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Pathfinder/SuccessFinder Privacy Policy
Effective Starting: 24 May 2018

1.                Introduction

Pathfinder Career System (hereafter referred to as “SuccessFinder”, “we”, “us”, “our”) provides a platform through a Software as a Service (SaaS) model, accessed via web browser. At SuccessFinder, we are committed to protecting your privacy and the data you share with us. This privacy policy explains how SuccessFinder processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and platform in accordance with the applicable regulation and standards identified in this Privacy Policy (such as GDPR, for example).

Any information stored on our platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. SuccessFinder implements and maintains appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

2.                General

We do not sell personal information and we share it only with our advisors, suppliers and selected partners and only to the extent it is necessary to facilitate a transaction, or an event related to you. Before you submit any information, we will inform you of the reason we are asking you for specific information, the parties to whom such information may be disclosed, and it is up to you whether or not you want to provide it. You may separately agree to provide your personal information to third parties that provide content for SuccessFinder, in order to access and/or use their products and/or services. If you agree to provide such information to these third parties, then your personal information will be subject to their privacy policies.

In addition to the foregoing, the following are the additional instances where we may disclose your personal information to third parties:

·         To investigate potentially fraudulent or questionable activities regarding your account(s) or the violation of our Terms of Use;

·         In anticipation of and in the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business;

·         When required or permitted by law.

The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested will be disclosed and we will take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so. There are some situations where we are legally permitted to disclose personal information, such as employing reasonable and legal methods to enforce our rights or to investigate suspicion of illegal activities.

3.                Information we collect and use

3.1 Participants

A Participant is a person who has completed a SuccessFinder assessment on the SuccessFinder platform.

Content and information submitted by Participants is referred to in this policy as “Participant Data.” Participant Data is controlled by a Client organization or other third party (ex: an independent practitioner, a consulting firm) for whom the client account was created (the “Client”). When SuccessFinder collects or processes (SF is the Data Processor) Participant Data, it is doing so on behalf of the Client (client is the Data Controller).

Personal Information We Collect

We collect your name, email address. This information is used to create the base Participant account. We collect the password you provide to access your account.

We gather your responses to the items in the SuccessFinder Assessment.  The purpose of the SuccessFinder platform, is to assess an individual’s behavior profile through our assessment. Your responses to the SuccessFinder assessment and the related results will be saved in your profile account on our system.

As a Participant you are also be provided with the option of also providing Sociodemographic data (age, gender, ethnic background, etc.). This is optional for research purposes, to maintain and improve the psychometric qualities (reliability and accuracy) of the assessment we offer, to ensure the assessment is fair and objective in the assessment of individuals, to develop and improve the products we offer. Sociodemographic data collected will only be used anonymously (no personally identifiable information in our research) and will not be made available to external parties, including an employer or client account user.

We may also automatically collect the following information from you:

·         Platform usage information - This is information about how you are accessing and using the platform, which may include administrative and support communications with us.

·         Log data - When you use the SF platform our servers automatically record information, including information that your browser sends whenever you visit a website. This log data includes your Internet Protocol (IP) address, your browser type and settings, the date and time of your use of the platform, information about your browser configuration and plug-ins, language preferences, and cookie and all similar cache data.

·         Device information - We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data (depending on what type of device you are using and its settings)

·         Geo-location information - Precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine your approximate location.

3.2 Client Users

A Client is an organization or other third party (ex: an independent practitioner, a consulting firm) under contract or in a business relationship with SuccessFinder.

If you have access to a Client Account on our platform, you are a “Client User” who has been given access by invitation of a Client. The client may be your employer, another organization, or an individual, and that client determines, through the Client Organization Consent form and the main agreement with SuccessFinder, what its policies are regarding data access, deletion, sharing, and retention of Participant Data. This may affect to your use of the platform, so be sure to check with the client organization who gave you access about their policies.

We collect your name, email address. This information is used to create the base Client User account. We collect the password you provide to access your account.

