California Privacy Policy

Harvey Nash Inc.’s Privacy Policy

Last Updated and Effective Date: January 5, 2023.

Welcome! Thank you for visiting Harvey Nash Inc. (“Harvey Nash,” “we,” or “our”). Our website, www.harveynashusa.com, (“Site”) is owned and operated by Harvey Nash Inc. To help inform you, we provide this notice explaining our information practices for California residents on our Site, and our other related tools, mobile enabled services, mobile applications and other applications and services to which this Privacy Policy is linked (“Services”). While some of the information we describe here is technical, our goal is to make this policy straightforward, so please contact us if you have any questions.

Summary

A table summarizing the contents of this privacy policy (“Privacy Policy”) appears below, followed by the policy in full. Should there be any discrepancy between the table and the full policy, the language of the full policy shall govern.

Scope and Consent	This Privacy Policy describes the information practices of Harvey Nash’s website, mobile apps, services, tools, and other applications and services that link to this Privacy Policy for California residents under the California Privacy Rights Act (“CPRA”). Your use of the Services is also governed by the Terms and Conditions.
Collection	We may collect the following personal information when you use the Services: Identifiers Professional or employment information Education information Financial information Internet or other electronic network activity information Geolocation data Health or medical information Protected classifications Sensitive personal information
Use	We use information collected from you for a variety of business and commercial purposes, such as maintaining and servicing accounts, processing payments, verifying customer information or auditing related to a current interaction with the consumer.
Retention	We retain your personal information for as long as necessary to comply with our legal obligations and other legitimate business purposes.
Disclosure	We may share your personal information and other information we collect with the following entities: Harvey Nash and the rest of our corporate family, vendors, social networks, law enforcement, new owners in the event of a change of corporate control, and others with your consent.
Summary of Information	You can view a summary of the personal information we have collected, used, and shared in the last 12 months.
Rights for California Residents	If you are a California resident, you have rights to know, access, delete, correct, non-discrimination, limit the use and disclosure of sensitive personal information, and opt-out of the “sale” or “share” of your personal information. We honor these rights for California residents to the extent required by applicable law. For example, because we only use sensitive personal information for certain limited purposes and do not sell or share your personal information, we do not offer these rights.
Cookies	We use the Google Analytics cookie on this Site, which provides us insights regarding our users. Google acts as our service provider in providing this service. To learn more about Google Analytics, please visit the following website, https://analytics.google.com/analytics/web/provision/#/provision. We do not use Google Analytics for cross-context behavioral advertising.
Third Parties	We are not responsible for the privacy practices of third-party websites that are linked to our Services.
Security	We seek to protect your personal information by using reasonable security measures.
Children’s Privacy	The Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from users within this age group. We also do not knowingly sell, share, use or disclose the personal information of children in this age group.
International Transfer	We store and process your personal information on our computers in the US and elsewhere in the world.
Notification Regarding Updates	You agree that we may notify you about material changes to this Privacy Policy by posting notices on the Services.
Contact Us	Harvey Nash Inc. privacy issues are covered by the Global Privacy Office. For more information about our privacy practices, review this Privacy Policy, send an email to CPRA@harveynash.com, or call us at 1-833-496-0299.

Full Privacy Policy

Scope and Consent.

When you use the Services, you are contracting with Harvey Nash Inc. and all Harvey Nash Inc.’s parent or subsidiary companies, which include Nash Squared, Alumni, Spinks (We Are Spinks), NashTech, PAT Management, Talent-IT, and Team4Talent, collectively referred to here as “Harvey Nash.” This Privacy Policy explains what we do with your personal information, whether as part of helping you find a job, developing your career, providing you with a service that may be of interest, or simply as a result of you visiting our website.

Information Practices: How we collect, use, retain, and disclose personal information.

Collection of Information

When you use our Services, we collect the following types of information from and about you. Some of this information may be considered “personal information,” meaning it identifies, relates to, describes, is capable of being associated with, or otherwise can be reasonably linked to you or your household. Some of this information may also be considered “sensitive personal information” which requires additional protections.

Personal and Sensitive Information You Provide

You may choose to provide us with personal information through the use of our Services, including:

Identifiers: As a job candidate or in response to a Harvey Nash survey, you may provide personal information such as name, address, email, phone number, social security number, driver’s license number, passport number, or other similar identifiers.

Protected classifications: During your employment application or your employment, you may provide personal information such as your age, sex, race, national origin, medical condition, marital status, military or veteran status, gender identity or expression and request for family care leave.

Professional, Employment, and Education Information: You may submit an application, resume or curriculum vitae via the Services, which contains information such as education, current and previous job title and employer, professional publications, and professional certifications.

Other Personal Information: You may disclose to us other information such as bank account number, payroll details and other financial information.

