Privacy Policy

Wilson Human Capital Group, Inc. (hereinafter referred to as “WilsonHCG” or “we” or “us” or “our”) and its subsidiaries and affiliates respects the privacy of our users. This Privacy Policy applies to “you” our clients, business partners, candidates, anyone using our website (“users”), suppliers and any other third parties with whom we may work or to whom we supply our services, including recruitment. We have a separate Privacy Policy for our employees, which is provided to the employee and accessible to them on our intranet.

Introduction

We strive to protect the personal information that we may collect about our users, under our control and take certain precautions to help maintain the security and accuracy of the data. When you use this website, you trust us with information about you.

Subsequently, you may provide us with personal data. Because your privacy is important to us, we recommend you read this privacy policy (“Privacy Policy”) so that you understand our approach towards the use of your personal data and contact us if you have any questions.

All the terms and conditions in this privacy policy are generally applicable to United States and Canada.

In general, our privacy practices conform with local laws and regulations, including where applicable the provisions of the California Consumer Privacy Act (CCPA) and the Nevada Privacy Law (SB 220). However, where specifically identified, certain jurisdictions will have variations and differences about their jurisdictional privacy practices. Those differences are indicated in the following heading(s): XV. CANADA’S POLICY.

Important information about our global websites

We are a global organization, and we aim to comply with the legal requirements of each individual country. Therefore, we provide regionally specific privacy policies. Please read the privacy policy on our website applicable to you.

This Privacy Policy also describes how you can contact us about our privacy practices and to exercise your rights.

Lastly, we use cookies on our website - please refer to “Section XII. Cookie Policy” contained herein.

Who are we?

We provide recruitment processing outsourcing services, consulting, reporting, talent mapping, employment branding, analysis, fixed term contract services, executive search, perm search, and other recruitment related services.

North America

• Claro Analytics Inc.
• WilsonHCG Canada Inc.
• WilsonHCG Canada Holdings, Inc.
• WilsonHCG Mexico S DE RL DE CV
• Wilson Worldwide, LLC DBA WilsonCTS
• Wilson Contingent Talent Solutions, Inc.
• Wilson Human Capital Group, Inc.
• Wilson RPO Holdings Inc.
• Mackenzie Ryan Holding Company, LLC
• Sales Consultants of Cary, LLC
• CESG, LLC

EMEA

• CPH Consulting Limited
• WilsonHCG EMEA Limited
• WilsonHCG España Sociedad Limitada
• WilsonHCG France
• WilsonHCG Ireland Limited
• WilsonHCG Poland Sp.zo.o
• WilsonHCG Talent S.R.L.

Africa

• Tracking Talent Proprietary, Ltd.

APAC

• WilsonHCG Hong Kong Limited
• WilsonHCG Talent Japan KK
• The Profile Group (HK) Limited
• Profile Search & Selection (Singapore) Pte. Limited
• The Profile Group (Shanghai) Limited
• The Profile Group Shanghai Limited Beijing Branch
• WilsonHCG Philippines, Inc.

Personal data information you provide to us or we collect

Our site does not automatically collect any individually identifiable information from visitors. The information collected depends on the nature of how you choose to interact with us and services you use. In most cases, we may obtain personally identifiable information about you only if you elect to give us that information. The personal data we may collect includes:

• Contact details (particularly name, company/employer name, address, telephone number and email address)
• Demographic data
• Occupational data
• Candidate recruitment data for job opportunities including role, skill set, education, experience, work history and any other data required in the recruitment process
• Identification information (including job title, place of employment, experience and or skill set)
• Personal information obtained through submission of a job application on our site, CV, resume or transcripts, and any supporting documentation attached to your resume such as copies of certificates and diplomas
• Information obtained while conducting a phone interview, video interview, in-person interview, or interview through one of our third-party interview and recruitment service providers
• Reference check information, such as a verification of your educational and professional background, and other relevant information subject to WilsonHCG policies and applicable laws
• Billing information for payment for suppliers (particularly bank account numbers and information and tax information for payments, deposits or other pre-approved financial transactions)

You can engage with us through social media websites, such as Facebook, LinkedIn, Twitter, Instagram, YouTube, Human Capital Connection blog, or through features at WilsonHCG.com that integrate with social media sites.

If you use these websites, we will be able to access basic information from your social media profiles. Such information may include your name, email address, gender, pictures, geographic location or posts you write.