·         Platform usage information - This is information about how you are accessing and using the platform, which may include administrative and support communications with us.

·         Log data - When you use the SF platform our servers automatically record information, including information that your browser sends whenever you visit a website. This log data includes your Internet Protocol (IP) address, your browser type and settings, the date and time of your use of the platform, information about your browser configuration and plug-ins, language preferences, and cookie and all similar cache data.

·         Device information - We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data (depending on what type of device you are using and its settings)

·         Geo-location information - Precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine your approximate location.

 

4.                How we use your information

4.1 . Participant Data

SuccessFinder may access and use Participant Data as reasonably necessary and in accordance with the Client’s instructions to (a) carry out service agreement with the Client (provide access through the platform to their participant’s data); (b) to prevent or address service, security, technical issues or at a Client User or participant’s request in connection with Client support matters; (c) as required by law and (d) as set forth in our agreement with the Client or as expressly permitted in writing by the Client.

We use other kinds of information in providing access to our solutions and technology.

We communicate with you by:

·         Responding to your technology support requests. If you contact us directly with a problem or question, we will use your information to respond.

We may also use account data to administer accounts and keep track of client billing and payments.

Client and Participant Choices

The Client organization provides us with instructions on what to do with Participant Data. A Client has many choices and control over participant data. For example, Clients may provision or deprovision access to the platform (including different features and data access) to client account users, manage permissions (who else in an organization is authorized to view reports), retention and export settings. These choices and instructions may result in the access, use, disclosure, modification or deletion of certain or all Participant Data, over which SuccessFinder has no control.

You can update certain Personal Information directly in your account settings at any time. For other information that cannot be directly updated by you, please contact us and we will respond to you within 2 business days.

Other choices not controlled by SuccessFinder

In addition, the browser you use on your device may provide you with the ability to control cookies or other types of local data storage, or other choice around how and whether location or other data is collected and shared. SuccessFinder does not control these choices, or default settings, which are offered by makers of your browser or device operating system.

Sharing and Disclosure

SuccessFinder does not share participant or client information with third parties for purposes except as described in this policy. We will never share, sell, or rent your personal information to third parties for promotional use. Note that Clients determine their own policies for the sharing and disclosure of any Participant Data or reports, which SuccessFinder does not control.

Participant Data

SuccessFinder may share Participant Data in accordance with our agreement with the Client and the Client’s instructions, including with third-party integrations. Acting on our Client’s behalf, SuccessFinder may share Participant Data with the provider of an integration added by Client (ex: HRMs). The third-party provider of the integration may share certain information about your account with SuccessFinder. However, we do not receive or store your passwords for any of these third-party services. SuccessFinder is not responsible for how the provider of an integration service may collect, use, and share Participant Data.

Should you contact SuccessFinder to help resolve a technical issue, we may need to share this information with the Client to help resolve the issue.

SuccessFinder may share or disclose participant Data and other information as follows:

·         During changes to our business structure. As we continue to grow and develop our business, we might sell or buy other sites, subsidiaries or business units or divisions. In such transactions, your personal information generally is one of the transferred business assets, but the acquiring organization will be bound by our Privacy Policy and such information will only be used in a manner consistent with purposes for which you provided your information.

·         To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.

·         To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

Aggregated or Anonymized Data

We may disclose or use aggregate or de-identified information for any purpose. For example, we may share aggregated or de-identified information for business (like reporting on the number of assessments completed per month, the speed at which assessments are completed) or research purposes (like improving our expert model or reporting on adverse impact research). This information will not include Personally Identifiable information on a Participant.

4.2.          Client User Data

We use Client User data to communicate with you by:

·         Sending emails.  SuccessFinder may send emails to client users related to accessing and using their account. We may also contact you to inform you about changes in our platform, important platform related notices, such as security notices. These emails and messages are considered part of the platform technology and you may not opt-out of them.

sites.

5.      Cookies and Related Technologies

Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer.

