Privacy Notice

Last updated: 09/02/2021

We are Visage, Inc. (“Visage”). This Privacy Notice explains who we are, how we collect, use and disclose your Personal Data and how you can exercise your privacy rights.  If you have any questions or concerns about our use of your Personal Data, or would like a printable version of this Privacy Notice, then please contact us using the details provided at the bottom of this Privacy Notice. If you are located in the European Union or the United Kingdom, the controller of your Personal Data is Visage, Inc.

1.   About us

Visage provides a crowdsourcing solution that uses advanced AI to help recruiters (our “Clients”) find the best talent for their roles. We obtain data about professionals and prospective candidates from publicly available sources and from our community of over 4,000 global sourcers. You can find more about us and the services we provide here.

2.   What does this Privacy Notice cover?

This Privacy Notice applies to our collection, use and disclosure of Personal Data that relates to:

(a)                  individuals who visit our website at visage.jobs or register to use our services in order to source candidates for their roles, and individuals who sign up to receive communications from us or attend our events (“Users”);

(b)                  professionals and prospective candidates that we source on behalf of our clients in connection with our services (“Professionals”); and

(c)                  individuals who help us to identify or provide intelligence about Professionals for our Clients in connection with our services (“Sourcers”).

Please note that this Privacy Notice only applies where we are processing Personal Data as a data controller. In certain circumstances, we process Personal Data as a data processor on behalf of our Clients, for example where they have provided us with information relating to their candidates. This Privacy Notice does not apply to the Personal Data we receive and process as a processor on behalf of our Clients, and you should contact the relevant company or organization if you have any questions about their privacy practices.

In addition, please also note that this Privacy Notice does not apply to the actions or activities of third party companies or organizations that we work with or any third party websites or platforms that link to or can be accessed through our website or services.

3.   What Personal Data do we collect?

Information about Users

We need to collect and use information about you in the course of providing our services to you and your organization. The Personal Data that we may collect about you broadly falls into the following categories:

Information you provide voluntarily: We ask you to provide certain information voluntarily. This typically includes:

  • Log-in credentials, such as your username and password;
  • Identification data, such as name, company, job title, location and photograph;
  • Contact data, such as email address;
  • Payment information, such as your credit card information and billing address where you pay for our services;
  • Communications data, such as chat messages;
  • Support data, such as information about a technical issue you have reported.

We will also generate a unique Visage ID that we use to identify you when you are using the services.

If we ask you to provide any other Personal Data not described above, then the Personal Data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect the information.

Information we collect automatically: Like most companies that offer online services, we may also collect certain information automatically about your computer or device and usage of our services using cookies and similar tracking technology.  In some countries, including countries in the European Economic Area and the United Kingdom, this information may be considered Personal Data under applicable data protection laws. This includes:

  • Device information, such as your IP address, operating system, device type and manufacturer and browser type;
  • Usage data, such as the dates and times you access the services and your browsing activities (such as what portions of the services you use, session durations, links clicked, non-sensitive text entered, and mouse movements).

Please see the section “Cookies and similar tracking technology” https://visage.jobs/cookie-policy below for more information.

Information we obtain from third party sources: From time to time, we may receive certain Personal Data about you from third party sources (such as Intercom), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us. The types of information we collect from third parties include your location (based on IP address), browser type and version, operating system, device type and pages visited. We use this information to better understand your use of our services.

Information about Professionals

We collect, use and disclose information about Professionals in the course of providing our services to our Clients. The Personal Data that we may collect about you broadly falls into the following categories:

Information we obtain from third party sources and our Sourcers: If you are a Prospective Candidate, we may receive Personal Data about you from publicly available sources (such as LinkedIn, news reports, press releases and social media platforms), our third party data providers (such as FullContact) or from Sourcers that provide information to use in connection with our services. Whenever we obtain information from third parties (including our third party data providers and Sourcers), we take appropriate steps to ensure that such third parties have obtained your information lawfully; and we act under the ruling of article 14 of the GDPR which applies where Personal Data is obtained from a source other than the Data Subject (the natural person to whom the data pertains to), for which this Privacy Policy acts as the mean to inform the Data Subject.

