CCPA Privacy Policy

Harvey Nash Inc.’s Privacy Policy

Last Updated: [January 1, 2020].

Welcome! Thank you for visiting Harvey Nash Inc. (“Harvey Nash,” “we,” or “our”). This Site is owned and operated by Harvey Nash Inc. To help inform you, we provide this notice explaining our information practices on our website (www.harveynashusa.com), 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 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. 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

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, non-discrimination, and opt-out of the “sale” of your personal information. We honor these rights for CA residents and for other U.S. residents to the extent required by applicable law. 

Additional Choices

You can withdraw your consent to the collection of your personal information at any time without affecting the lawfulness of consent-based processing before its withdrawal. 

Tracking Technologies (Cookies)

We use tracking technologies (including cookies) to recognize you, track your visits to our Services, and customize your experience on the Services. For more information about the use of cookies and similar technology on our online services please review this Privacy Policy and our Cookies Policy We offer an opt-out for “sales” of personal information as discussed in Section 4.

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 16. We do not knowingly collect personal information from users within 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 CCPA@harveynashusa.com, or call us at 1-833-496-0299. 

Full Privacy Policy

1. 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 Harvey Nash Group, 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.

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

Collection.

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. 

Personal 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.

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 such as browser cookies, web beacons and similar technologies.

Internet or Other Electronic Network Activity Information: We may collect information regarding your interaction with an Internet Web site, application or advertisement via the devices and computers you use to access 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.

Cookies and Other Tracking Technologies

We use tracking technologies (including cookies, beacons, pixel tags, and scripts) to collect usage information. We may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information. For more information see Section 7 (Tracking Technologies).

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.

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 

Data Retention.

Your information will be retained in accordance with our data retention policy, which is designed to retain data for as long as needed for the purpose(s) for which we originally collected it or for other legitimate business purposes, including to comply with legal, regulatory, contractual, employment and other compliance obligations. 

Where we had limited contact with you, we will retain your data for a maximum of two years from the date of last contact. Where we have engaged with you more extensively—e.g., worked with you as client or interviewed and placed you as a candidate—we may retain your data longer. We will delete your data after that time except where we need to keep it to comply with our legal obligations, to resolve disputes or to enforce agreements.

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 Harvey Nash Group.

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.

Advertising Technology (“Ad Tech”) Vendors and Social Networks: On the Services, we may work with third parties to serve advertisements, provide us with data collection, reporting, and ad response measurement and assist with delivery of relevant marketing messages and advertisements. These third parties may view, set, or edit their own tracking technologies/cookies that are deployed when you visit our Services. The use of these technologies by these third parties is subject to their own privacy policies and we encourage you to review them. They might also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit and other information about you or your device in order to analyze and serve targeted advertising on the Services and elsewhere. For more information about third party ad servers at our Services and your ability to opt-out of targeted advertising from such third parties, please visit Ad Choices.

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 third parties at your specific direction.

  1. Summary of Information Practices in Last 12 Months.

The following table summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Privacy Policy on January 1, 2020. On mobile devices, scroll horizontally to view full table.

Categories of Personal Information

Categories of Sources

Commercial / Business Purpose(s) for Collection

Categories of Vendors (including third parties and service providers) to which Personal Information is Disclosed 

Categories of Vendors (including third parties and service providers) to which Personal Information is Sold

Identifiers

Examples: name, alias, email address, postal address, phone number, IP address, account name, social security number, driver’s license number, passport number, unique personal identifier or tracking technologies (e.g., pixel tags, cookies) to collect usage information. For more information see Tracking Technologies.

