Privacy Policy

True Talent Advisory LLC and its affiliates and subsidiaries (“True,” “we,” “us” or “our”) recognizes the importance of protecting the privacy of our customers and online visitors. True provides services (“Services”) through its brands, such as True Search, True Bridge, True Advisory and Search Essentials. The following privacy policy (“Privacy Policy”) sets for how we collect, use, disclose, retain and otherwise process information learned about you from your interactions with us, including when you use our Services and visit our websites and mobile apps from which you are accessing this Privacy Policy (collectively, the “Site”).

This Privacy Policy applies to you if you are: (i) acting as a candidate using our Services to search or apply for a job or who might be interested in a future position with one of our employer clients (“Candidate”); or (ii) a client using our Services as an employer (“Employer”).

Please review this Privacy Policy carefully. When you access or use the Site or Services or submit information to or through the Site or Services, you consent to our collection, use, disclosure, retention and processing of your information as described in this Privacy Policy.

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1. Information We Collect

a. Personal Information

i. Candidates

If you are a Candidate, we may collect the following types of personal information about you:

Identifiers: Name, alias, address, unique personal identifier (e.g., social media identification or personal websites), online identifier, IP address, email address.
Categories of Personal Information listed in the California Customer Records Statute: Name, physical characteristics or description, address, telephone number, education, employment, employment history, salary and income information.
Characteristics of Protected Classifications under Applicable Law: Gender, race, disability, veteran status and languages spoken.
Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, actions taken on the Site, approximate geographic location, language preference.
Geolocation Data: Approximate geographic location.
Audio, Electronic, Visual or Similar Information: Photographs, recordings of calls and virtual meetings, including video and voice recordings, call transcripts, meeting details, and other communications between you and us.
Professional or Employment-Related Information: Employment history, professional certifications, skills, references, resume, salary once you are placed with an Employer, and income or other information collected through interviews and any evaluations.
Education Information: Degrees received, schools attended.

This information is collected and stored electronically when you visit the Site, sign up to join our network, apply to a job through our Services, or contact us.

We may also receive similar data from our business partners, including our subsidiaries, affiliates or other related companies, third-party social media platforms (e.g., LinkedIn), subject to your registration and privacy settings with such social media platforms, Employers and our service providers. We may also receive such data from publicly available sources.

Where permitted by applicable law, we may combine your personal information with other information we have collected from you. We may also combine your personal information with the information we receive about you from our other sources, such as our business partners and publicly available information.

ii. Candidates

If you are an Employer, we may collect the following types of personal information about you:

Identifiers: Name, unique personal identifier, online identifier, account username and password, IP address, email address.
Categories of Personal Information listed in the California Customer Records Statute: Name, physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or any other financial information.
Commercial Information: Services purchased, obtained or considered or other purchasing histories or tendencies.
Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, actions taken on the Site, approximate geographic location (e.g., country), language preference.
Geolocation Data: Approximate geographic location (e.g., country).
Audio, Electronic, Visual or Similar Information: Photographs, recordings of calls and virtual meetings, including video and voice recordings, call transcripts, meeting details, and other communications between you and us.
Other: Responses to surveys and assessments about our Services.

This information is collected and stored electronically when you visit the Site, purchase one of our Services, register an account with us, or contact us.

We may also receive similar data from our business partners, including our subsidiaries, affiliates or other related companies, and our service providers.

b. Information Collected Automatically

In addition, information about your device’s hardware and software is automatically collected by True when you use the Site. This information may include:

IP address
Operating system type
Browser type
Access times and dates
Device type
Actions taken on the Site
Approximate geographic location
Language preference
Other technical information such as protocol status and substatus, bytes sent and received, and server information.

This information is used by us for our business purposes, including for the operation and improvement of the Site, for technical troubleshooting, to maintain the quality of the Site and to provide general statistics regarding use of the Site. We may collect this information through our service providers who provide website analytics services and from third-party social media platforms (e.g., LinkedIn), subject to your registration and privacy settings with such social media platforms.

c. Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

The types of cookies True may use on the Site include:

Necessary Cookies. These cookies are necessary for you to browse the Site and use its features, such as accessing secure areas of the Site. Without these cookies, certain aspects of the Site may not be available to you.
Personalization Cookies. These cookies collect information about how you have used the Site in the past and allow the Site to remember the choices you have made. These cookies allow us to improve how the Site works for you and tailor the Site to your preferences.
Analytics Cookies. These cookies collect information about how you use the Site, such as which pages you most often visit on the Site, the time you spend on the Site, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the Site.

We may also use third-party cookies, like Google Analytics, for example, which sets cookies on the Site to help analyze how visitors use the Site. You can visit https://www.google.com/settings/ads to learn more about Google’s use of cookies. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose.

