Effective Date: March 16, 2021
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or
- Contact data, such as your first and last name, email address, professional title, and
- Account data, such as your username and password that you set to establish an account on the
Service, and your account settings.
- Profile data, such as your contact data, gender, work experience, education, biographical or
employment narrative, locations, your custom Talentsky URL, photograph, links to your profiles
on social networks and other third party sites, interests, preferences, companies and/or
individuals you follow, and any other information that you add to your account profile.
that you choose to create through or upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload. For example, content may include professional mentor profiles that you create and invite others to join, tasks or job responsibilities that you associate with your mentor profiles or profile, Achievements that you create to tell stories of your achievements or experiences, or your professional skills that you identify.
- Data about colleagues, such as name, email address and account settings, that you provide to
create Talentsky user accounts for them when you are an administrator of an enterprise
- Communications that we exchange, including when you contact us with questions, feedback, or
- Payment data needed to complete your orders (including name, payment card information and
billing information) and your purchase history.
- Marketing data, such as your preferences for receiving communications about our products,
services, activities, events, and publications, and details about how you engage with our
- Other information that we may collect which is not specifically listed here, which we will use as
Data from other sources. We may combine personal information we receive from you with personal
information we obtain from other sources.
- Other users of the Service, who can interact with you such as by following you, rating and
submitting feedback on your skills, and suggesting Achievements to you.
- Your employer or organization,
who can create an account for you, associate your account with the employer or organization, add you to mentor profiles, and otherwise interact with you on the Service.
- Public sources, such as social media platforms, publications, and news sites.
- Business partners, such as joint marketing partners.
Automatic data collection. We, our service providers, and our business partners may automatically log
information about you, your computer or mobile device, and your activity over time on our Service and
other sites and online services, such as:
- Device data, such as your computer or mobile device operating system type and version
number, manufacturer and model, browser type, screen resolution, IP address, unique
identifiers, the website you visited before browsing to our website, and general location
information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or
screen, navigation paths between pages or screens, information about your activity on a page or
screen, access times, and duration of access.
Cookies and similar technologies. Like many online services, we use the following technologies:
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the
visitor’s browser or to store information or settings in the browser for the purpose of helping
you navigate between pages efficiently, remembering your preferences, enabling functionality,
helping us understand user activity and patterns, and facilitating online advertising.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a
webpage or email was accessed or opened, or that certain content was viewed or clicked.
How we use your personal information
We use your personal information for the following purposes or as otherwise described at the time we
Service delivery. We use your personal information to:
- provide, operate and improve the Service and our business;
- establish and maintain your user profile on the Service;
- calculate and display on the Service your “score” for certain skills and your ranking relative to
provide you with suggestions, such as new skills and mentor profiles you may be interested in;
- enable security features of the Service, such as by sending you security codes via email, and
remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending announcements, updates,
security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our
- provide support for the Service, respond to your requests, questions and feedback.
Research and development.
We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We and our third party partners may collect and use your personal
information for marketing and advertising purposes:
- Direct marketing. We may send you Talentsky-related or other direct marketing
communications as permitted by law. You may opt-out of our marketing communications as
described in the Opt-out of marketing section below.
- Interest-based advertising. We may contract with third-party advertising companies and social
media companies to display ads on our Service and other sites. These companies may use
cookies and similar technologies to collect information about you (including the device data,
online activity data and/or geolocation data described above) and your interactions over time
across our Service, emails and other sites and services, and use that information to serve ads
that they think will interest you. You can learn more about your choices for limiting interest-
based advertising, in the Your choices section below.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and
defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal
activity, including cyberattacks and identity theft.
How we share your personal information
Your employer or organization. If you are provided access to Enterprise functionality on the Service by your employer, it may control which features and information are available to you and may be able to view or access information related to your use of the Service. Your employer or organization can terminate your access to and use of the enterprise portion of your account.
Other users and the public. Your profile, which includes your name, career experiences, education, as well as your followers and other users or entities that you follow, are visible to other users of the Service and the public. You may choose to make visible to other users or the public your content posts and achievement posts, which you can control in your account’s privacy settings. Any content or activity that you do not make private in your account settings will be associated with your profile information and can be collected and used by others. We cannot control who reads the information that you make viewable or what they may choose to do with it.
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as information technology, hosting, email delivery, marketing, and website analytics).
Advertising partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads on their platforms to those customers and similar users.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the purposes described in the Compliance and protection section above.
Business transferees. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Talentsky (including, in connection with a bankruptcy or similar proceedings).
You have the following choices with respect to your personal information.
Privacy settings. Your name, job title and place of work are visible to other users of the Service and the public. You may choose to make visible to other users or the public your other profile information as well as your Achievements, posts, users you follow, your followers, comments and other content that you create on the Service, which you can control in your account’s privacy settings.
If you follow a Premium Mentor Profile, your skill matching analysis will be visible to that Skill Mentor and the organization where their email is verified, if that organization has paid for enterprise analytics. Unfollowing a Mentor Profile removes your data from the Skill Mentor’s view and, if applicable, the organization’s view.
You can block other users, and report other accounts or specific messages if you think they involve improper or illegal behavior.
Deactivate or delete your account. You can choose to deactivate your account in your settings page. If your account remains deactivated for more than 30 days, we will delete your account. We may retain some information associated with your account for compliance, audit and recordkeeping purposes where permitted by law.
Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive service-related and other non-marketing emails.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. We use Google Analytics to help us understand user activity on the Service. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Service by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.
How to contact us
You can reach us in the following ways:
- Email: email@example.com
Attention: Privacy Department
4546 El Camino Real, Suite B10-316
Los Altos, CA 94022
The information provided in this section applies only to individuals in Europe.
We have appointed a Data Protection Officer, whose contact information is: Rizwan Ahmed, firstname.lastname@example.org.
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Talentsky has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) - UK Representative
Pursuant to Article 27 of the UK GDPR, Talentsky has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
- by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
|Personal Information||Processing purpose||Legal basis|
|Account data||Service delivery||Performance of our contract with you|
|Profile data||Service delivery||Your consent|
|Content||Service delivery||Your consent|
|Data about colleagues||Service delivery||Performance of our contract with you|
|Communications data||Service delivery / Marketing and advertising||Performance of our contract with you / Our legitimate interests|
|Payment data||Service delivery||Performance of our contract with you|
|Marketing data||Marketing and advertising||Our legitimate interests|
|Device data||Research and development||Our legitimate interests|
|Online activity data||Research and development / Compliance and protection ||Our legitimate interests / Compliance with our legal obligations|
|Other information||All of the purposes listed above||Our legitimate interests|
Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
Automated Decision-Making and Profiling. We may use automated decision-making in regard to your personal information for some services, for example creating your skill matching analysis. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision-making and/or profiling by contacting us at email@example.com.
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. If you are located within Europe, you may ask us to take the following actions in relation to your personal information that we hold:
You may submit these requests by email to firstname.lastname@example.org or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Cross-Border Data Transfer
We are based in the United States and we store and retain your personal information in the United States and elsewhere outside Europe in countries not deemed by the European Commission to provide an adequate level of personal information protection. As you are providing us directly with your personal information this is not considered to be a transfer of personal information out of Europe and so we do not need to put in place a specific mechanism to transfer your personal information out of Europe.