Privacy Policy.

Last revised on May 8, 2020.

This privacy policy (“Privacy Policy”) describes True Capital Partners, LLC’s (“True Search”) and its affiliates’ and subsidiaries’ practices for collecting, using, sharing, and protecting personal information.

When a potential candidate uses True Search’s services to submit a resume or inquire about job openings, you direct us to engage with an ecosystem that will help you find your next opportunity. To help you, we will need to share your information with companies seeking job candidates and business partners that assist with employment searches, such as AboveBoard, Inc.

To comply with privacy requirements in Europe and California, we have provided additional details about our privacy practices to users in the European Union, European Economic Area, United Kingdom (collectively “Europe” or “European”) and California.

Collection and Processing of Your Personal Information

Personal information means information that identifies, or can be used to identify, you as an individual. Non-personal information means information that does not directly identify you. We collect both types of information about you.

We collect personal information about you from a variety of sources, including when you visit our website, when you voluntarily provide information to us, when information is publicly posted (e.g., Google, Facebook, Twitter, etc.), or when we receive it from third parties, such as our clients.

There may be instances in which the information that we collect is considered sensitive personal information under the laws of the country or state in which you reside. As a general matter, we only collect sensitive personal information when it is necessary or when you provide it to us voluntarily (e.g., in a resume).

Types of Information, Purpose for Collection, and Use of Information

The following are some examples of the type of information that we collect and what we use that information for:

Business Contacts. We collect business contact information, and billing information, from our clients and our potential clients for a legitimate business purpose. We use this information in order to provide products, services, or information about our products and services.
Potential Candidates. True Search gathers personal information about individuals who might be interested in a current, or future, position with a True Search client. Such information includes address, contact information, job role, function, social media presence, investment information, or work or educational experiences, and other information that may be included in a resume.
Email Interconnectivity. If you receive email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners/images within it. We may also take the information in your emails and add it to our contacts and log it with our customer relationship management (CRM) system.
Employment. If you apply for a True Search job posting, or become an employee at True Search, we collect information necessary to process your application or to further the employment relationship. This may include, among other things, your Social Security Number/National Insurance Number.
Feedback/Support. If you contact us or provide feedback, we will collect your name and email address, as well as any other content that you send to us, in order to reply.
Mailing List. When you sign up for one of our mailing lists we collect your name, email address, resume, LinkedIn/website address, how you heard about us and the reason for your contact.
Mobile Devices. We collect information from mobile devices such as location and unique identifying information broadcast from devices when visiting our website using HubSpot and Google Analytics.
Surveys. If you participate in a survey, we may collect information you provide such as your contact information, job details, and experience with True Search.
Web Logs. We collect your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when using the Internet), domain name, click-activity, referring website, viewed websites and/or a date/time stamp for visits.
Online Activity. We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. We use both session cookies (which expire once a web browser is closed) and persistent cookies (which stay on a device until deleted). Among other things, cookies allow us to provide a more personal and interactive experience and to improve our marketing efforts. You may remove certain cookies as described here. If cookies are disabled some areas or features of our websites may not work properly. We allow our analytics partners to place cookies on our websites as described here.

Use of Information

In addition to the purposes and uses described above, we may use personal information in the following ways:

To contact potential candidates who may be interested in an employment opportunity with one of our clients.
To identify you when you visit our websites.
To respond to your inquiries related to support, employment opportunities, or other requests.
To provide our products and services.
To improve our services and product offerings.
To conduct analytics.
To send marketing and promotional materials, including information relating to our goods, services, sales, or promotions.
For internal administrative purposes, as well as to manage our relationship with you.
To, in an aggregated or anonymized form, generate industry reports about trends such as trends in hiring and compensation.
To assess whether you may become a potential client in the future.
For compliance, fraud prevention and safety, including to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request.
To comply with law.
Other uses to which you consent.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