The information we obtain typically includes:

  • Identification data, such as your name, location, time zone and social media URL or username;
  • Contact data, such as your email address;
  • Professional profile data, such as your current job title, employment type, seniority, employer, company industry and CV;

Information we obtain from our Clients: Our Clients may also provide us with Personal Data about you in connection with our services (for example, if they provide us with a list of their existing candidates). We use this information to provide the services to our Clients and only as instructed by the Clients. Under these circumstances, we process your information as a processor on our Clients’ behalf and it our Clients, as the controllers of the information, that determine what information we process about you and how we use it. If you have any privacy-related questions or concerns about one of our Client’s privacy practices, or the choices a Client has made to share your information with us, you should contact that company or organization directly. We are not responsible for the privacy or security practices of our Clients, which may differ from those described in this Privacy Notice.

Information about Sourcers

We need to collect and use information about you in the course of providing our services to you. The Personal Data that we may collect broadly falls into the following categories:

Information you provide voluntarily: We ask you to provide certain information voluntarily.  This typically includes:

  • Log-in credentials, such as your username and password;
  • Identification data, such as name, company, job title, location and photograph;
  • Contact data, such as email address;
  • Payment information, such as your bank account information where we pay you for identifying Professionals for us;
  • Communications data, such as chat messages;
  • Support data, such as information about a technical issue you have reported.

We will also generate a unique Visage ID that we use to identify you when you are using the services.

If we ask you to provide any other Personal Data not described above, then the Personal Data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your Personal Data.

Information we collect automatically: Like most companies that offer online services, we may also collect certain information automatically about your computer or device and usage of our services using cookies and similar tracking technology.  In some countries, including countries in the European Economic Area and the United Kingdom, this information may be considered Personal Data under applicable data protection laws. This includes:

  • Device information, such as your IP address, operating system, device type and manufacturer and browser type;
  • Usage data, such as the dates and times you access the services and your browsing activities (such as what portions of the services you use, session durations, links clicked, non-sensitive text entered, and mouse movements).

Please see the section “Cookies and similar tracking technology” https://visage.jobs/cookie-policy below for more information.

Information we obtain from third party sources: When you log into our services using a third party account (such as LinkedIn), we may also collect certain information from the third party necessary to authenticate your account, such as your email address and any other information you allow the third party to share with us.

4.   How do we use your Personal Data?

We use Personal Data about you for the following purposes:

  • Provide, maintain and improve our services;
  • Enable Users and Sourcers to register to use our platform and create and maintain their profile;
  • Share information about Professionals with our Clients so that they can visualize the professional profiles of Professionals and decide upon their adequacy for a given job opportunity;
  • Contact Professionals on behalf of our Clients to tell them about a job opportunity that may be of interest to them;
  • Send out technical notices, updates, security alerts, and support and administrative messages to our Users and Sourcers;
  • Respond to comments, questions, and requests from those who interact with Visage, as well as providing customer support to our Users and Sourcers;
  • Communicate with our Users and Sourcers about news and information relating to our services;
  • Provide information about our services in accordance with your marketing preferences;
  • Monitor and analyze trends, usage, and activities in connection with our services;
  • Personalize and improve our services;
  • Detect, prevent and respond to potential fraud, violations of our terms and conditions or other misuse of our services;
  • Comply with our legal obligations.

In general, we will use the Personal Data we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your Personal Data.  However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws.

5.   Who do we share your information with?

We may disclose your Personal Data to the following categories of recipients:

  • We may share your information with our third party service providers and partners who provide data processing services to us (such as data storage providers, analytics services, marketing services, and external consultants and professional advisers) or who otherwise process Personal Data for purposes that are described in this Privacy Notice or notified to you when we collect your Personal Data. A list of our current third party service providers is available here;
  • For Professionals, we may share your information with our Clients in order to provide our services to them and for the purposes described in this Privacy Notice;
  • For Professionals, we may share some of your information with our Sourcers with whom we liaise in connection with providing the services to our Clients;
  • We may share your information with any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • We may share your information with a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Notice;
  • We may share your information with any other person with your consent to the disclosure.

6.   What is our legal basis to process your information? (European individuals only)

If you are located in the European Union or the United Kingdom, we need a legal basis to collect, use and disclose your Personal Data. Our legal basis for collecting, using and disclosing your information will depend on the information concerned and the context in which it is processed.

