PRIVACY POLICY

This Privacy Policy discloses the privacy practices for HBPad Consulting, LLC (referred to as “us” or “we”) provides the http://www.hbpad.com/ website and affiliated mobile application (referred to as this “Site”). We are the provider of the Services (as defined below) and are committed to protecting your privacy online. Please read the information below to learn the following regarding your use of our Services. You acknowledge that this Privacy Policy is part of our General Terms of Use, and by accessing or using our Services, you agree to be bound by all of our terms and conditions. If you do not agree to these terms, please do not access or use our Services.

Services

We offer a variety of Services (referred to singularly as a “Service,” or collectively as the “Services”) through the Site including the following:

Staffing Services. We offer Information Technology (“IT”) and business recruiting Services across North America, Europe, and Africa. These Staffing Services are subject to additional staffing terms and conditions https://hbpad.com/terms-and-conditions/ which are incorporated herein by reference.

Consulting Services. IT consulting and digital transformation, cyber security, sales of  IT hardware and software (“Consulting Services”). These Consulting Services are subject to additional consulting terms and conditions https://hbpad.com/terms-and-conditions/ which are incorporated herein by reference.

Training Services. Our platform hosts a variety of professional development and certification programs (“Training Programs”). These Training Programs are taught by experts in their respective fields and are subject to additional training terms and conditions https://hbpad.com/terms-and-conditions/ which are incorporated herein by reference.

Verification Services. We partner with third party verification Services for the verification of candidate employment, education, skills and certifications (“Verification Services”). These Verification Services are subject to additional verification terms and conditions https://hbpad.com/terms-and-conditions/ which are incorporated herein by reference.

And all of our Services are subject to our General Terms and Conditions, which are incorporated herein by reference.

1. How Do We Protect the Data We Collect

We attach great importance to your right to privacy and the protection of your personal information. We want you to feel secure that when you deal with us, your personal information are in good hands. We protect your personal information in accordance with applicable laws and our data privacy policies. In addition, we maintain the appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how we process your personal information:

1. What Categories of Information Do We Collect

We collect personal information of our clients, candidates and their current/former/prospective employees, business contacts, and website users. If the data we collect are not listed in this Privacy Policy, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used.

Below is also a chart describing the categories of personal information we collect if you decide to provide it. You do not have to provide it, but some of the Services may not be available to you if you do not.

We may make inferences about you and collect additional information as described in this Privacy Policy. If you share someone else’s personal information with us, you must ensure they are aware of this notice and have consented to sharing.

We obtain personal information directly from you (such as when signing up for a newsletter or registering on our site) or indirectly from third parties, including affiliates, public authorities, social media, suppliers, clients, vendors, and acquisition targets. Providing personal information is voluntary unless required by law or policy, but without certain data, some purposes or features outlined in this Privacy Policy may not be available to you.

1. How We Use the Information

We use your personal information only where required for specific purposes. Please view the table below for (i) a list of the purposes for which we use your personal information and (ii) an overview of the legal basis for each such purpose.

“Legitimate interest” means that we have reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity.

We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept,” “I agree” or similar buttons/checkboxes/functionalities in relation to a Privacy Policy, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.

We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g., in case of a medical emergency) to do so.

1. What Information Do We Share

We may transfer personal information to our business clients, service providers, professional advisors, public and governmental authorities, or third parties in connection with our operation of our business, including any (potential) corporate or commercial transaction and including clients if the data has been processed to provide client services. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal information will be given adequate protection as required by relevant data privacy laws and our internal policies. We may also transfer your personal information to any of our global affiliates/partners.

For example, we may disclose personal information to third parties for other business purposes as follows:

• We share your information with third-party providers for billing, payments, customer service, marketing, security, account maintenance, order processing, verification, research, data hosting, auditing, and other data-related services.
• To protect and defend the legal rights, safety, and security of us, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
• For other business purposes described in this Privacy Policy or for any other purpose disclosed to you at the time we collect the information pursuant to your consent. We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

1. Sensitive Data

The term “sensitive data” refers to the various categories of personal information identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offenses (including information about suspected criminal activities).