Cookies help us improve the Site by providing us with information about which parts of the Site are most popular, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. We also use cookies to help improve your experience with the Site.
Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site. You may also manage your cookie preferences by clicking here.

2. How Information is Used

We may use the information we collect for any of the following purposes:

to provide the Site and Services to you;
to send marketing and promotional materials, including information relating to our Services;
to personalize the Site and Services we offer, and to give each user a more consistent and personalized experience when interacting with us;
for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site and Services;
to respond to your inquiries and communicate with you;
to, in an aggregated or de-identified form, generate industry reports about trends such as trends in hiring and compensation;
for our other business purposes, such as data analytics, accounting, auditing and reporting, improving the Site and Services, developing new products or services, identifying Site usage trends;
as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain;
other uses to which you consent.

For Candidates

to contact you about an employment opportunity with an Employer you may be interested in;
to enable you to apply to a position with an Employer
to conduct pre-employment assessments and interviews;
to allow an Employer to evaluate your qualifications and suitability for employment.

For Employers

to fulfill your requests, such as those related to ordering and payment;
to create and manage your account with us;
to enable you to search for Candidates and evaluate a Candidate’s qualifications and suitability for employment;
for customer service.

3. Disclosure of Information

We may disclose your information:

With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or Services, assist us in providing functionality on the Site, provide data analytics on the Site, send out email updates about the Site and our Services.
With Our Subsidiaries, Affiliates or Other Related Companies. We may share your information with our subsidiaries, affiliates or other related companies for our internal business purposes, including for marketing purposes and to assist with employment searches.
Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics service providers.
For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental or law enforcement request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, equity investment, or asset sale, or in the unlikely event of bankruptcy.

For Candidates:

Employers. If you are a Candidate, we may share your information with Employers. Employers may use and disclose your information according to their respective privacy policies.
Other Potential Employers. If you are a Candidate, we may also share your information with companies that may have an interest in candidates with your qualifications.

For Employers:

Candidates. If you are an Employer, we may share your contact information with Candidates who are interested in applying for a position with your company.

True does not share your personal information with third parties for those third parties’ direct marketing purposes.

4. Links to External Websites and Online Services

Our Site may contain links to third-party websites and online services. Any access to and use of such third-party websites and online services is not governed by this Privacy Policy but is instead governed by the privacy policies of those third-party websites and online services, and we are not responsible for the information practices of such third-party websites and online services.

5. Social Media

Some aspects of the Site may allow you to interface with social media, such as LinkedIn. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Site through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

6. Your Rights and Choices

a. Accessing, Correcting and Deleting Your Personal Information

If you have an account with us, you can review your personal information by logging into your account and visiting your account profile page. If you would like to delete your personal information, you may do so by deleting your account.

If you want to verify, correct or delete your personal information, you may send us an email at privacy@trueplatform.com to request access to, correct or delete your personal information. We may not accommodate a request if we believe complying with the request would violate any applicable law or if applicable law permits us not to comply with the request. We may request specific information from you to help us confirm your identity and to provide you with the personal information that we hold about you or make your requested changes or deletions.

b. Opt-out

You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in such emails or contacting us at privacy@trueplatform.com.

7. Data Security and Retention

True uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information. However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information.

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

8. Do Not Track Signal

Our Site does not currently take any action when it receives a Do Not Track signal request. The Do Not Track signal is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on the Do Not Track signal, visit www.donottrack.us.

9. Children

We do not knowingly collect or maintain personal information from any person under the age of 18. No parts of our Site are directed to or designed to attract anyone under the age of 18.

10. Nevada Residents

Under Nevada law, True does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us at privacy@trueplatform.com.

10. California Residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“CCPA”) provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information.

CCPA Rights

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting, selling or sharing personal information.
The categories of third parties with whom we disclose personal information.
The specific pieces of personal information we have collected about you.

You may also request that we disclose to you:

The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Delete

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your personal information. We do not sell your personal information for monetary consideration. However, we do use cookies for analytics purposes. The collection of data through certain tracking technologies may be considered a “sale” under the CCPA. To opt-out of having your information sold and shared with third-party website analytics service providers for this purpose, visit our “Do Not Sell or Share My Personal Information” web page.

True does not have actual knowledge that it sells or shares personal information about minors under the age of 18.

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct a business that collects sensitive personal information about you to limit its use of your sensitive personal information (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CCPA. True does not use or disclose any sensitive personal information for any purpose other than those permitted under the CCPA.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable request to us. You can do so by calling us at (888) 677-8471, emailing us at privacy@trueplatform.com or visiting https://privacy.trueplatform.com.

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

How We Collect, Use, Disclose, Sell and Share Personal Information

Please see Section 1.a (Personal Information) for the categories of personal information we have collected about you in the twelve (12) months prior to the effective date of this Privacy Policy. Each of the categories are disclosed for a business or commercial purpose as described above in Section 2 (How Information is Used) to the third parties listed in Section 3 (Disclosure of Information).

