Privacy Policy

High5 and its group companies, (collectively,“High5”, or “we”) are committed to safeguarding your privacy. In this Online Privacy Notice (“Notice”) we explain to you what information we may collect, use, share, and store about you, and the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below at ‘Contacting Us’.We participate in and comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as supervised by the U.S.Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area (“EEA”) member countries and Switzerland to the United States, respectively. You can find out more about our Privacy Shield commitments below.

1. Information Collection

We collect data about our clients, our talent and our prospects. We limit this collection to what is necessary in relation to the purposes for which the data is processed, and we collect it for specified, explicit and legitimate purposes. The data is stored securely on our platform and on our CRM system.

1.1 Talent Data

We collect data when you complete a registration form and when you apply for projects. We collect personal data such as name, contact information, career history contained in your profile and CVs. We do not explicitly collect or store sensitive data, although if this information is contained within your CV then this information will be saved, but not processed.
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We may receive or acquire information about you from suppliers from third-party partners (such as background check providers) or other third-party sources (such as information from publicly available sites (like Monster.com,CareerBuilder.com, or LinkedIn), or a job seeker’s third-party reference.·    
  
You may also choose to provide us with access to certain personal information stored by third parties, like social media sites.  For example, if you register for an account to access some of our sites, you can choose to import your LinkedIn basic profile data (such as your name, experience, location,photo, and contact information). By authorizing High5 to have access to this information, in collecting, storing, and using this information, in accordance with this Privacy Notice, High5 will only pursue the legitimate interests set out below under Use of Personal Information.·      
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We collect publicly available information from job boards or professional social media websites where career data is made available by individuals and can be viewed by recruiters.
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Sensitive Personal Information: In connection with the various services we provide, or if you are applying for a job opportunity with us or one of our customers, you may be asked for types of personal information that are viewed by some countries as sensitive personal information. Sensitive personal information includes, for example, government-issued identification numbers (such as national insurance numbers),information relating to a person’s race or ethnic origin, political opinions or religious or philosophical beliefs, physical or mental health or condition, sexual orientation, trade union membership, genetic data and any related legal actions, or the processing of biometric data for the purposes of uniquely identifying an individual.  It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws (collectively “Sensitive Personal Information”).·      
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Although we aim to minimize the amount of Sensitive Personal Information we process, we may process such information in certain circumstances, such as where we are required to or permitted to do so by law (e.g. information about your racial/ethnic origin, gender, and disabilities for equal opportunity monitoring or affirmative action programs), or where it is necessary to provide you with aservice, or if we need to perform a criminal background check, drug/alcohol test or fitness-for-duty testing.  If required by applicable data protection laws, we will obtain your express consent to our collection and use of your sensitive personal information.

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1.2 Clients and Client Account Data

We collect data when you complete a registration form or post a project with us. We may collect both personal data (such as your name and contact details) and also corporate data including company name, contact details and information regarding project assignments or recruitment needs.

1.3 Prospect Data

If you are a business that we believe is likely to benefit from using High5 we may collect personal data from third parties who have provided us this information, or from collecting data during face to face meetings, events or telephone conversations. This only includes corporate/b2b data and we retain the data for a maximum of twelve months on our CRM and email marketing systems.

1.4 Billing and Other Information

We may collect and store billing and invoicing addresses and information for customers and consultants. We may collect citizenship and work authorization status. Where we request information from you, we will let you know prior to collection whether the provision of the personal information we are requesting is required either by employers as a term of their employment or by law, or whether the information may be provided on a voluntary basis, and the consequences of not providing the information.

1.5 Usage Information

We may collect information about how you use us, which may include links you interact with, applications for projects, consultants you review, any messages you send via the platform and any communications between you and us.

As we collect information when you interact with the High5 website and the High5 platform, this information may include your Internet Protocol (IP) address, your browser type, the times and dates when you are using your account, and any preferences.

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1.6 Device Information

We may collect information about the device you are using, including the type of device and what operating system you are using.

Any personal data or sensitive personal data you provide to us will be processed in accordance with the Data Protection Act 1998. However, despite adopting industry best practices and standards in terms of electronic transmission security and processing of data, these are inherently insecure and like any other entity which provides services and processes data we cannot absolutely guarantee the security of any data you provide to us.

2. Information use

We use the information we collect to deliver our service. We restrict data processing to delivery of this service for business to business (b2b) purposes. We do not process sensitive personal information, and restrict data processing to corporate/B2B data. Our impact assessment shows that this data processing activity is very unlikely to have an adverse impact on your privacy.

2.1 Talent Information

We use the information we collect to provide, maintain and improve our services to consultants so that we can identify suitable project opportunities. This includes personal data which will be stored, processed, used and disclosed by us to deliver this service. This has been identified as a legitimate interest: processing this data allows us to provide consultants with the service for which they have registered, namely, finding new business opportunities.