Affiliates. We may share personal information with our affiliates in connection with processing your inquiries, providing services, and improving our products and services. In limited situations we may also share business contact information with one of our affiliated companies so that they can provide you with information concerning the products or services that they provide.
Business Partners. When a potential candidate uses our services to submit a resume or inquire about job openings, you direct us to engage with an ecosystem that will help you find your next opportunity. To help you, we will need to share some of your information with business partners that assist with employment searches, such as AboveBoard, Inc. Some of the business partners are our affiliates and others are non-affiliated businesses.
Clients. True Search may share information about potential candidates with our clients. True Search clients may use and disclose such information according to their respective privacy practices.
Other Potential Employers. We may share unsolicited resumes or solicitations from potential candidates with companies that may have an interest in such candidates.
Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request.
Service Providers. True Search may provide personal information to third parties that act as agents, consultants or contractors to perform tasks on behalf of and under True Search’s instructions. Such recipients must agree to abide by confidentiality obligations and are not permitted to use your personal information except for the limited purpose that we request.
Third-Party Tracking Companies. We may share your information with third-party tracking companies, including analytics partners. These third parties may also collect information directly from you as described in this Privacy Policy over time and across different websites. The privacy policy of the third party company applies to their collection, use and disclosure of your information. For example, one of our partners is HubSpot, which collects and stores information from you such as email address, first name, last name, phone number, job role, function, company, location, investment information and social media presence. Another example is Google Analytics, which collects information anonymously and reports website trends without identifying individual visitors.
Corporate transactions. We may also share your information if another company acquires our company, business, or our assets, or in the event of a bankruptcy or reorganization.

Retention of Information

We retain personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual requests that we delete information about them.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We may retain and use this anonymized information for our business purposes.

Protecting Information

True Search uses reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while True Search strives to protect your personal information, we cannot guarantee the security of personal information. In the event that True Search is required to notify you about a situation involving your data, we may do so by email, telephone, or mail to the extent permitted by law.

Your Choices

You can make the following choices regarding your personal information:

Access, Transfer, Correction, and/or Deletion of Your Personal Information. You may request to access, transfer, correct, or delete the personal information that True Search has collected about you by writing to the contact listed below under the section titled “Contact Information.” When we delete personal information, it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it.
Ability to restrict or object to processing. You may request to restrict our continued processing of your personal information or object to our reliance on legitimate interests as the basis of our processing of your personal information. If we receive an objection, we will evaluate whether we are required by law to discontinue such processing.
Online Tracking. You may opt out of certain third-party online tracking as described here. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive or contacting us. If you decide not to receive promotional emails, we may still send you service-related communications.
Opt-Out / Revocation of Consent. If we rely on your consent to process personal information, you may revoke that consent by contacting us. Note that in some situations we may no longer be able to provide you services if you revoke your consent; we may also limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
Different Purposes. If we use your information for a materially different purpose than the purpose for which we collected it, we will notify you, as required by law.

Transmitting Information to Other Countries

Personal information may be processed in a country where you do not reside that has privacy laws that may be less stringent than the laws in your country. Where possible, we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us, you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us.

Contact Information

If you have any questions or concerns related to this Privacy Policy, please contact True Search.

US:

True Capital Partners, LLC
56 N Haddon Avenue
Haddonfield, New Jersey 08033

Europe:

True Europe, LLC
Swan House 37-39 High Holborn
London
WC1V 6AA
UK

ATTN: Privacy Officer
privacy@trueplatform.com
(888) 966-4410

(or)

+44 203 795 6998

European users who are not satisfied with our response may have a right to lodge a complaint with your local supervisory authority.

Miscellaneous

Modifications to Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, we will notify you of the change.
Affiliated Companies. Some True Search affiliates, programs and/or sites may have their own, possibly different, privacy policies. True Search encourages you to read the privacy policies of any of True Search’s affiliate websites that you may visit.

Additional Information for European Users

Controller

True Search is the controller of your personal information covered by this Privacy Policy. See the Contact Information section above to contact our Data Protection Officer.

Legal bases for processing

The legal bases for our processing of your personal information are described below.