In addition to the information you provide, or accessed through social media websites, WilsonHCG may collect information from commercially available sources that it deems credible. Such information may include your name, address, email address, demographic data and occupation.

The above information may be stored in internal systems, such as client relationship management (CRM) and talent acquisition software (TAS) applications, on secure servers that are not accessible by third parties.

These systems permit WilsonHCG employees to access and process such data solely for the purposes of customer fulfillment, business administration, business reporting, statistical analysis and marketing of WilsonHCG products and services.

We do not sell or rent our mailing lists to external organizations. We will not disclose your personal information to third parties, except with your consent or as required by law.

How we use personal data

Our collection and/or use of personal data may include the following:

• Share within our internal teams and with our clients for recruitment purposes
• Communicate with you, including to let you know about important changes and/or notifying you of content published by WilsonHCG which is likely to be relevant and useful to you
• Assess your ability and suitability for the employment position(s) you are interested in if you are a candidate
• Provide our services to you as and when you ask us and to fulfil our contractual obligations to you (for example, supplying candidate data to prospective employers)
• Fulfil our contractual obligations to suppliers
• Ask third parties to provide services to us including professional advisors, IT (including cloud providers), marketing, recruiting and interviewing software or services, and outsourced services to help run our business properly and efficiently
• Market to you on industry specific content, provided that you consent to this
• Comply with regulations and legislation
• Resolve complaints and issues and establish and defend our legal rights or manage insurance claims in which you are involved
• Manage our business properly and efficiently

To optimize our services, we may use your personal data for direct marketing. We take your privacy seriously and will only use your personal data when you are aware. If required by law, we will request your consent prior to using your personal data for direct marketing.

Additionally, if at any time you wish us to stop using your information for any or all of the above purposes, please CONTACT US as set out below. We will stop the use of your information for such purposes as soon as it is reasonably possible to do so.

Unless specifically stated in this Privacy Policy, we will not disclose any personally identifiable information without your permission unless we are legally entitled or required to do so (for example, if required to do so by legal process or for the purposes of prevention of fraud or other crime) or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and those of our users/customers or other individuals.

Please be assured that we will not use your personal data for any purposes other than indicated. 

Your consumer rights

In addition to the right to receive information contained in this Privacy Policy, the law gives you certain rights in relation to your personal data and you can exercise these rights by emailing us at privacy@wilsonhcg.com

• Right to Know
• Right to Request/Access
• Right to Opt-Out/Or Opt-In
• Right to Request Deletion
• Right to not be discriminated against verifiable consumer request receiving it. If there is going to be a delay in dealing with your request or there is a reason why we can’t comply with your request, we will let you know and explain why within 45 days.

You have the following right(s):

Right to know

You have the right to know the categories of personal information WilsonHCG collects about you. Those categories are described in this policy under both: INFORMATION YOU PROVIDE TO US OR WE COLLECT and HOW WE USE INFORMATION.

WilsonHCG will not collect additional categories of information or use personal information collected for additional purposes without providing you notice consistent with this policy.

Right to request/access

You have the right to request the categories of personal information WilsonHCG collects about you by emailing privacy@wilsonhcg.com.

Right to opt-out (or opt-in)

“Do Not Sell My Personal Information” and/or “opt-out” from “selling” of your personal information is your right as a candidate. You also have the right to opt-out from the subsequent selling of your personal information by a third party that received personal information after an initial “selling.” The third party shall not sell your personal information unless you have received “explicit notice” and you are provided an opportunity to opt-out. You understand that the opt-out can only stop the “selling” of personal information, and it does not impact other uses of their information. You can also opt-out by emailing us at privacy@wilsonhcg.com. Additionally, you do have the right to opt back in (opt-in) at your discretion.

Right to request deletion

Once requested through the website and/or privacy@wilsonhcg.com email account, we will delete your personal information we have collected about you, subject to certain exceptions.

Right to not be discriminated against

WilsonHCG will not discriminate against you for exercising any of your rights under this policy.

Who do we share your personal data with?

When you provide personal data to an individual at WilsonHCG (for example a recruiter) you are providing that information to our whole organization. In addition, we share your personal data with various third parties depending upon your relationship to our company.

You can obtain more information on any providers or suppliers we share your personal data with by requesting a copy of any agents at privacy@wilsonhcg.com.