We do not generally collect “sensitive data,” but if we do, we will ask your consent.

1. Data Security

We use industry standard measures and technical security arrangements to protect all of the data we hold.

1. Data Processing Location

As an international organization, personal information we collect may be transferred or be accessible throughout our global business network. Any transfers of personal information will take place in accordance with our internal policies and procedures, and any applicable laws.

1. Sources of Personal Information

Most of the personal information we obtain comes directly from you. Other sources, though, may include publicly available sources (e.g., the internet), former employers, former educational institutions.

1. How Long We Retain Your Personal Information.

We will retain your personal information only for as long as is necessary. Personal information may be deleted after a reasonable time according to the following retention criteria:

• We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
• We will only keep the data while your account is active or for as long as needed to provide services to you.
• We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

1. What Are My Rights In My Personal Information

You are entitled (in the circumstances and under the conditions, and subject to the exceptions set out in applicable law) to:

• Request access to your personal information: Find out if we hold your data and get a copy if we do.

• Request correction: Ask us to fix or complete inaccurate personal information.

• Object to processing: Tell us to stop processing your personal information.

• Request erasure: Ask for your personal information to be deleted when it is no longer needed.

• Request restriction: Limit our processing of your personal information, including with your consent.

To the extent that the processing of your personal information is based on your consent, you have the right to withdraw such consent at any time by contacting us at privacy@hbpad.com. Please note that this will not affect our right to process personal information obtained prior to the withdrawal of your consent, or our right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal information, you believe that your privacy rights have been violated, we encourage and welcome individuals to come to us first to seek resolution of any complaint.

2. How Do We Use Your Personal information When You Visit the Site

We collect personal information from the Site in four ways: (1) directly (for example, when you provide personal information to sign up a candidate; (2) from your employer; (3) indirectly (for example, through our website’s technology); and (4) from your education establishment (which may include formal education establishments, trade schools, any place you learned a skill, etc.).

We may collect and process the following personal information:

• Personal information that you provide by filling in forms on our Site. This includes registering to use the Site, Services, registering for alerts, or participating in other services we may offer from time to time.
• If you contact us, we may keep a record of that correspondence.

• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

• Any postings, comments or other content that you upload or post to our Site.

• The Site may collect information related to your computer or mobile device, such as IP address, operating system, device type, device identification number, mobile operating system, and browser type. This data is used for system administration, traffic filtering, user domain lookup, and statistical reporting.

• Details of your visits to our Site, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data.

Our Site may also include:

• Links to and from the sites.

• Some third-party widgets and apps may collect your personal information and use it for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs. 

3. How Do We Use Cookies and Other Tracking Technologies

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

We utilize your IP address and browser details to assess the effectiveness of our website, enabling us to identify areas for enhancement. This analysis supports our efforts to customize the site and deliver a more relevant and beneficial user experience. For more information about our use of Cookies, please see our Cookies policy.

4. How Do We Use Personal information for Marketing Purposes

In addition to the information set out above, the following sections describe how we use personal information for marketing purposes.

1. Where Do We Get the Marketing Data

The majority of personal information collected and utilized for marketing is associated with employees of our clients and other organizations with whom we maintain established business relationships. Additionally, we may source contact information from publicly available resources, including information shared on social media platforms, for the purpose of initiating contact with appropriate representatives at client companies or other organizations.

1. Targeted Emails

Commercial emails are sent to individual clients, individuals at client companies or other organizations for business development or maintenance, following applicable marketing laws. These targeted emails often include web beacons, cookies, and related technologies to determine whether recipients open, read, delete the messages, or click links. Clicking a link in a marketing email from us activates a cookie that records which pages are viewed and what content is downloaded from the website, regardless of registration status or user sign-in.

Targeted e-mails from us may include additional data privacy information, as required by applicable laws.

You may adapt your contact, content and data preferences by contacting us at privacy@hbpad.com.

1. Push Notifications

When you use our mobile applications, you may receive notifications related to industry topics you select within the app or information about live events. With your consent through app permissions or settings, push notifications or alerts may be sent to your mobile device even if you are not logged in. Notification preferences can be managed or deactivated at any time by adjusting the notification settings in the mobile app or in the device settings/app permissions on your mobile device.