To communicate with you by sending service emails and messages, including notifications on projects. These service emails are considered part of the default services to progress projects, and you may not opt out of them but you can choose the frequency with which you are notified. In addition we may send you marketing news about new features. You can opt out of these at any time.

2.2 Clients and Client Accounts

We use the information we collect to provide, maintain and improve our services to you so that we can find the most suitable consultants for client projects and make this process as efficient as possible for both parties. This includes personal data which will be stored, processed, used and disclosed by us to deliver this service so that the consultant can be provided with information about the opportunity and the client company. This has been identified as a Legitimate Interest: processing this data allows us to provide client companies with the service for which they have registered, namely, finding independent consultants for project assignments and vacancies, including interim and full-time vacancies. To communicate with you by sending service emails and messages. These service emails are considered part of the default services for which you have registered, in order to progress projects and find consultants. In addition we may send you marketing news about new features. You can opt out of these at any time.

2.3 Prospect Account

In this instance, we are collecting and processing your personal data using Legitimate Interests as the legal basis for processing. We believe the service we provide is likely to be of interest to you, based on your company, which may be a registered client account with Talmix, and role. We restrict processing to communications on Talmix services to b2b data. If you do not consider that this information is relevant to you, please tell us, or unsubscribe, and you will be removed from future communications.

2.4 Billing and Management

We use account information to keep track of billing and payments. This information is only requested when contracts are in place and is stored securely on our accounting system.

2.5 Marketing to Client Accounts and Consultants

We often need to contact you for invoicing and similar purposes. We may also use your contact information for our marketing or advertising purposes. You can opt out of these communications at any time.

We may also use any non-personal or anonymised data about you for internal business purposes, such as generating statistics and developing marketing plans.

We may disclose any data we deem necessary, in our sole discretion, to comply with any applicable law or on the request of any appropriate authority. Once you have registered with us, we will use your data to communicate with you by post, email or telephone.

3. Cookies

We may place a "cookie" on your computer's hard drive so we can recognise you as a return user. The cookie will be stored on your computer's hard drive until you remove it. You can have your browser notify you of, or automatically reject, cookies. If you reject our cookie, you may still use our Website, but you may be limited in the use of some of the features. In addition, we may use IP addresses to analyse trends, administer our Website, track users' movement, and gather broad demographic information for our use. For more information about cookies on our site, please read our Cookie Policy.

4. Sharing Data

4.1 Associated Companies

High5 may disclose your personal information to any affiliate within the EEA High5 family of companies, for use in accordance with this Privacy Notice.  This includes our subsidiaries, affiliates, and our ultimate holding company.  This sharing of personal information with High5 affiliates may include combining the personal information gathered by certain High5 Sites with information independently gathered on other High5 Sites as well as information gathered offline into one or more database(s) useable by High5, including all of its affiliates. Again, this combined information will only ever be used for the purposes disclosed within this Privacy Notice.

4.2 Third Parties

We may retain other companies and individuals to perform functions on our behalf in relation to the purposes set forth in this Privacy Policy. Examples include data analysis firms, customer support specialists, webhosting companies, and companies we use to provide marketing services. Such third parties may be provided with access to data needed to perform their functions, but may not use such information for any other purpose.

High5 may share and disclose personal information about you with the following types of third parties and in the following circumstances:·      
Potential employers or potential customers – We may share your personal information ifyou are a job seeker with a customer for the purpose of providing our staffing and recruiting services, or search, workforce management, or talent advisory services. In connection with the above, we may need to disclose certain data about your previous employment (such as your C.V. and corresponding information or to the extent permitted by law, the results of any criminal background checks or other specific employee data such SSN/National ID) with that customer or other service providers or agents acting on our behalf to facilitate and enable the potential placement or employment. To the extent you are employed by a customer of High5 through our search, workforce management, or talent advisory services, the High5 customer will process such personal information in accordance with its own policies and procedures.·      
Compliance with laws – We may disclose personal information to a third party where we arelegally required to do so in order to respond to or comply with any applicablelaw, regulation, subpoenas, court orders, legal process, or government requests, including in response to public authorities to meet national securityor law enforcement requirements.·      
Vendors, consultants, and other service providers – We use third party vendors, consultants, and other service providers to assist us in providing our services, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/C.V. data, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training, occupational health and safety screening, and drug and background screening.
In providing these services on behalf of High5, it may be necessary for us to provide these third parties with access to your personal information.
In cases of onward transfer to third parties of data of individuals resident in the EEA or Switzerlandr eceived pursuant to the EU-U.S. Privacy Shield or the Swiss-U.S. PrivacyShield, High5 is potentially liable under the Privacy Shield Principles if our agents process your personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.·      
Business transfers – Circumstances may arise where, whether for strategic or other business reasons, High5 decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchasers, orthe receipt of it from sellers. It is High5’s practice to seek appropriate protection for information in these types of transactions.·      
Vital interests and legal rights – We may collect and possibly share personal information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of anyperson, violations of High5’s terms of use, or as otherwise required by law, including without limitation to meet national security or law enforcement requirements. We also may disclose your personal information to third parties when we choose to establish or exercise our legal rights or defend against legal claims.·       With your consent – We may disclose your personal information for other purposes with your consent. Your personal information is never sold, rented, or leased to any external company, unless you have granted us permission to do so.