To provide our products and services. Where we have an agreement governing this purpose, processing is necessary to perform the contract governing our provision of services or to take steps that you request prior to signing up for our services.When we collect sensitive information, such as through a resume, we process such information as necessary to carry out obligations in the field of employment or rely on the individual’s consent.In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To perform processing activities that constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).The following processing activities constitute our legitimate interests:
- To contact potential candidates who may be interested in an employment opportunity with one of our clients.
- To identify you when you visit our websites.
- To respond to your inquiries.
- To send marketing and promotional materials.
- To conduct analytics.
- For internal administrative purposes.
- To, in an aggregated or anonymized form, generate industry reports about trends.
- To assess whether you may become a potential client in the future.
- For compliance, fraud prevention and safety.
To comply with law. Processing is necessary to comply with our legal obligations.
Other uses. Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested the consent or by contacting us.

Cross-border data transfer

Whenever we transfer your personal information out of Europe to countries not deemed by the European Commission to provide an adequate level of personal information protection, we will transfer the information:

Pursuant to the recipient’s compliance with Standard Contractual Clauses, EU-US Privacy Shield, or Binding Corporate Rules,
Pursuant to the consent of the individual to whom the personal information pertains, or
As otherwise permitted by applicable European requirements.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Notice to California Users

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information.

This notice and the privacy rights it describes do not apply to information related to our business contacts, job applicants, or employees.

Personal Information that We Collect, Use and Share

The information below describes how we currently collect, use and share personal information, and how we have collected used and shared personal information over the past 12 months. The below information may not cover information you volunteer to us, such as in correspondence.

We do not sell personal information. We engage in:

Online tracking. As we explain above, we use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to learn how you may opt out of our (and third-party tracking companies’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.
Directed disclosures. In addition, when you use our services to submit a resume or inquire about job openings, you direct us to engage with an ecosystem that will help you find your next opportunity, including by sharing your information with companies seeking job candidates, job leads, and business partners that assist with employment searches.

We may collect, use and share personal information in the following ways:

Potential Candidates’ Information and Mailing List Information
- Sources of personal information: Potential candidates, clients, and publicly available sources (e.g., social media platforms)
- CCPA categories of personal information collected: Identifiers, commercial information, professional information, education information, and protected classification characteristics
- Business/commercial purposes for which we may collect and use personal information:
  - To provide our products and services.
  - To contact potential candidates who may be interested in an employment opportunity with one of our clients.
  - For internal administrative purposes.
  - To conduct analytics.
  - To send marketing and promotional materials.
  - To, in an aggregated or anonymized form, generate industry reports about trends.

- Data sharing: By using our service, you direct us to disclose this information with companies seeking candidates and business partners that assist with employment searches.

- - Email Interconnectivity, Mobile Devices, Web Logs, and Online Activity
- Sources of personal information: Automatically collected
- CCPA categories of personal information collected: Online identifiers, internet or network information, and geolocation data
- Business/commercial purposes for which we may collect and use personal information:
  - To identify you when you visit our websites.
  - To conduct analytics.
  - For internal administrative purposes.
- Data sharing: This information is collected directly by third-party tracking companies.

Surveys and Feedback/Support
- Sources of personal information: Potential candidates
- CCPA categories of personal information collected: Identifiers, commercial information, and professional information
- Business/commercial purposes for which we may collect and use personal information:
  - To provide our products and services.
  - To respond to your inquiries.
  - To conduct analytics.
  - For internal administrative purposes.
  - To, in an aggregated or anonymized form, generate industry reports about trends.
- Data sharing: We do not share this information.

Please note that we may also disclose personal information with service providers, and in connection with corporate transactions or compliance.

California Residents’ Privacy Rights

The CCPA grants California residents the following rights:

Information. You can request information about how we have collected, used and shared your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in the above chart.
Access. You can request a copy of the personal information that we have collected about you.
List of Third-Party Marketers. Under California’s Shine the Light law, True Search users who are California residents may request a notice identifying the categories of personal information that we share with third parties for their own direct marketing purposes, and such third parties’ contact information.
Deletion. You can ask us to delete the personal information that we maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain information we maintain for compliance in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination, as prohibited by the CCPA.

How to Submit a Request

To request access to or deletion of personal information:
- call 800-218-0340
- email privacy@trueplatform.com
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.