Users and Sourcers:

We may process your Personal Data in order to perform a contract with you (such as to register and maintain your account and process your payment information). In other circumstances, we may process your information where the processing is in our legitimate interests (such as to communicate with you about news and information relating to our services, monitor and analyze usage trends, and personalize and improve our services).

When required, we will process your Personal Data only where we have your consent to do so (for example, if we need to collect and process any sensitive Personal Data about you). In limited cases, it may be necessary for us to process your information to comply with a legal obligation to which we are subject (such as to share your information with a law enforcement body or regulatory agency where disclosure is required by law, or to exercise, establish or defend our legal rights).

Professionals:

We will usually process your information where the processing is in our legitimate interests (such as when we share certain information about you with our Clients or when we contact you on behalf of our Clients to tell you about a job opportunity that may be of interest to you). We only share your contact information with our Clients where we have your consent to do so.

In limited cases, it may be necessary for us to process your information to comply with a legal obligation to which we are subject (such as to share your information with a law enforcement body or regulatory agency where disclosure is required by law, or to exercise, establish or defend our legal rights).

If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us at privacy@visage.jobs.

7.   Cookies and similar tracking technologies

We use cookies and similar tracking technologies to collect and use Personal Data about you on our website and through the services.  Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how you have interacted with our website and services, including the pages accessed and links clicked, session duration, non-sensitive text entered, and mouse movements. Collecting this information enables us to better understand how people are using our website and services and we use the information for our internal analytics purposes to improve the quality and relevance of our services.

Google Analytics: We may use cookies served by Google Analytics to collect limited data directly from you to enable us to better understand your use of our website, including making use of the demographics and interests reports services of Google Analytics. Further information on how Google collects and uses this data can be found at www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the services by visiting https://tools.google.com/dlpage/gaoptout.

Posthog: We may use Posthog to record and collect certain information about how you’re using the services. This allows us to see what you’re doing so that we can give you accurate and helpful assistance and to generate useful analytics. You can opt-out of all Posthog supported tracking within the services by login to Visage, and disable the tracking in your privacy settings.

For further information about the types of cookies and similar tracking technologies other we use, why, and how you can control them, please see our Cookie Notice https://visage.jobs/cookie-policy.

8.   International data transfers

Your Personal Data may be transferred to, and processed in, countries other than the country in which you are located. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, Visage is headquartered in the United States and our servers are located in Oregon. Our third party service providers and partners also operate in the United States and in Europe. This means that when we collect your Personal Data we may process it in any of these countries.

However, we’ve taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Notice and applicable data protection laws. If you are located in the EEA, United Kingdom or Switzerland these measures include transferring your information to a country that the European Commission or UK authorities (as applicable) have determined provides an adequate level of protection for Personal Data, or by implementing standard contractual clauses with our Clients, third party service providers and partners. Where appropriate, we also use additional safeguards to ensure that your information remains protected in accordance with applicable law.

9.   Data retention

We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Specifically, when reaching out to a Data Subject (prospective employee who may be interested in participating is a given recruitment process) and while observing the ruling under article 14 of the GDPR, Visage will erase the gathered data within 28 days of its collection if there has been no feedback from the Data Subject.

10. Your privacy rights

Depending on your location and applicable data protection laws, you may have certain rights with regard to the Personal Data we control about you.

  • If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by emailing us at privacy@visage.jobs or by contacting us using the contact details provided under the section “contact us” below https://www.visage.jobs/.  
  • In addition, if you are located in the European Union or the United Kingdom, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by emailing us at privacy@visage.jobs or contacting us using the contact details provided under the section “contact us” below https://www.visage.jobs/ .
  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us by email at privacy@visage.jobs or by using the contact details provided under the section “contact us” below https://www.visage.jobs/ .
  • Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent. Again, to withdraw your consent please contact us by email at privacy@visage.jobs or by using the contact details provided under the section “contact us” below https://www.visage.jobs/ .

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Finally, you may also have the right to complain to a data protection authority about our collection and use of your Personal Data.  For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.

11. Additional information for California residents

If you are a California resident, the following information also applies to you and supplements the information contained elsewhere in this Privacy Notice.

