Last Updated: July 22, 2022
Collection and Use of Personal Information
When you use or register with the Website, we may, with your consent, collect certain “Personal Information,” which is information that identifies you as an individual or relates to an identifiable individual, including information considered “personal data” under the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”), in order to carry out our business purposes of providing our recruiting, employment, and consulting services. Personal Information includes: your name and contact information (email, address and phone number), your gender, any pseudonymous data, your job search criteria and preferences, your employment experience, educational history, your skills, reference information, background information, other information contained in your resume, or any login ID or email address and password created by you. The majority of this Personal Information is provided by you directly when you contact us, submit an employment application, through phone conversations or e-mail exchanges, contact with us about our services, or during your employment relationship. We also collect data about individuals who are employed or engaged by our customers in connection with our provision of consulting services to those customers. We do not collect Personal Information from third-party sources.
We use Personal Information to register you with the Website, to provide you with information regarding employment opportunities and career-related information, and to otherwise provide you with requested information or services. We may from time to time use your Personal Information to send you automated email messages, or marketing materials regarding our services, including employment information. We may also use Personal Information for our business purposes, such as data analysis, audits, and improving our services.
Disclosures of Personal Information
SolomonEdwards may disclose Personal Information to third parties in the following circumstances: (1) to our third-party service providers who perform business functions and services on our behalf; (2) to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of SolomonEdwards or its affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of the users or the public. We also may disclose or transfer information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Collection and Use of Other Information
We may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Website functions properly.
- Net-Results: We also utilize Net-Results for an intelligent set of marketing automation tools to improve how we manage marketing lead generation campaigns.
- The Net-Results tracking beacon issues a unique ID to each visitor, stored in a “1st party cookie”. Being a 1st party cookie means that the Net-Results tracking beacon makes no attempt to monitor Website visitors once they have left the Website.
- Whenever a page is viewed on the Website, the Net-Results tracking beacon retrieves the unique ID from the cookie. It then sends data to the Net-Results servers to be stored, including the visitor’s unique ID, the URL of the page that was visited, the date and time at which the page view occurred, the URL of the web page that led the visitor to the current page, and the IP address reported by the visitor’s web browser. Net-Results uses the IP address in an effort to discover the city, state/province, and country where the Website visitor is located. It can sometimes tell the name of the company where the visitor works.
- If a Website visitor, at some point during their visit or during any subsequent visit, submits a Net-Results Form embedded on the Website, Net-Results will record the form submission and update the Contact record for that visitor. Depending on the fields that the form required, the Contact’s first name, last name, and email address may be populated, for example. The Contact is no longer an “Anonymous Contact” but an “Identified Contact”. The vast majority of Website visitors will not submit a form on the Website and will therefore remain anonymous and unidentified.
- IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. As mentioned above, an IP Address may be identified and logged automatically in our server log files whenever a user accesses the Website, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Website. We may also derive your approximate location from your IP Address.
We do not collect Other Information from third-party sources, other than through Google Analytics and Net-Results. Please note that we may use and disclose Other Information for our business purposes.
Storage of Personal Information
We will retain your information for as long as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Third Party Services
This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links.
We use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Withdrawal of your Consent
If your Personal Information changes, if you no longer desire our service, or if you want to limit the use or disclosure of your Personal Information beyond what is set forth in this Policy, then you may correct, update, amend, delete/remove, request portability of or use or disclosure restrictions on or withdraw your consent to our collection and/or use of your Personal Information (including for direct marketing purposes) by emailing us or by contacting us by postal mail at the contact information listed below. We will respond to your request within 30 days, but we may not be required to honor your request in all cases. Please note that if you withdraw your consent to our collection and/or use of your Personal Information, then certain portions of our Website may be inaccessible to you and/or you may not be able to receive our recruiting, employment, and/or consulting services.
Our Website includes links to our brochures, white papers, case studies, and other marketing materials. If you wish to download certain materials or sign-up for events/webinars, we will use your name and email address to send such materials to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in such emails or by contacting us at the email address provided below. When your interactions with us have resulted in your registration for multiple services or resources it may be necessary to opt out from each service separately.
Because processing your information is necessary to the performance of the recruiting, employment, and consulting services that we provide to you, a request to exercise certain rights may result in us being unable to continue providing one or more of our services to you. Subject to applicable law, we also may limit requests or charge reasonable fees.
