Last modified: August 2, 2019
This Policy applies to information we collect:
- on our Sites;
- in email, text, and other electronic messages between you and our Sites;
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by us or any third-party; or
- any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.
Children Under the Age of 13
Our Sites are not intended for children under the age of 13 and children under the age of 13 are not permitted to use our Sites. We will remove any information about a child under the age of 13 if we become aware of it
Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect Information You Give Us and Information We Collect Automatically.
How We Use Information
We use your Personal Data for various purposes described below, including to:
- provide our Sites to you;
- provide you with information you request from us;
- enforce our rights arising from contracts;
- notify you about changes; and
- provide you with notices about your account.
Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
How We Share Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Policy. We disclose your Personal Data to a few third parties, including:
- our subsidiaries and our affiliates;
- our third-party service providers that we use to support our business;
- to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
International Resident Rights
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Consent to Processing Outside the European Economic Area
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
Closing Your Account and Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and
- and to comply with other legal requirements.
Information transmitted over the Internet is not completely secure, but we institute measure designed to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Sites confidential.
Data Controller, Data Protection Officer, and Representative
CyberSN is the data controller of the Personal Data you provide on the Site and has appointed a Data Protection Officer and a representative.
We will post any changes to our Policy on our Sites. If we make material changes to our Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.
You may contact us or our Data Protection Officer through the contact information below.
2. Children Under the Age of 13
Our Sites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Sites. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Sites or on or through any of its features/register on the Sites, make any purchases through the Sites, use any of the interactive or public comment features of our Sites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 13, please Contact Us as described below.
3. Information We Collect About You and How We Collect It
In order for us to provide you our services it is essential that we collect and use the information as described in this Policy. We collect information about you to provide our services as described below (“Personal Data”):
- by which you may be personally identified, such as name, postal address, e-mail address, and telephone number;
- that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit, error information, clickstream data, and other communication data and the resources that you access and use on the Site; and/or
- about your internet connection, the equipment you use to access our Site, and usage details.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the Sites; and
- from third parties, for example, our business partners.
Information You Give Us
We collect information for processing and use in accordance with this Policy when you perform actions such as completing registration forms, creating profiles, submit your resume, or provide us with other Personal Data. Because offerings and features may change from time to time, the options you have to provide us with Personal Data also may change. The following are examples of providing actions where you are Personal Data to us:
- Signing up for email alerts or notifications
- Creating an account
- Completing a form related to our products or services
- Submitting a resume
- Contacting us for technical support or customer service
- Entering a contest or promotion sponsored by us
- Responding to a survey that we might ask you to complete for research or other purposes
- Carrying out a transaction on our Site and placing orders on our Site, during which we may require you to provide financial information
- Searching for information on our Site
- Reporting a problem with our Site to us
The Personal Data you submit through the processes about will be collected by us on or through our Site. The Personal Data we collect from you is required to enter into a contract with u, for us to perform under the contract, and for us to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it. Depending on how you interact with our Sites, the information we collect from you may vary. For example, to create an account we may ask only for an email address and password. In other circumstances, such as when you complete a form related to a service, we may ask you to provide other information, which may include your name, phone number, and/or postal address. We also collect and store certain information associated with actions you take. For example, when searching for jobs, we store the titles, locations and general salary range, when applicable, of jobs you search. We also store information about the job postings that you apply to, the time and duration of your activity on our Sites, and other information about your behavior on our Sites to enhance usability and performance.
When you set up an individual user account on the Sites, you may create a profile (a “Profile”) that will include Personal Data you provide. When complete and save your Profile, your saved Profile can be viewed by prospective employers, subject to visibility settings you control. Your covert Profile on our Sites is important does not include or link to information you submit to the Sites unless you wish to reveal this information.
If you enter credit card information on the Sites in connection with a purchase, the information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
When you submit Personal Data to a third party and are informed at the time of collection that your information may be shared with us, we may collect that information for lawful marketing purposes.