Information we collect and sources of information

Our Privacy Notice already describes the information we collect about Users, Professionals and Sourcers and the sources of information. This section organizes that information around the Personal Data categories set out in the California Consumer Privacy Act (CCPA).

In the past 12 months, we have collected the following information from the following sources:

  • Identifiers, such as your name, company, job title, email address, Internet Protocol address, unique personal identifier, account username, third party account names and other online identifiers. We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our services.
  • Internet and other electronic network activity information, such as browser type, operating system, device type, manufacturer and browser type, browsing activities and other information regarding your interactions with our services. We obtain this information automatically in the course of your interactions with our services.
  • Commercial information, such as records of services purchased. We obtain this information directly from you or otherwise automatically in the course of your interactions with our services.
  • Geo-location data, such as your general location information (based on your IP address). We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our Services.
  • Electronic and visual information, such as chat messages and any interactions that you may have with us (such as for customer service purposes), photographs, and feedback or testimonials you provide about our services. We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our services.
  • Professional or employment-related information, such as job title, employment type, seniority, employer, company industry and CV. We obtain this information about Professionals on behalf of our Clients in order to provide our services to them.

We collect Personal Data directly from you, automatically from your use of our services and from certain third parties (for example, when you log into our services using a third party account) as described in the section “What Personal Data do we collect?” above.

How we use and share information

We collect and use Personal Data for the business and commercial purposes as described in the section “How do we use your Personal Data?” above. Visage does not share your Personal Data except as approved by you or as otherwise described in this Privacy Notice.

In the preceding 12 months, we have disclosed the categories of Personal Data described above for the business purposes described in this Privacy Notice.

The CCPA gives California residents the right to opt out of the “sale” of their Personal Data. This term is defined broadly and may apply to our sharing of Personal Data about Professionals with our Clients. If you are a Professional, we may have “sold” the following categories of Personal Data about you in the preceding 12 months:

  • Identifiers, such as those set out under the heading “Information about Professionals” above;
  • Professional or employment-related information, such as job title, employment type, seniority, employer, company industry and CV;

If you are a California resident, you may opt out of such sharing with our Clients as explained below. Please understand that this could result in fewer career opportunities for you.

We do not sell Personal Data about our Users or Sourcers and do not knowingly sell Personal Data about California residents under the age of 16.

Your privacy rights

Under the CCPA, California residents have the following rights:

  • You have the right to know the Personal Data that we have collected, disclosed and sold over the past 12 months, and information about our data practices.
  • You have the right to request deletion of your Personal Data that we have collected from you.
  • You have the right not to be discriminated against for exercising your rights under the CCPA. We will not discriminate against you for exercising any of these rights.
  • You have the right to opt-out of the sale of your Personal Data.

California law also permits you to request certain information regarding the disclosure of your Personal Data by us to third parties for the third parties’ direct marketing purposes.

To exercise any of the above rights, or if you are an agent authorized to exercise a right under the CCPA, please contact us by email at privacy@visage.jobs or by using the contact details provided under the section “contact us” below https://www.visage.jobs/ . Please note that to protect your information, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to “Do Not Track” signals. However, you are able to opt-out of the use of tracking technologies as explained in the section “Cookies and similar tracking technologies” above.

12.Updates to this Privacy Notice

We may update this Privacy Notice from time to time. We will take appropriate steps to notify you of any material changes to this Privacy Notice and obtain your consent if and where this is required by applicable data protection laws. You can see when this Privacy Notice was last updated by checking the “last updated” date at the top of this Privacy Notice.

13.How to contact us

If you have any questions or concerns about our use of your Personal Data, or would like to submit a rights request, please contact us by email at privacy@visage.jobs or by post at:

Visage Inc.

200 Wylie KuyKendall Ln

Kyle

TX 78640

United States

If you are located in the European Union or the United Kingdom, Visage, Inc. is the data controller responsible for your Personal Data. You can contact us through the methods described above or by email at privacy@visage.jobs. As explained above, if we have obtained your information from one of our Clients then we process your information on their behalf acting as a data processor. In this context, the Client is the data controller responsible for your Personal Data and you should contact that company or organization if you have any privacy-related questions or concerns about their privacy practices.