Sensitive Personal Information: The following personal information, which are listed above, constitute sensitive personal information: social security number, driver’s license number, passport number, race, national origin, medical condition, sex life or sexual orientation (as inferred from marital status, sex, or gender identity or expression), and financial account information if in combination with any required security or access code, password, or credentials allowing access to an account.

Automatically Collected Information

We automatically collect personal information when you access and use our Services, including: Identifiers: Identifiers such as your IP address, Internet service provider (ISP), device make and model, and unique personal identifiers.

Internet or Other Electronic Network Activity Information: We may collect information regarding your interaction with our Services, which includes but is not limited to browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you visit our Services, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Services and other information about your internet activity (“usage information”).

Geolocation Data: If you choose to install our mobile application and allow the use of your device’s location, we may receive geolocation data. We may also use or collect your IP address to estimate your approximate location.

Information from Outside Sources

We may collect personal information about you from other sources. For example, if you apply for a job position using the Services, we may obtain information about you from background check vendors, job boards, social media sites, publicly available databases, data aggregators, staffing agencies, and other third-party vendors.

Use of Information

We collect personal information for a variety of business and commercial purposes, such as to:

Process payments
Verify customer information
Maintain or service accounts
Process or fulfill orders and transactions
Auditing related to a current interaction with the consumer
Provide customer service (e.g., to resolve disputes, feedback, problems with the Services)
Conduct and review Harvey Nash surveys
Improve, upgrade or enhance our Services
Short-term, transient use

We collect and use sensitive personal information only for limited purposes under the CPRA, including to perform the services that you request, for security purposes, for short-term, transient use, to protect against malicious, deceptive, fraudulent, or illegal actions, and to verify or maintain the quality of our Services. Because we use this sensitive personal information for these limited purposes, there is no need for us to provide a Limit Use and Disclosure of Sensitive Personal Information right under the CPRA.

Data Retention

We store personal and sensitive information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Disclosure

Information collected may be shared with:

The Harvey Nash Inc. Corporate Family: We may share the information we collect about you with the Harvey Nash Inc. corporate family and our affiliates and subsidiaries, including but not limited to Nash Squared. This Privacy Policy is intended to provide notice on behalf of all of these entities.

Service Providers: We may disclose your information to service providers and vendors under contract who help with our business operations, such as HR software providers, payroll vendors, health benefits providers, cloud storage providers, to assist with, bill collection, payment processing, web hosting, recruitment, employment, research, IT, direct mail and email distribution, site analytics and operations, fraud investigations, processing opt-out requests, and responding to consumer requests. We may also share your information with legal, financial, insurance and other advisors in connection with corporate transactions, the management of our business and operations, to defend against legal claims; to investigate, prevent, or act against illegal activities, suspected fraud, situations involving potential threats to safety, or violations of Harvey Nash Inc.’s terms of use; to protect our operations, assets, and intellectual property; to allow us to pursue appropriate legal remedies or limit damages; to pursue any reorganization, merger, sale, joint venture, assignment, transfer of assets, or other disposition of all or any portion of our business, assets, or stock; or as otherwise required by law.

Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Harvey Nash Inc. user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, ZIP code, telephone number, email address, user ID history, IP address, fraud complaints, and anything else we may deem relevant to the investigation.

Change of Control – New Owners: We may transfer your personal information as an asset that is part of a merger, acquisition, bankruptcy or other transaction if a third party assumes control of all or part of our business.

Other Entities with your Consent: Other parties at your specific direction.

Summary of Information Practices in Last 12 Months.

The following table summarizes our personal information collection, use, and disclosure practices in the preceding 12 months since we last updated this Privacy Policy. On mobile devices, scroll horizontally to view full table.