CCPA Rights for California Residents
Under CCPA, California residents may have the right to request certain information about our practices with respect to Personal Information. In particular, you can request the following information regarding the personal information we collected or used about you in the 12 months prior to our receipt of your request:
- The categories of your Personal Information that we’ve collected.
- The specific pieces of your Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purposes for which we collected or sold Personal Information.
- The categories of personal information we disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties with which we shared Personal Information.
You can submit a request to us for the following additional information:
- The categories of third parties to whom we’ve sold Personal Information, and the category or categories of Personal Information sold to each.
- The categories of Personal Information that we’ve shared with service providers who provide services for us, like processing your bill.
“Selling” data and what it means for job applicants:
We use our applicants’ information in order to help people get jobs. However, the CCPA has a much broader definition of “sell” than this.
Typically, the definition of “selling” information is that it involves a company taking information it has learned about you and exchanging that information with an unrelated third party for money, who will then use that data for a new purpose that you did not intend. SolomonEdwards never does this with your information.
Here’s what SolomonEdwards does that may fall under the CCPA’s notification requirements. Note that this list is not meant to be exclusive but shows examples of what our products and services do.
- We display your submitted resume to internal recruiters and clients who act as your employer.
- We create profiles or bios from your submitted resume.
- We recommend your submitted resume or profile to internal recruiters and employers.
- As an employer we also collect and use Personal Information for human resources, employment, benefit administration, health and safety, and business-related purposes and to be in legal compliance. Below are the categories of Personal Information we collect and the purposes for which we intend to use this information:
- Identifying information, such as your full name, gender, date of birth, and signature.
- Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
- Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
- National identifiers, such as SSN, passport and visa information, and immigration status and documentation.
- Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
- Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
- Geolocation data, such as time and physical location related to use of an internet website, IP address, application, device, or physical access to a Company office location.
- Sensory or surveillance information, such as COVID-19 related temperature checks and call monitoring and video surveillance.
- Profile or summary about an [applicant/employee]’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
What SolomonEdwards does not do:
- We don’t sell data to data brokers.
- We don’t exchange information about you with a third party for money.
Reasons SolomonEdwards collects and may use your Personal Information:
- Recruit and evaluate job applicants and candidates for employment. -Showing resumes and profiles to employers is how we help people who have submitted their resume get jobs.
- Comply with all applicable laws and regulations.
- Conduct background checks.
- Investigate and enforce compliance with and potential breaches of SolomonEdwards’ policies and procedures.
- Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
- Perform workforce analytics, data analytics, and benchmarking.
- Administer and maintain SolomonEdwards’ operations, including for safety purposes.
- Exercise or defend the legal rights of SolomonEdwards and its employees, affiliates, customers, contractors, and agents.
Opting out of data “selling”:
A request to not “sell” or “transfer” your information to a prospective employer prohibits us from providing our services to you. In order to opt out, you can request that we delete your account and personal data.
To submit a request to view a copy and/or delete your Personal Information, contact us using the information below. By submitting this request, you are declaring that you are a California resident exercising your rights under CCPA.
If you have any questions about this Notice or need to access this Notice in an alternative format due to having a disability, please contact DPO@solomonedwards.com.
Use of Site by Minors
The Website is not directed to individuals under the age of eighteen (18) and, we do not knowingly collect Personal Information from individuals under 18.
The Website is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Where required, SolomonEdwards implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties. You can request a copy of the EU Standard Contractual Clauses by emailing us at firstname.lastname@example.org.
Revisions to the Policy
If we change this Policy we will post any updates here for your review. The “Last Updated” line at the top of this page indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Website and it is provided to you.
If you have any questions about this Policy, or if you would like to update any personal information you have provided to us, please contact us at:
Attention: Lito Abiva
1255 Drummers Lane, Suite 200
Wayne, PA 19087
Email Address: email@example.com
Local Data Protection Authority
You may, depending on where you are located, have the right to make a complaint with your local data protection authority based on issues you may have with this Policy. You can find the contact information for your local data protection authority at the following website: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
This website is owned by SolomonEdwardsGroup, LLC, which does business only in the United States of America. If you do not want this website to collect data regarding yourself or your activities, do not use this website. By continuing to use this website, you consent to SolomonEdwardsGroup, LLC’s collection of your data. If applicable SolomonEdwardsGroup, LLC will comply with laws of countries other than the United States of America.