Where necessary, your personal data may be shared with various third parties including:

• Our third party agents who provide services to us i.e. independent contractors service providers that perform functions on our behalf i.e. payroll, benefits, insurance, and other administrative services;
• Vendors, consultants, and other third party service providers to assist us in providing services on our behalf, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/C.V. data, interviewing, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training
• Third party data storage providers that process data on our behalf i.e. email and storage provider, applicant tracking system
• Potential and active clients we provide recruitment services for, and to match the professional profile we have stored of our candidates in our database to any positions we have been asked to fulfill by any of our clients, and including any related administrative use such as invoicing
• Public authorities that make a lawful request, including to meet national security or law enforcement requirements

Security of your personal information

We have implemented technology, security policies and measures to protect the personal information that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction and accidental loss. To find out more, see below.

This includes:

• Storing personal data in our internal systems (such as client relationship management (CRM) and talent acquisition software (TAS) applications) on secure servers that are not accessible by third parties
• Adhering to the Privacy Principles where personal data is transferred from the European Union to the United States – see our Transferring Personal Data Outside the EU section in the EU Privacy Policy
• Providing internal policies, procedures and training about data protection to our employees
• Restricting access and requiring that all our employees and others who have access to or are associated with the processing of your personal information to sign company confidentiality agreements. Failure to meet these obligations is dealt with under our disciplinary procedure and may result in termination of employment
• Encrypting many of our services using Secure Sockets Layer (SSL)
• Regular reviews of the way we process data in line with our data protection policies

External website links and social media

On our website, we may have links to other websites, or you are referred to our website through a link from another website. Therefore, we cannot be responsible for the privacy policies and practices of other websites.

Such content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their website. Additionally, we do not intend to imply sponsorship, affiliation or endorsement with third party sites.

We recommend that you check the policy of each website you visit to better understand your rights and obligations, especially when you are submitting any type of content on those third party websites. Please contact the owner or operator of such website if you have any questions/concerns.

Collection of non-personal information

We also collect information which does not identify you (non-personal information). This includes the type of internet browser you use or the website from which you linked to our website.

We may also aggregate information which you have submitted to us (for example, your age and the town where you live) which is anonymous - you cannot be identified from this information. We share this aggregate information with third parties (for example to provide salary averages) to help us provide an effective service on our website.

This website uses Google AdWords

Our website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site.

Using Google AdWords means that we can advertise to previous visitors who have begun but not completed an action on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network.

Third-party sellers, including Google, use cookies to serve ads based on someone’s past visits to our website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policies (you can find Google’s Privacy Policy here> www.google.co.uk/intl/en/policies/privacy/)

Cookie policy

What is a cookie?

Cookies are small data files that your browser places on your computer or device.  Cookies help your browser navigate a website and the cookies themselves cannot collect any information stored on your computer or your files.

When a server uses a web browser to read cookies, they can help a website deliver a more user-friendly service. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.

Why do we use cookies?

We use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website.

Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in the comment forms.

Some of the cookies we use are session cookies and only last until you close your browser, others are persistent cookies which are stored on your computer for longer.

How are third party cookies used?

For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third party websites for information regarding their use of cookies. For further details on the third-party cookies that we use, see the third party cookies section below.

How do I reject and delete cookies?

We will not use cookies to collect personal identifiable information about you. However, should you wish to do so, you can choose to reject, or block cookies set by us or the websites of any third party suppliers by changing your browser settings – see the Help function within your browser for further details.

Please note that most browsers automatically accept cookies, so if you do not wish cookies to be used you may need to actively delete or block the cookies. Visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. For information on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to your handset manual.

Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

Third party advertising cookies opt-out

WilsonHCG is dedicated to providing privacy on the Internet. In addition to developing our Privacy Policy, we have provided you the opportunity to opt out of future third party advertising cookies.

WilsonHCG allows third parties to place cookies on our site for advertising purposes. This Privacy Policy does not cover the collection methods or use of the information collected by these third parties. These third parties have their own privacy policies and may be members of the Network Advertising Initiative ("NAI"). To remove yourself from some or all NAI member advertising programs, please visit the NAI Opt-Out Page and follow the relevant instructions. Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser, you may need to renew you opt-out choice.

