Effective Date: May 17, 2018
DHI and its subsidiaries such as Lengo and DHI Career Solutions Inc. participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. DHI is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List [https://www.privacyshield.gov/list]
The data controller of DHI and its subsidiaries’ websites is DHI located at Telephone House 69-77 Paul Street London EC2A 4NW Mazars LLP is a data protection officer and can be contacted at DPO@lengo.com or at Mazars LLP Tower Bridge House – St Katherine’s Way – London E1W 1DD
DHI is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. DHI complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, DHI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, DHI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Right to Lodge a Complaint
We commit to investigating and resolving complaints about our collection or use of your personal information. To make a complaint, contact us at firstname.lastname@example.org.
To help us address the issue effectively, please provide the following:
- The specific data privacy complaint (please provide as much detail as possible including country, your understanding of the data privacy infringement and issues, and redress requested);
- Your full name and how we can contact you; and
- Any previous correspondence on this specific data privacy issue.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If you are a resident of the EEA and have an unresolved privacy or personal information collection, use, or disclosure concern that we have not addressed satisfactorily, please contact the EU Data Protection Authorities. If you are a resident of Switzerland and have this concern, please contact the Swiss Federal Data Protection and Information Commissioner. In connection with its self-certification under the Privacy Shield, TrustArc commits to cooperate with the panel established by the EU Data Protection Authorities and comply with the advice given by the panel with regard to personal information transferred from the EU. TrustArc also commits to cooperate with and comply with the advice of the Commissioner with regard to personal information transferred from Switzerland. This is provided at no cost to you.
For more information on how to contact the EU Data Protection Authorities, click here.
For more information on how to contact the Swiss Federal Data Protection and Information Commissioner, click here.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
- The information we gather
- How we use the information we gather
- How we share information we gather
- Tracking Technologies
- Survey & Sweepstakes
- Social Media Features
- Connecting via Sign-in Services
- Data Subject Rights and Correction of Personal Information
- The information we gather
When visitors use the Services, we passively collect and aggregate information indicating, among other things, which pages were visited, the order in which they were visited, and which links were “clicked.” Collecting such information involves the collection and logging of IP addresses, Internet Service Provider (ISP), operating system, and browser software used by each user of the Services. This information we collect helps us identify the most popular areas of the Sites and determine the effectiveness of our promotional activities. In addition, we may disclose some of this information to advertisers to inform them of the number of people who have seen and/or clicked through their advertisements.
In certain areas of the Sites, such as those in which you complete a profile, submit your resume, create a new account, or enter DHI-sponsored contests or promotions, we may request that you provide us with certain personally identifiable information, such as your e-mail address, first and last name, postal zip code, country of residence, mobile number, profession, or work experience. We will, in such situations, seek to identify which informational items are required and which are optional. In some instances, we may collect geo-location based information for the purpose of helping identify jobs in your area. We may share this information for the sole purpose of providing you this feature. You may opt-out of location based services by editing the setting at the browser level.
If you post profiles and resumes on our Sites, such information can be viewed by our customers. At any time, job seekers may elect that their profile and resume not be searchable by our customers by logging into their account and changing the status of their profile or, if that is not possible, they may contact us at email@example.com and we will make the change for them.
In addition, job seekers may elect to make their profile searchable by our customers on a confidential basis only. In this case, the user’s name and contact information will not be displayed to customers performing searches on the Site. If the customer desires to contact the confidential job seeker regarding an employment opportunity, they will send an email to the job seeker through our system. We will forward the email to the seeker’s email address. The seekers email address will not be provided directly to the customer. When posting a resume confidentially, it is the job seeker’s responsibility to ensure that their contact information is not included within their resume attachment.
DHI Services are not available to children under 16 years of age. We do not knowingly collect personal information from children under 16 years of age.
Please note that we cannot control the acts of users of the Services. All members and visitors should be aware that, when they disclose personal information in a resume or profile or other medium, the information may be collected and used by others to send that person unsolicited email from other parties outside DHI. In the event that you encounter any DHI user who is improperly collecting or using information about you or other users, please contact firstname.lastname@example.org.
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
To provide services to our customers, Lengo may collect indexed content, including information about you, from a variety of publicly available websites. Indexed content may include personal information such as posts on blogs. In general, such indexed content is available through standard search engines or by visiting the public websites themselves. We combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. DHI may append this information to your profile or use this content to create a profile, whether or not an individual has an account with us. If you would like to remove the information we collect, contact us at email@example.com. DHI has no ownership rights to the indexed content sourced from third party sites and cannot guarantee that we will not collect information from a publicly available source at a later point in time.
Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include job and industry information, such as skills, title, experience, qualifications, etc. and any other publicly available information from Facebook, LinkedIn, Twitter, StackOverflow, GitHub, and Dribble.
- How we use the information we gather
Please take some time to familiarize yourself with the different ways we use the information we gather. DHI encourages all third parties involved, including but not limited to its advertisers, to adhere to our policies regarding the privacy of our visitors and users and to otherwise handle personal information in a responsible manner. Nevertheless, in the event you encounter any third party associated with, or who claims association with, DHI who you feel is improperly collecting or using information about you, please contact firstname.lastname@example.org.
DHI relies on legitimate interest to process or use your personal data as described above. If you do not agree with this approach, you may object against DHI’s processing or use of your personal data as set out below.
- 1. We use information collected passively, as identified above, in aggregate form to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our visitors and users, and by measuring demographics and interests regarding specific areas of the Services. We may provide statistical information based on this data to advertisers, users, and other current and potential business partners. We may also use the aggregate data to inform these third parties as to the number of people who have seen and clicked through links to their sites.
- We may use the personal information a user submits for the following purposes:
- To understand a user’s needs and create content that is relevant to the user;
- To generate statistical studies;
- To conduct market research and planning by sending user surveys;
- To notify user referrals of DHI services, information, or products when a user requests that DHI send such information to referrals;
- To improve services, information, and products;
- To help a user complete a transaction, or provide services or customer support to users and to recipients of DHI products;
- To communicate with the user and with recipients of DHI products and services;
- To email users about services, information, products and offers from our business partners (and as set forth in section C, ‘How we share information we gather’);
- To personalize the Sites for the user;
- To notify the user of any changes with the Sites which may affect the user;
- To allow the user to purchase products, access services, or otherwise engage in activities the user selects; and
- To allow us to contact you by phone and/or email. In some cases, this includes text messaging of alerts, and carrier charges may apply.
User names, identifications (“IDs”), and email addresses (as well as any additional information that a user may choose to post) may be publicly available on the Sites when a user voluntarily and publicly discloses personal information, such as when a user uses features to send a message to another user, or as part of a message posted to a public forum or a publicly-released software application. Users may not be able to change or remove public postings once posted. Any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from these pages, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Circumstances under which DHI would publicly disclose information collected from surveys include, but are not limited to, sharing survey results with the Sites’ users, providing data to DHI advertisers on user preferences and/or demographics, and publicizing overall usage data in press communications. Where surveys allow users to submit written comments, and where DHI advises users of the possibility of such disclosure at the time they take the survey, DHI reserves the right to disclose any information provided by users, provided that no personal information identifying a specific user is disclosed. Participation in surveys is at a user’s option; DHI does not conduct mandatory surveys.
- How we share information we gather
Subject to the foregoing, DHI uses your personal information in several ways. DHI may share your personal information with third party service providers to help us with our business activities such as processing credit cards, email and digital marketing activities (including social media and display marketing), offering customer service, or operating a community forum. These service providers are authorized to use your personal information only as necessary to provide these services to us. With respect to job applications, DHI will not disclose your profile or resume on our Sites to prospective employers without your consent or to carry out your instructions.
We may share your information with third-party business partners, for instance, for the purpose of enhancing our products and services or so that they can market their products or services to you. If you do not want us to share your personal information with these companies, contact us at firstname.lastname@example.org.
If you “opt in” to receive promotional materials from third parties, information you have made available to us may be made available to third parties who provide goods or services that we believe may be of interest to you. Such aggregate information is provided in a collective manner, and no single person can be identified from such information. You may “opt out” of receiving such materials at any time in a variety of ways: by using the opt-out link here [https://campaign.lengo.com/optout], by using the link included in each email, by changing your subscriptions preferences on the “user settings” page in your DHI account or by contacting us at email@example.com If you have provided more than one email address to our service, you may continue to be contacted, unless you request to unsubscribe each email address you have provided. If you opted in to receive information directly from third parties, then you must contact those third parties directly to opt-out.
When you submit any personal information on this Site, we will obtain your consent authorizing the Sites to sell to Third Party Contractors any and all personal information that is necessary to enable additional service offerings.
If DHI is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. DHI reserves the right to assign, sell, license, or otherwise transfer to a third party your personal information in connection with an assignment, sale, joint venture, or other transfer or disposition of any portion or all of DHI’s or its affiliated entities’ assets or stock.
- Tracking Technologies
Technologies such as cookies, beacons, tags and scripts are used by DHI and our partners, analytics, and service providers. These technologies are used generally for analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole.
We use pixels, or transparent GIF files, to help manage online advertising. These pixels are provided by our ad management partner, DoubleClick. These files enable our ad management partner to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our Sites. It does not contain your name, address, telephone number, or email address. For more information about DoubleClick, including information about how to opt out of these technologies, go to http://www.google.com/privacy/ads/ or you may also opt out by clicking Here.