  • 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); and 
  • 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 
  • Ad networks, ad tech vendors, social networks, and other marketing and advertising vendors 

  • Data analytics providers 

Other Categories of Personal Information in California Civil Code 1798.80(e)

Examples: bank account number, payroll details and other financial 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

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

  • 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
  • Data analytics providers 

Internet or Other Electronic Network Activity Information

Examples:

  • Information regarding a consumer’s interaction with our Website, mobile application or advertisement
  • 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 
  • Ad networks, ad tech vendors, social networks, and other marketing and advertising vendors 
  • 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
  • Data analytics providers 

Geolocation data

Examples: general location at city level 

  • Cookies (i.e. Google Analytics)
  • Providing, maintaining and improving the Services and products and services 
  • Auditing related to a current interaction with the consumer
  • Ad networks, ad tech vendors, social networks, and other marketing and advertising vendors 
  • 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

  • Data analytics providers 

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 of Personal Information: We do not “sell” your information for money, but we use Google Analytics, an analytics tool, to review browsing behavior, device information, demographic information (i.e. age and gender), location at the city level, acquisition source, and time spent on our Site, which may be deemed a “sale” of personal information under the California Consumer Privacy Protection Act (CCPA). To the extent we use such technologies on the Services, we offer an opt-out as discussed in Section 4. We do not knowingly sell or otherwise disclose the personal information of minors under 16. 

  1. Choices for Access, Deletion, Opt-Out of Sale, 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” about you (as that term is used in the CCPA). Additionally, you have the right to access, delete and opt-out from the “sale” of your personal information. If you are a non-California resident, Harvey Nash will still seek to honor your request to exercise these rights to the extent required by applicable law.

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 CCPA@harveynashusa.com or call 1-833-496-0299. In response, we will produce an Access Report detailing the personal information we have collected, disclosed, and/or sold 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 CCPA@harveynashusa.com, or call 1-833-496-0299. Note, we may need to retain certain personal information as permitted by law to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.
  • How to Opt-Out of the Sale of Personal Information: We offer an opt-out from the use of cookies and other tracking technologies in connection with our Services, which may in some cases constitute the sale of your personal information under the CCPA or other privacy laws. This will cause information to cease to be added to any cookies or other tracking technologies that have been set on our Services or block them entirely. Please note, you will need to opt-out again if you visit one of our Services from a different device or browser if you clear your cookies.

Right to Non-Discrimination: You have the right to be free from being discriminated against for exercising any of your CCPA rights, including being denied services, being charged different prices for services, being provided a different level or quality of services, or being suggested that you will receive a different price for services or level or quality of services. 

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 can use an authorized agent to make requests on your behalf. But we may require the agent to provide a written permission and verify his/her identity or demonstrate that he or she has power of attorney in connection with a request for access or deletion. 

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

  1. 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).

  1. Additional Choices.

If you have consented to our collection of your personal data for multiple specific purposes or explicitly consented to our collection of special/sensitive categories of personal data (i.e., personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) your consent can be withdrawn at an any time without affecting the lawfulness of processing based on consent before its withdrawal.

For information about how to access, delete, or update your personal information or opt-out of the sale of your personal information, go to Section 4. (Choices for Access, Deletion, Opt-Out of Sale, and Right to Non-Discrimination for California Residents or as Required by Law).

  1. Tracking Technologies (Cookies).

When you visit the Services, we may use tracking technologies provided by Google Analytics to enhance your online experience or customize our offerings.

A few additional important things you should know about our use of tracking technologies (cookies):

  • We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the services. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
  • You may encounter tracking technologies/cookies from our service providers, that we have allowed on our site that assist us with various aspects of our website operations and services, such as Google Analytics. 
  • You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another user, there may be a cookie placed by that web page).

For more information about the use of cookies and similar technology on our online services please review this Privacy Policy and our Cookies Policy

  1. 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.

  1. 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. If you believe that your login credentials have been compromised, please contact us as indicated in the Contact Us Section below.

  1. Children’s Privacy.

The Services is a general audience site and it is not intended for individuals under the age of 16. We do not knowingly collect personal information via our websites, applications, services, or tools from individuals under 16 years old. 

  1. 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.

  1. 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 CCPA@harveynashusa.com or calling us at 1-833-496-0299.