1. Customer Relationship Management (“CRM”) Databases

The company utilizes CRM database technology to organize and monitor marketing activities. These databases contain personal information related to individual clients, as well as individuals at client companies with whom there is an existing or prospective business relationship. The personal information processed may include business-related information such as contact details, publicly available information (for example, board memberships, published articles, press releases, or relevant social media posts), responses to targeted emails (including web activity from email links), website activity of registered users, and other business information provided by staff through interactions.

1. Combination and Analysis of Personal Information

We collect data from publicly available sources, as well as from interactions via email, websites, and other personal communications. This may include information gathered from our various sites, such as careers and corporate websites, and data collected when users register, log in, or access our platforms through social media credentials. We use this combined data to evaluate user interactions and conduct activities outlined in our privacy policy.

You may adapt your contact, content and data preferences by contacting us at privacy@hbpad.com.

1. Sharing Personal Information with Third Parties

In addition to the third parties mentioned  above, we may share your personal information with marketing agencies.

1. Rights Regarding Marketing Communications

Individuals may prevent receiving marketing communications by selecting appropriate options on forms used to gather personal information or by using opt-out features provided in emails. In these instances, a minimal amount of personal information will be retained solely to record the opt-out request and avoid future contact.

UNITED STATES REGIONAL PRIVACY STATEMENT

This PRIVACY NOTICE applies solely to visitors, users, and others who reside in the States of California, Utah, Virginia, Texas, Connecticut, Colorado and any other states with individual privacy rights (“consumers” or “you”). We adopt this notice to comply with the appliable privacy laws thereto. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this notice. 

Information We Collect 

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include the following: 

1. Publicly available information from government records.
2. De-identified or aggregated consumer information.
3. Information excluded from the applicable law’s scope, like:
   1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), a state equivalent or clinical trial data;
   2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or applicable state law, and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

1. Directly from you or our service providers.
2. Indirectly from our Consumers. For example, through information we collect from our Consumers in the course of providing services to them.
3. Directly and indirectly from activity within our Site. For example, from submissions through our Site or Site usage details collected automatically.

Use of Personal Information 

We may use or disclose the personal information we collect for one or more of the following business purposes: 

1. To fulfill or meet the reason for which the information is provided. 
2. To provide you with information, products or Services that you request from us, or otherwise communicate with you.
3. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
4. To improve our Site and present its contents to you.
5. To promote safety, security and integrity.
6. For analytics, testing, research, analysis and product or Service development.
7. As necessary or appropriate to protect the rights, property or safety of us, you, our service providers or others.
8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
9. As described to you when collecting your personal information or as otherwise set forth in the applicable law.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

Sharing Personal Information 

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

1. Category A: Identifiers.
2. Category B: Customer Records personal information categories.
3. Category D: Commercial information
4. Category F: Internet or Similar Activity
5. Category G: Geolocation data
6. Category I: Professional or employment-related information
7. Category J: Non-public education information
8. Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties: 

1. Our affiliates.
2. Our clients
3. Our service providers.
4. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Your Rights and Choices 

Applicable law provides consumers (residents of the aforementioned states) with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: 

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we share that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we sold or disclosed your personal information for a business purpose, we will disclose two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose or identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable 

consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug the Services or other products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with any applicable law.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Request a Correction

You have the ability to correct a lot of your personal information, as it is accessible in your user profile. You also have the right to request that we correct inaccurate personal information, which  can be made directly to us at privacy@hbpad.com.

Right to Opt Out of Targeted Advertising

The right to opt out of the processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising may be made directly to us at privacy@hbpad.com.

Exercising Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through our Site.

Only you or a person registered with the state where you reside that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must: 

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Non-Discrimination 

We will not discriminate against you for exercising any of your rights. Unless permitted by the applicable law, we will not: 

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice 

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our Site. 

Contact Information 

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us through the Site using “ATTENTION: PRIVACY COMPLIANCE OFFICER” in the message. You may reach us at privacy@hbpad.com.