We use web beacons from time to time. A web beacon is a string of code that provides a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data, or determining how many times a specific web page has been viewed. Web beacons enable DHI to recognize a browser’s cookie when a browser visits a Site, and to learn which banner ads bring users to each Site. For example, when a user visits a web page, the code for the page may include instructions to go to another server to gather a single pixel graphic image. Web beacons are not placed on a user’s computer. Such web beacons may be provided by DHI’s third party advertising companies to help manage and optimize any online advertising.
If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
DHI web servers may automatically log aggregate information, such as a user’s IP address, domain name, browser type, date and time of access, and other log file data.
Links to third party websites
Links to third party web sites or widgets to enable sharing of information through social networks on the Sites are provided solely as a convenience to the user. When a user uses these links, the user leaves the Sites. DHI has not reviewed all of these third party sites, does not control, and is not responsible for, any of the third party sites, their content or privacy practices. DHI does not endorse or make any representations about the third party sites, or any information, services, or products found on the sites. If a user decides to access any of the linked sites, DHI encourages the user to read their privacy statements. The user accesses such sites at user’s own risk.
The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please help keep your account safe by using a strong password. Accordingly, we advise that you do not communicate any confidential information through our Services.
If you have any questions about security on our Site or the security of your personal information, you can contact us at firstname.lastname@example.org
- Surveys and Sweepstakes
Occasionally, DHI may conduct surveys in order to better deliver advertisements and content and to better understand your needs relating to the Services.
From time-to-time we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personal information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). That information, to the extent it conflicts with this policy, will govern that particular promotion or sweepstakes – please remember to read it carefully. We may use this information to notify contest winners and award prizes, to monitor the Sites use, to personalize the Sites, to send participants an email, and to measure participants’ demographics, interests and opinions. We may use a third party service provider to conduct these surveys or contests; that company will be prohibited from using our users’ personal information for any other purpose. We will not share the personal information you provide through a contest or survey with other third parties unless we give you prior notice and choice.
If you choose to use our referral service to tell another person about a job, we will ask you for that person’s email address. We will automatically send that person a one-time email inviting him or her to visit the site. We use this information for the sole purpose of sending this one-time email, and do not store these email addresses.
If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com
- Social Media Features
- Connecting via Sign-in services
You may be able to log in to our Sites using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on the Sites to your profile page to share with others within your network.
- Data Subjects’ Rights and Correction of Personal Information
DHI acknowledges that you have the right to access your personal information. DHI has no direct relationships with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their inquiry to the DHI client (the data controller).
You can request from DHI at any time information about which personal data DHI processes about you and the correction or deletion of such personal data. If your information changes, or you no longer desire our services, you may correct, update, amend, delete/remove or deactivate it by making the change on your account page or by emailing our Customer Support at firstname.lastname@example.org or by contacting us by telephone or postal mail at the contact information listed below.
Depending on which laws apply to your personal information, we may only be able to do some of these actions for you. If you request an action and we refuse to do it, we will explain your legal rights, the reason for our refusal and any recourse you may have. Please note that if you request that DHI delete your personal data, you will no longer be able to use any DHI service that requires the use of your personal data. If you have provided more than one email address to our service, you may continue to be contacted, unless you request to unsubscribe each email address you have provided.
If DHI uses your personal data based on your consent or to perform a contract with you, you may further request from DHI a copy of the personal data that you have provided to DHI. In this case, please contact email@example.com and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the personal data is to be sent to you or another recipient.
You can request that we restrict your personal data from any further processing in any of the following events: (i) you state that the personal data DHI has about you is incorrect, (but only for as long as DHI is required to check the accuracy of the relevant personal data), (ii) there is no legal basis for DHI to process your personal data and you demand that DHI restricts your personal data from further processing, (iii) DHI no longer requires your personal data but you claim that you require DHI to retain such data in order to claim or exercise legal rights or to defend against third party claims or (iv) if you object to the processing of your personal data by DHI (based on DHI’s legitimate interest as further set out in Section A above), which may be required when determining if DHI has a prevailing interest or legal obligation in processing your personal data.
We will respond to your request without undue delay within 30 days. DHI reserves the right to take reasonable steps to verify customer identity prior to granting access or processing changes or corrections. Please direct any such request to firstname.lastname@example.org.
- Data Retention:We will retain your information for as long as your account is active or as needed to provide you Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Blogs:The Sites may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
- Testimonials:We post testimonials on the Sites which may contain personal information. We do obtain consent by email or a release agreement prior to posting the testimonial to post their name along with their testimonial.