Data retention

Unless you specifically ask us not to, we will only keep your personal data for as long as it is:

• Necessary for the purposes for which the personal data are processed
• To enable us to comply with our legal obligations, for example for tax purposes

Please refer to our data retention policy and timelines, which are dependent on the nature of our relationship with you. you can request the policy for your region at privacy@wilsonhcg.com

Data Subject	How long personal information/data is kept
Potential Clients	We will retain personal information for the length of time you have consented to, i.e. 2 years from the date of the last time you had contact with us.
Clients	We will retain personal information for 7 years from the date that you ceased to be a client or based upon the legal requirements of your region as specified in the retention policy, whichever is longer.
Potential Candidates who are not placed in employment using our services	We will retain personal information for 2 years from the date of the last consent or based upon consented duration if otherwise.
Candidates placed in employment using our services	We will retain personal information for 7 years from the date that you ceased to be an employee, or the legal requirements of your region as specified in the retention policy, whichever is longer.
Potential Suppliers	>We will retain personal information for 6 months from the date of the last contact or as provided in the consent form if otherwise.
Suppliers	We will retain personal information for 7 years from the date that you ceased to be a supplier or based upon the legal requirements of your region as specified in the retention policy, whichever is longer.

 

Children's policy

We do not collect information from children under 13. If we learn we have collected personal information of a child under 13, or equivalent minimum age of jurisdiction outside the above circumstances, we will take the proper steps to remove this information.

If you believe, at any time, that we have collected information from a child under 13, or you are a parent or guardian that needs to access, correct, or delete their child’s personal data, please reach out to privacy@wilsonhcg.com

Canada policy

The following policies are Canadian jurisdictional privacy practices, which vary from our general privacy practices, and are applicable to only to consumers within Canada.

We strive to comply with PIPEDA (Personal Information Protection and Electronic Documents Act) as well as applicable provincial privacy legislation.

Privacy principles

WilsonHCG follows principles when collecting, using, disclosing and protecting your personal information, which include:

• Accountability– We have an appointed PIPEDA Compliance monitor.
• Identifying Purposes – Under this policy we state the reason for collecting your personal information.
• Consent - We obtain your consent before collecting, using or disclosing your information.
• Limiting Collection - The personal information we collect is only used, disclosed or retained for its original purpose, unless we have your consent, or the information is required to meet legal requirements.
• Limiting Use, Disclosure, and Retention - We limit the personal information we collect to what is necessary for us to conduct business and to serve you to the best of our ability.
• Accuracy - We strive to ensure that the information we have is accurate and up to date.
• Safeguards - We safeguard the privacy of your personal information through security measures.
• Openness - We are open with you about our policies and practices related to managing your personal information.
• Individual Access - Upon request, we can provide you with access to your personal information. You can ask how your information is used, ensure your records are accurate and complete, and update information as necessary.
• Challenging Compliance - We address your concerns. If you have concerns or questions regarding your privacy, we have steps you can follow to make sure your questions are answered to your satisfaction.

Changes to this policy

From time to time we may make changes to this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we use your personal data, we will post these changes on this page. Please check our Privacy Policy on a regular basis.

Contact us

Your information is ultimately controlled by Wilson Human Capital Group, Inc., a company registered in Delaware, USA with registered number 5370276 whose registered office is at: 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808.

We value your opinions and feedback. If you have any questions, comments or concerns regarding our Privacy Policy or data protection, please send them to privacy@wilsonhcg.com or write to us at our corporate office located at 400 North Ashley Dr., Suite 1500, Tampa, Florida 33602

Toll Free number: (888) 204-1070

Policy Title	Non-EU Privacy Policy Non-HR
Scope and Applicability	Your individual privacy is important to us and this Privacy Policy is an overview to explain how we process (collect, use and hold) personal data (any information that identifies or could reasonably be used to identify you). Please read through the policy carefully and if you have any queries please email privacy@wilsonhcg.com or look at the contact us information below.
Status (draft, authorized, superseded, withdrawn)	Authorized
Names of authors and accountable owners	IT and executive committee are the authors of all policies published. The accountable owners include executives and admins on the corporate side of WilsonHCG.
Version numbers	5
Most recent date of publication	October 2020
Approvers (e.g. Security Committee or an equivalent management body)	WilsonHCG uses outside counsel(s) and reputable legal and HR resources to review all policies. We ensure compliance with all laws and regulations as they pertain to the different areas of the business and the different regions we support around the world.
Document history/date of last and next reviews	Reviewed Annually