Categories of Personal Information	Categories of Sources	Commercial / Business Purpose(s) for Collection/Disclosure	Categories of Service Providers to Whom Personal Information is Disclosed	Categories of Third Parties to Whom Personal Information is Sold or Shared
Identifiers Examples: name, alias, email address, postal address, phone number, IP address, account name, social security number, driver’s license number, passport number, and unique personal identifier* *Social security, driver’s license, and passport numbers from the above list are considered sensitive personal information	You Outside sources such as credit agencies, staffing agencies and background check vendors	Process payments; Verify customer information; Maintaining or servicing accounts; Process or fulfill orders and transactions; Auditing related to a current interaction with the consumer; Provide customer service (e.g., to resolve disputes, feedback, problems with the Services); Improve, upgrade or enhance our Services; and Short-term, transient use, provided the information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction	Service providers such as HR software providers, payroll vendors, background check vendors, cloud storage providers, IT vendors, database providers, customer service vendors and other service providers that that need access to such information to perform services for us Data analytics providers	None
Other Categories of Personal Information in California Civil Code 1798.80(e) Examples: bank account number, payroll details and other financial information* *Financial account information if in combination with any required security or access code, password, or credential allowing access to the account is considered sensitive personal information	You Outside sources such as credit agencies	Process payments	Service providers such as HR software providers, payroll vendors, background check vendors and cloud storage providers	None
Characteristics of protected classifications under California or federal law Examples: race, color, age, sex, citizenship, national origin, medical condition, marital status, military or veteran status, gender identity or expression and request for family care leave* * Race, national origin, medical condition, sex life or sexual orientation (as inferred from marital status, sex, or gender identity or expression) are considered sensitive personal information	You Outside sources such as background check vendors	Verify customer information	Service providers such as HR software providers, payroll vendors, background check vendors and cloud storage providers	None
Internet or Other Electronic Network Activity Information Examples: Information regarding a consumer’s interaction with our Services; Domain information, pages visited, and hyperlinks clicked; Session information such as time spent on certain pages and page interaction	Your mobile devices and computers used to access our Services	Auditing related to a current interaction with the consumer Providing, maintaining and improving the Services and products	Data analytics providers IT vendors, cloud computing providers, database providers, customer service vendors and other service providers that that need access to such information to perform services for us	None
Geolocation data Examples: general location at city level	Cookie (i.e. Google Analytics)	Providing, maintaining and improving the Services and products and services Auditing related to a current interaction with the consumer	Data analytics provider IT vendors, cloud computing providers, database providers, customer service vendors and other service providers that that need access to such information to perform services for us	None
Professional or Employment-related and Education Information Examples: job history, educational history, professional certifications, publications, etc.	You Outside sources such as background check vendors	Process and evaluate employment applications Verifying customer information	Service providers such as HR software providers, payroll vendors, background check vendors, cloud storage providers and others as necessary to provide services to us

Sale or Sharing of Personal Information: We do not sell or share your personal information with third parties. We also do not knowingly sell, share, use or disclose the personal information of children under the age of 18. As such, there is no need to opt-out of the sale or sharing of your personal information. Please Contact Us below if you have any questions.

Choices for Access, Deletion, Correction, and Right to Non-Discrimination for California Residents or As Required by Law.

If you are a California resident, you have the right to know what personal information we collect, disclose, and “sell” or “share” about you (as those terms are used in the CPRA). Additionally, you have the right to access, delete and correct your personal information. As mentioned above, we do not provide a limit use and disclosure of sensitive personal information right because we use sensitive personal information only for certain CPRA-permitted purposes. We also do not offer an opt-out of sale or share right because we do not sell or share your personal information. If you have any questions about these rights, please Contact Us below.

To exercise these privacy rights and choices, please follow the instructions below:

How to Request Access to Personal Information: You may request access to your personal information twice in a 12-month period. To do so, please email us at CPRA@harveynash.com or call 1-833-496-0299. In response, we will produce an Access Report detailing the personal information we have collected, disclosed, sold and/or shared about you. This Access Report will be delivered by mail or electronically at your request.

How to Request Deletion of Personal Information: You may ask Harvey Nash to delete the personal information it has collected and/or maintained about you. To do so, please email us at CPRA@harveynash.com, or call 1-833-496-0299. Note, we may need to retain certain personal information as permitted by law and the CPRA.

How to Request Correction of Personal Information: You may ask Harvey Nash to correct the personal information that it has collected and/or maintained about you. To do so, please email us at CPRA@harveynash.com, or call 1-833-496-0299.

Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

Verification: Please note, we will take steps to verify your identity before fulfilling any of the above requests. We will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., name, email, mailing address).

Authorized Agents: You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please Contact Us.

Do Not Track Signals: Harvey Nash does not respond to Do Not Track signals to the extent received from a web browser.

Communication Preferences and Marketing (Opt-out).

If you do not wish to receive marketing communications from us, you can indicate your communications preference within the direct communication from us. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes).

Cookies.

When you visit the Services, we may use the Google Analytics cookie to learn more about our users. Google acts as our service provider in offering this service. To learn more about Google Analytics, please visit the following website, https://analytics.google.com/analytics/web/provision/#/provision. We do not use Google Analytics for cross-context behavioral advertising.

Third Parties.

Our Services may contain links to other third-party websites. We are not responsible for the privacy practices or the content of these third-party sites.

Security.

We may store and process your information in the United States and around the world. We maintain reasonable technical, physical, and administrative security measures designed to help protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. It is your responsibility to make sure that your personal information you submit is accurate. However, we do offer a right to correct, as indicated above. If you believe that your login credentials have been compromised, please contact us as indicated in the Contact Us section below.

Children’s Privacy.

The Services is a general audience site and it is not intended for individuals under the age of 18. We do not knowingly collect personal information via our websites, applications, services, or tools from individuals under 18 years old.

Notification Regarding Updates.

We will change this Privacy Policy from time to time. When we make changes, we will revise the date at the top of the policy and, in some cases, will notify you through the Services, such as on our homepage, or via email or other communication.

Contact Us.

If you have any questions or concerns about this Privacy Policy or our privacy practices, you may contact us by emailing us at CPRA@harveynash.com or calling us at 1-833-496-0299.

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