True collects the personal information described in Section 1.a (Personal Information) from or through the following categories of sources:

You, directly and indirectly, including when you access the Site, sign up to join our network or purchase our Services, register an account with us, contact us;
Service providers, including those that provide website analytics services to help us understand the activities taken on the Site;
Business partners, including our parent company, subsidiaries, affiliates or other related companies;
If you are a Candidate, Employers and third-party social media platforms (e.g., LinkedIn), subject to your registration and privacy settings with such social media platforms; and
Publicly available information.

As noted in Section 7 (Data Security and Retention), we will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations.

The following categories of personal information were sold or shared in the twelve (12) months prior to the effective date of this Privacy Policy:

Identifiers: unique personal identifier, online identifier, IP address.
Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, actions taken on the Site, approximate geographic location (e.g., country), language preference.
Geolocation Data: Approximate geographic location (e.g., country).

Such information is sold to or shared with our third-party website analytics service providers.

We share or sell such information:

to provide the Site and Services to you;
to send marketing and promotional materials, including information relating to our Services;
to operate, improve, and personalize the Services we offer, and to give each user a more consistent and personalized experience when interacting with us;
for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site and Services;
for our other business purposes, such as data analytics, accounting, auditing and reporting, improving the Site and Services, developing new products or services, identifying Site usage trends;
as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain; or
other uses to which you consent.

12. EU/UK/Switzerland Residents

With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”), any national law of an EU member state adopted pursuant to the GDPR, the United Kingdom Data Protection Act of 2018, and the Switzerland Federal Act on Data Protection (collectively, “European Data Protection Laws”), we serve as the “controller” and are located at True Europe, LLP,[address].

We process the personal data set forth in Section 1 (Information We Collect) above for the purposes set forth in Section 2 (How Information is Used) above. Our legitimate bases for processing such personal data include:

Performance of Contract. We may use your information to perform our contractual services or prior to entering into an agreement with you. If you use the Site or if you contact us to request information about our Services, we use your information to provide to you the features and functionality of the Site and our Services.
Legitimate Interest. We may use information for our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. For instance, we may use your personal data to contact you and respond to your requests and inquiries, to administer our business, including by creating statistical analyses, to identify prevent and detect fraud or to pursue or defend ourselves against legal claims.
Consent. We may use your information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, we will not be able to send you marketing materials that you request. You are also free to withdraw your consent at any time. A withdrawal of consent will not affect processing that has been completed during the time in which the consent was valid.
Fulfillment of Legal Obligations. We may use your information to comply with our legal obligations. To comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., respond to your requests to exercise your rights under European Data Protection Laws).

For information on whom we share your personal data with please refer to Section 3 (Disclosure of Information).

All personal data we collect is currently processed in the United States by us or by a party acting on our behalf. When you provide personal data to us, you consent to the transfer of your data to, and processing of your data in, the United States. The Site is currently hosted in the United States. We will transfer your personal data to the United States through the use of appropriate safeguards as required by European Data Protection Laws.

As noted in Section 7 (Data Security and Retention), we will retain your information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

Under European Data Protection Laws, you have the following privacy rights, which you may exercise by calling us at (888) 677-8471 or emailing us at privacy@trueplatform.com:

Right of Access. You have the right to obtain confirmation as to whether your personal data is being processed, as well as access to the personal data along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
Right to Rectification. You have the right to rectify your inaccurate personal data and to complete any incomplete personal data, including by means of providing a supplementary statement.
Right to Erasure or Right to be Forgotten. You have the right to erase your personal data under certain circumstances.
Right to Restrict Processing. You have the right to restrict our processing of your personal data under certain circumstances.
Right to Object. You have the right to object, on grounds relating to your particular situation, at any time to our processing of your personal data, which is based on public interest or our legitimate interests, including the profiling of data. In this case, we will stop processing your data, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims. You also have a right to object to the processing of your personal data for direct marketing purposes.
Right to Data Portability. Under certain circumstances, you have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller without hindrance from us.
Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal data, you may withdraw your consent at any time to stop any further processing.
Right to Lodge a Complaint. You have a right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates the European Data Protection Laws.

13. Questions / Contact Us

If you have any questions regarding this Privacy Policy, please contact us at:

US:
True Talent Advisory LLC

3 Logan Square
1717 Arch Street Floor 46
Philadelphia, PA 19103

Europe:
True Europe, LLP

MidCity Place,
71 High Holborn
London United Kingdom WC1V 6EA

ATTN: Privacy Officer
privacy@trueplatform.com
(888) 677-8471

14. Notification of Changes

Any changes to our Privacy Policy will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change.