Effective May 2018
This privacy notice describes how we, K2 Integrity Holdings, Inc. , and our affiliates and associated offices from time to time (“K2”, “we”, “us, “our”), process, maintain, use and share information about individuals (each a “User”, “you”, “your”) who use our website and related features (collectively, the “Site”) or who we communicate or interact with. Outside the scope of this notice, we also process information about individuals on behalf of our clients in connection with our client services (“Client Services”). By visiting our Site, you acknowledge the processing described in this notice and related documents.
2. HOW WE USE INFORMATION ABOUT YOU
We will only process your information, in accordance with applicable law, for the following purposes:
a. responding to your queries, requests and other communications, for example, if you apply for a job or you send us an inquiry about our Site or Client Services;
b. providing the Site, our content, features and related services, and allowing you to use features on our Site, when you choose to do so;
c. enabling our service providers and vendors to carry out certain functions on our behalf in order to operate our business, including webhosting, data storage, identity verification, recruitment tools, financial reporting tools, technical and other functions, as applicable;
d. carrying out profiling for business administration, recruitment, marketing and other business purposes, such as for example using recruitment tools that allow us to assess applicants and to consider their suitability for specific roles;
e. personalizing your experience, e.g., to recognize your device, for example, the same personal computer or mobile device, to show content that matches information you were interested in on prior visits, or to use cookie data and limited log data to track access to and use of the Site, in order to understand our audience as a whole and to improve content and how the Site works;
f. sending you personalized marketing emails, newsletters, or other communications about our Client Services as permitted by law or as requested by you. Please refer to “Your choices” below for information on how to unsubscribe;
g. ensuring the security of our business and preventing and detecting fraud;
h. administering our business, including complaints resolution, troubleshooting of our Site, data analysis, quality control, staff training, testing of new features, research and statistical purposes;
i. developing and improving our Site, Client Services and related services;
j. providing Client Services, where we process information about individuals as a data processor in accordance with the instructions of our clients in their capacity as data controllers; and
k. complying with applicable law, including in response to a lawful request from a court or regulatory body.
The legal basis for our processing of information about individuals for the purposes described above will typically include, always only where permitted by law:
3. YOUR CHOICES
Marketing. If you would like us to stop sending you marketing emails, you may use the opt-out link at the bottom of any marketing email we send. Although we encourage you to use the opt-out link because it is automated, you may also send us a request at [email protected]. You can also use that address to request a copy of any information, such as your contact details, that you have submitted to us through this Site or that we have in our marketing files to correct the information or to delete that information from marketing use. We will endeavor to satisfy such requests within a reasonable time. We reserve the right to retain a copy in our inactive records for any legally required purposes.
Cookies. When you arrive on our Site you will see a banner message informing you about cookies. Once you click ‘OK’, this message will close. If you do not wish to give consent you must modify your browser settings and click ‘OK’ when you revisit the site so the banner will not reappear. If you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting as explained at http://www.allaboutcookies.org and http://www.youronlinechoices.com/, in relation to third-party cookies. If you choose to decline cookies, the Site may not function properly. Unless you change the settings, we assume that you are happy for us to place cookies on your device.
4. DISCLOSURE OF DATA ABOUT YOU TO THIRD PARTIES
We may transfer information about you, in accordance with applicable law, to the following recipients:
Our Group Companies. We may share your information with our affiliates or associated offices in the U.S., Europe, and other countries from time to time. In such cases, where required by law, we will safeguard your information by executing appropriate instruments, such as the EU Commission’s model clauses. Where required by law, we will disclose a copy of such safeguards to you.
Service Providers. We may contract with third-party service providers to perform functions for us, and provide or give access to your information for the purpose of doing so. Where required by law, we will ensure that your privacy rights are adequately protected by appropriate technical, organization, contractual or other lawful means. You may contact us for a copy of such safeguards in these circumstances.
Business Transfers. We reserve the right to transfer to relevant the parties, their service providers, and advisors some or all of the information we have about you as part of a share transfer, business transfer of some or all of our assets to another company, reorganization, dissolution, or similar event.
Our Clients as Part of Client Services. Where we act as a processor on behalf of our clients.
Disclosures for Legal Reasons. We reserve the right to disclose information about you when we are required to do so by law or regulation, for example, in response to a court order or subpoena or any other valid legal process. We may also disclose the information in response to a law enforcement agency request or when we believe such disclosure is necessary to protect our rights or to safeguard anyone’s property or safety.
5. RETENTION OF PERSONAL DATA
We retain information about individuals for as long as is necessary for the purposes listed above or longer where this is required by the law. Please contact us for further details of applicable retention periods.
We may keep an anonymized form of your information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
We will retain information in accordance with our clients’ instructions where we act on their behalf as a data processor.
6. DATA SUBJECT RIGHTS
Individuals based in Europe and certain other individuals (each a “Data Subject”) may have rights in relation to their information (referred to as “Personal Data”) under European data privacy laws. This excludes information processed as part of our Client Services on behalf of our clients, who should be contacted instead. Please contact us or visit the website of your local data privacy authority or privacy regulator for further information about your rights.
7. OTHER IMPORTANT INFORMATION
Security. We will use appropriate technical and organizational information security measures to try to prevent unauthorized access to your information. However, please be aware that the transmission of information via the internet is never completely secure. While we can do our best to keep our own systems secure, we cannot control the internet as a whole and we cannot therefore guarantee the security of your information as it is transmitted to and from our Site.
Children. The Site is intended for use by adults, primarily in their business or professional capacities. We do not target, or knowingly collect any information from, children under the age of 13.
California Consumer Privacy Notice (“CCPA”). Please click here for information regarding your rights under the CCPA.
Contact us. If you have a question, request, complaint, dispute, or concern related to this Privacy Notice, you may send a message by email to [email protected] or contact:
K2 Integrity Holdings, Inc.
Attn: Legal Department
730 Third Avenue
New York, NY 10017