law: the use of advertising cookies on our site; the transfer of your candidate profile information to businesses that may want to hire you. You have the right to opt out of each of these.
  6. Right to Non-Discrimination – HireAction will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you Service, charge you different prices for it or provide you a different level or quality of Service. Note however if you opt out of the transfer of candidate profile information to businesses that may want to hire you, we cannot provide that portion of the Service to you.
  7. Right to Object or Restrict – At any time, you may object to the processing of your personal information, or request us to restrict it, on legitimate grounds, except if otherwise permitted by applicable law.

If you would like to exercise your rights regarding access, deletion, or sale of your information, you may submit an email to ccpa@hireaction.com. If you would like to opt-out of cookie based tracking, please review our Cookie Policy to adjust your preferences. Note we do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise blanket choices regarding the collection of personal information about online activities over time and across third party websites. To exercise any other rights, you can also send us your request at the email or postal address provided below in “Contact Us” section. We reserve the right to confirm your identity in order to process your requests. Please note that these rights are not absolute, and in certain cases we may decline your request as permitted or required by law.

7. Third Party Sites

This Privacy Policy only addresses the use and disclosure of information collected from you by HireAction through this Site or the Service. You should be aware that when you are using the Site or the Service, you may be directed to other websites that are beyond our control or be interfacing with third-party integrated services. We would expect most, if not all, of these third parties will collect information about you when you use their offerings. However, HireAction is not responsible for the privacy practices of third parties, regardless whether they are linked or otherwise connected to this Site or the Service. We encourage you to read the posted privacy policy whenever interacting with any third-party website or other offering.

8. Children

The Service and this Site are not directed to children under 13. If you learn that your minor child has provided us with personal information without your consent, please contact us.

9. California Residents

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the personal information for the preceding 12 months that we collect about “consumers” as defined under the CCPA, the business or commercial purposes for which we collect this personal information (“Why We Collect Personal Information”), where we obtain this personal information (“Sources of Personal Information”), and the categories of third parties with whom we may share consumer personal information (“To Whom May We Disclose Personal Information”). The section references relate to the sections above in this Privacy Policy. During the preceding 12 months, we have “sold” within the meaning of the CCPA the following categories of your personal information: identifiers, limited to cookie data associated with interest-based advertising; and candidate profile information for candidates who have opted into our sharing their information with prospective employers.

Personal Information CollectedSources of Personal InformationWhy We Collect Personal Information?To Whom May We Disclose Personal Information?
Identifiers such as a name, address, unique personal identifier, email, phone numberSection 1Section 2Section 3
Customer records information such as your education and employment historySection 1Section 2Section 3
Commercial information such as records of products or services purchased, obtained, or considered as well as records of surveys, promotions and correspondenceSection 1Section 2Section 3
Internet or other electronic network activity information, including browsing historySection 1Section 2Section 3
Financial information such as your payment card informationSection 1Section 2Section 3
Professional or employment-related information, such as your current employment informationSection 1Section 2Section 3
Inferences such as how you interact with our ServiceSection 1Section 2Section 3

10. Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@hireaction.com with the subject line “Nevada Do Not Sell Request” and providing us with your name, or the web form here. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

11. Non-US Residents

  • International Transfers

    We are a global business based in the United States, and we may transfer data globally to be processed by us or our service providers in order to provide the Service to you or for such other purposes as set forth in this policy. If you are not a resident of the U.S., you hereby consent and agree that we may collect, process, use, and store your information, as discussed in this policy, outside your resident jurisdiction, including in the U.S. Please be aware that U.S. law and the laws of other countries where we may store and process your information may offer different levels of protection for information than may be available in your country.

    If we transfer your information, as discussed in this policy, out of Europe to a country not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be performed:
    • pursuant to the recipient’s compliance with the standard contractual clauses or Binding Corporate Rules;
    • pursuant to the consent of the individual to whom the personal data pertains;
    • as otherwise permitted by applicable European data protection law requirements.

      You may contact us if you want further information on the specific mechanism used by us when transferring your information out of Europe.
  • GDPR and DPA

    HireAction is committed to compliance with the European Union’s General Data Protection Regulation (“GDPR”) to the extent applicable. If you or your organization is required under the GDPR to enter into a data processing agreement (DPA) with HireAction, you may review it https://hireaction.com/dpa.

12. Governing Law

As this Privacy Policy is incorporated into our Terms of Service, any disputes involving you and us that relate to privacy or the use of your information, and that arise out of or are related to this Privacy Policy or our Sites or Services, will be subject to our Terms of Service, including the provisions regarding the limitation of damages and liability, choice of law, arbitration and dispute resolution. Any dispute resolutions proceedings will be conducted only on an individual basis and not in a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general legal action. Your access and use of the Sites and/or Services signifies your explicit consent to this waiver. The foregoing does not prevent consumers in the European Union from bringing a claim to enforce their consumer rights in relation to this Privacy Policy in their local courts.

13. Changes

HireAction reserves the right to update or modify this Privacy Policy from time to time, with any such changes to be effective prospectively. Please visit this page periodically so that you will be apprised of any such changes. Your continued use of the Service or the Site after any modification to this Privacy Policy will constitute your acceptance of such modification.

14. Contact Us

We have appointed a data protection officer (“DPO”) who is responsible for overseeing our privacy practices. If you have any questions or concerns about this Privacy Policy or our privacy practices, or wish to exercise your rights, please contact our DPO by:

  • Mail: HireAction, LLC Attn: Data Protection Officer, 82 Nassau St #60266, New York NY 10038
  • Or by e-mail at privacy@hireaction.com

and we will work with you towards a resolution.

EU residents may submit a complaint to the data protection regulator in their jurisdiction. You can find your data protection regulator here.

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