Privacy Policy

Your privacy is important to us. This privacy statement explains the personal data iTalent processes, how iTalent processes it and for what purposes. iTalent Corporation and its products and subsidiaries (collectively "iTalent Corporation”, “iTalent Corporation DBA iTalent Digital”, "Chama", "ChamaCloud", "ICS", "Intelligent Content Syndication", "SmartConX" and “MojoRank”) are committed for protecting your privacy and ensuring you have a positive experience on our websites and in using our products and services ("Solution" or "Solutions"). This Privacy Statement applies to iTalent website (www.italentdigital.com) and describes how we handle personal information. Additional information on our personal information practices may be provided in the supplements on the right or in notices provided at the time of data collection.

For the purposes of EU data protection laws ("Data Protection Law"), iTalent is data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).

Definitions

Service

Service is the italentdigital.com website operated by iTalent Digital

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

We gather various types of Personal Information from our users and others, as explained in more detail below, and we use this Personal Information internally in connection with our Services, for example, to personalize, provide, and monitor and improve our Services, to allow you to set up a user account and profile, to contact you, allow others to contact you, and allow you to contact others through the Services, to respond to customer care and other inquiries, to process and fulfil your requests for certain products and services, and to analyze how you use the Services.

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Cookies and Usage Data

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Use of Data

iTalent Digital uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

Legal basis for processing in the EU

In the EU, the purposes for which we process your personal data are:

• where we need to perform the contract, we are about to enter into or have entered into with you for the Service;
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation in the EU.

Please contact us at infosec@italentdigital.com if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), iTalent Digital legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

iTalent Digital may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• To comply with the law

iAgent for GDPR analyzes the GDPR requests received and routes them intelligently to target systems and repositories, triggering required actions to ensure compliance. iTalent Digital customizes iAgent for GDPR to each customer, delivering a complete data inventory template, data typing, tagging and classification, and the configuration of tailored data- and application-specific policies.

Retention of Data

iTalent Digital will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

iTalent Digital will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

iTalent Digital will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

iTalent Digital will not transfer Personal Information to third parties except where permitted or required by the customer and then in accordance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, iTalent Digital may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

iTalent Digital may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of iTalent Digital
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. iTalent Digital aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where iTalent Digital relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

EU-US Privacy Shields

iTalentdigital.com (“iTalent Digital”) complies with the EU‑U.S. Privacy Shield Framework set forth by the United States Department of Commerce with respect to the collection, use and retention of Personal Data transferred from the European Union and the United Kingdom to the United States, respectively, as further described above. iTalent Digital has certified that it adheres to the EU-U.S. Privacy Shield Principles which include Supplemental Principles (collectively, the “EU-U.S. Privacy Shield Principles”) for Personal Information covered by the Policy. This Privacy Shield Policy outlines our commitment to the Privacy Shield Principles (the “Principles”) and our practices for implementing the Principles. If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. iTalent Privacy Shield certification can be found at https://www.privacyshield.gov/list. To learn more about the Privacy Shield Framework, please visit the Department of Commerce’s dedicated Privacy Shield website, located at https://www.privacyshield.gov/Program-Overview.

ITalent Digital complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and UK, including the onward transfer liability provisions.

In compliance with the Privacy Shield Principles, iTalent Digital commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact iTalent Digital at: infosec@italentdigital.com

iTalent Digital has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

ENFORCEMENT AND DISPUTE RESOLUTION

If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the EU-U.S. Privacy Shield Principles.

As further explained in the EU-U.S. Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. iTalent Digital is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email : infosec@italentdigital.com

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

The iTalent Digital Privacy Statement was revised and posted as of April 20, 2020.