4.3 International Transfer

As a global company, we may transfer personal information to High5 companies and third parties located in the United States and in other countries that may be outside your country of residence for storage and processing in order to provide our services. These countries maynot necessarily have data protection laws as comprehensive as those in your country or residence. In addition, we will have taken appropriate safeguards to protect your personal information in accordance with this Notice and applicable law wherever it is processed.  These safeguards include implementing theEuropean Commission Standard Contractual Clauses for transfers of personal information between High5 companies and our self-certification to the PrivacyShield Frameworks which are explained in further detail below.  Further details of these safeguards can be provided upon request. 
‍EU-U.S. and Swiss-U.S. Privacy Shield Framework
‍For personal information we receive from the EEA and Switzerland, High5 and its US controlled subsidiary companies have certified their compliance to the EU-U.S. and Swiss-U.S. Privacy ShieldFrameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the EEA andSwitzerland. We have certified that we adhere to thePrivacy Shield Framework Principles of: Notice, Choice, Accountability forOnward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability when processing personal information from the EEA in the U.S.
If there is a conflict between the policies in this Notice and the Privacy Shield Principles, the Privacy ShieldPrinciples shall govern.  To access the Privacy Shield List and to find details of our certification, please visit: https://www.privacyshield.gov. High5 is subject to the investigatory and enforcement powers of the FederalTrade Commission (FTC) with regards to our compliance with the PrivacyShield.  Residents of the EEA or Switzerland who believe that their information has not been processed in compliance with the Privacy ShieldPrinciples may raise their complaints in a number of ways:You can contact us directly using the contact details provided below and we will respond to your complaint within 45 days of receipt.
‍High5
285Davidson Avenue Suite 406
Somerset, NJ 08873-4153
ATTN: Privacy Officer
privacyofficer@high5hire.com
We have also committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus (“BBB”). The BBB is a non-profit alternative dispute resolution provider located in the United States.  If you do not receive timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Further, for residents of the EEA, theEuropean data protection authorities (DPA) and for residents of Switzerland, the Swiss Federal Data Protection and Information Commissioner, may refer your complaint to the US Department of Commerce or the Federal Trade Commission forf urther investigation. Please note that if your complaint is not resolved through the above methods, under limited circumstances, a binding arbitration process option may be available before a Privacy ShieldPanel.  To find out more about the Privacy Shield‘s binding arbitration scheme please see www.privacyshield.gov/article?id=My-Rights-under-Privacy-Shield  

5. Links

This Website may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites. This Privacy Policy applies only to the information we collect on this Website. Please read the privacy policies of other websites you link to from our Website or otherwise visit.

6. Security

We take various steps to protect information you provide to us from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.

In the event of any data breach we have a clearly documented policy where by anyone affected will be notified as soon as the breach is identified and remedial steps implemented. We will notify the ICO of any breaches, regardless of severity.

We implement various security measures to protect the security of your personal information, both on line and off line. We have a security panel that meets each quarter to review current processes and systems.

7. Business Transfer

As we continue to develop our business, we might sell or buy entities or assets. In such transactions, user information, including personal data, generally is one of the transferred business assets, and by submitting your personal information on the Website you agree that your data may be transferred to such parties in these circumstances.

8. Notification of Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use your data will be based on the privacy policy in effect at the time of the use.

9. Updating your Information

You have the right to have any personal data stored by us blocked, deleted or corrected.

You have the ability to review, change or remove your personal data contained on our database. You can change your personal data by logging into your account. You may change your personal data on your account at any time by editing your profile (the "Talent Passport") or by contacting us via email or the website.If you wish to delete the data held by us then you will need to email us at support@talmix.com. If you wish your data to be deleted, then your account will also have to be deactivated.

However, we may be required to store and to not delete such data (or that we may store such data for a certain period, though we will implement your request for deletion as soon as the mandatory storage period expires).

Your information will be stored by us for as long as your account is active or for as long as storage of your information is required for us to provide our services, prevent fraud or to meet our legal obligations or for arbitration or to fulfil our agreements.

In case of termination of the usage relationship, the data of the user will be regularly deleted from our network, except for inventory data insofar as it is required for the establishment or contents of or changes to the contractual relationship.

You have the right to revoke permission for the use, processing or transmission of your data by us at any time in writing or by email to privacyofficer@high5hire.com

We will delete any and all of your data stored by us. However, this shall not apply if this data is still needed for the implementation of a contractual relationship. Furthermore, we may process and/or use the user’s data if this is done as part of the object of a contractual relationship or a contract-like relationship based on trust and/or insofar as it is done to protect our justified interests and if, following a careful balancing of interests, no reason exists to believe that legitimate interests of user outweigh the exclusion of the processing and/or use of his data.