SuccessFinder uses “cookies” and similar technologies to provide access to and support our platform such as measuring traffic patterns, personalizing content, and controlling security. The cookies we use supply non-personally identifiable information, but they may identify your computer, browser and Internet specifications.

Other examples of information collected and analyzed include the Internet protocol (IP) address used to connect your computer to the Internet, login info, e-mail address, computer, and connection information such as browser type and version, operating system and platform.

6.      Data Storage, Transfer and Security

SuccessFinder takes security very seriously. Our development and operations teams work to protect the information provided from loss, misuse, and unauthorized access or disclosure using a variety of industry-standard administrative, physical, and security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. These steps consider the sensitivity of the information we collect, process and store.

Our development, operations and security teams ensure the continuous monitoring and development of the platform to ensure it is secure and to prevent abuse and fraud.

SuccessFinder hosts data with hosting service providers in Canada. The servers on which Personal Information is stored are kept in a secure, controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be safe from intrusion by others, such as hackers.

Where Downloadable Products are used, responsibility of securing access to the data you store in the Downloadable Products rests with you and not SuccessFinder. We strongly recommend that you protect your data against unauthorized access to your password and to your computer or device.

Confidentiality. SuccessFinder’s personnel are required to enter in confidentiality agreements restricting the distribution of any confidential information (including personal information).

7.      Minors

We do not process any data concerning minors (under the age of 16) nor are our solutions directed to minors. If you learn that a minor under age 16 has provided us with personal information without parental consent, please contact us.

8.      GDPR

SuccessFinder Client as Controller

In the course of our Clients’ use of the SuccessFinder platform, Client will dictate and control what data elements are to be processed by SuccessFinder. As a result, Clients will be responsible for their obligations as Controller of Personal Data as defined in the General Data Protection Regulation (“GDPR”).

SuccessFinder as Processor

SuccessFinder shall process Personal Data in its role as Processor in accordance and as defined in the GDPR; and as described in this Privacy Policy.

All processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation.

From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the GDPR and SuccessFinder’s processing will take place in accordance with the GDPR.

Should Clients require SuccessFinder’s help in responding to a participant request as it relates to GDPR, they should contact info@successfinder.com.

8.1  Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Contact support@successfinder.com for assistance.

To the extent that SuccessFinder’s processing of your Personal Data is subject to GDPR, SuccessFinder relies on its legitimate interests, described above, to process your data.

Data Subjects are encouraged to notify the Client (Data Controller), that is, the organization that mandated the assessment, whenever they intend to exercise their rights under the GDPR. Visitors and Participants may notify SuccessFinder at info@SuccessFinderinc.com to exercise the rights below.

As for Clients, SuccessFinder can be notified through its named support portal to handle such requests. If at any time SuccessFinder receives a request from a Client-User, SuccessFinder will notify Client as soon as reasonably possible.

Subject to applicable law, you also have the right to

                 I.            restrict SuccessFinder’s use of Other Information that constitutes your Personal Data and

               II.            lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our lead supervisory authority.

8.2.     Data Protection Officer

We have appointed a Data Protection Officer (DPOs) to be responsible for the privacy program at SuccessFinder. You can contact our DPO via email at the following address:

dpo@successfinder.com

9.      Changes to this Privacy Policy

This policy is subject to change from time to time. Should that be the case, we will post any changes directly on this page and you can become aware of this by revising the “Effective Starting” date. If you continue to use our platform after those changes are in effect, you are agreeing to the revised policy terms. We therefore encourage you to review our Privacy Policy whenever you use our platform to stay informed about our information practices and the ways you can help protect your privacy.

10. Contacting Us

Please also feel free to contact us if you have any questions about our Privacy Policy or practices. You may contact us at info@successfinder.com or at our mailing address below:

SuccessFinder Inc.

2170 boul. René-Lévesque Ouest, Suite 202

Montreal, Qc

H3H 2T8, Canada

Tel.: 1-844-932-9231

 

© 2018, SuccessFinder Inc.

 

Pathfinder Career System 2018 ©
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