Information We Collect Automatically
When you use the Sites, your device is automatically providing information to us. The type of information we collect by automated means generally includes technical information about your device, browsing actions, and patterns, including log file information that is automatically reported by your browser or mobile device each time you access the website or our Sites. The information we automatically collect may include information such as:
- information about your computer and internet connection, such as your IP address, operating system, and browser type; usage information and statistics about your interaction with the Sites, such as the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, Sites type, location data, date and time of your visit to our Sites, error information, clickstream data, and other and communication data and information about how you used the Sites; and
- information about the device you use to access the Sites, including type of device, operating system, settings, and unique device identifiers, and IP address. We may also use analytics software to allow us to better understand the functionality of our Sites on your phone. This software records information such as how often you use our Sites, the events that occur within the our Sites, aggregated usage, performance data, and where our Sites were accessed from. We do not link the information we store within the analytics software to any Personal Data you submit within our Sites.
The information we collect automatically is statistical data and does not include Personal Data but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Sites and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Sites, according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Sites.
We do not collect Personal Data automatically, but we may tie this information to Personal Data about you that we collect from other sources or you provide to us.
4. How We Use Information
We use the information collected to provide our services and have a legitimate interest in using the information we collect, including Personal Data. We use information that we collect about you or that you provide to us, including any Personal Data for these purposes:
- to present our Sites and their contents to you;
- to provide you with information, products, or services that you request from us;
- to fulfill any other purpose for which you provide it and otherwise authorize;
- to provide you with personalized content, services and offers by CyberSN, as well as other promotional content and services and provide you with recommended jobs on CyberSN;
- to customize and improve the features, performance, and support of the CyberSN website and Sites;
- to provide you with notices about your account and subscription, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Sites or any products or services we offer or provide though them;
- to recommend a you to an employer hosted by CyberSN, subject to visibility settings you control. For example, CyberSN may use Sites materials such as covert profiles and functional roles to determine whether the job seeker’s collected qualifications match a job posting and vice-versa, we may then differentiate matching profiles and or jobs that do not match, and present them to employers as matches or not matches;
- to allow you to participate in interactive features on our Sites, such as sharing your saved Profile with employers, subject to visibility settings you control;
- to improve internal operations, including detecting and preventing fraud and unsolicited email, troubleshooting, data analysis, testing, research, and service improvement;
- to create aggregated statistical data that does not identify you individually;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent
5. Lawful Basis for Processing Your Personal Data
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
- Consent. By using our Sites, you consent to our collection, use, and sharing of your Personal Data as described in this Policy. If you do not consent to this Policy, please do not use the Sites;
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between us and you; detect and correct bugs and to improve our Sites; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; and develop our product and services;
- To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you; and
- As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
6. How We Share Information
We do not share, sell, or otherwise disclose your Personal Data to third parties other than as outlined below. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this Policy:
- to our subsidiaries and affiliates;
- to affiliated and unaffiliated contractors, service providers, and third parties all over the world that we use to support our business, including payment processing, web servers, cloud storage systems, CRM providers, email services, content support teams, and marketing partners. These companies are subject to strict confidentiality agreements and are authorized to use your Personal Data only as necessary to provide these services to us. Our payment processor’s privacy policies may be found at http://stripe.com/us/privacy.
- if we believe in good faith such disclosure is necessary
- to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us; including to respond to any government or regulatory request
- when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity
- as we deem necessary and is permitted by applicable laws to protect and defend the rights or property, rights, or safety of us, the users of our services, or third parties;
- as permitted under applicable laws to meet national security and similar requirements.
- to the acquirer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Sites’ users is among the assets transferred;
- to fulfill the purpose for which you provide it; For example, if you apply for a particular job through the Sites, we may disclose your Personal Data to the employer to whom you apply, subject to visibility settings you control;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
7. International Resident Rights
If you are a resident of the European Economic Area (“EEA”), or any other country providing it’s residents the rights substantially similar to the GDPR, you have the following data protection rights:
- Access and Update. If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided under the Contact Us section of this Policy. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You can object to the processing of your Personal Data or ask us to restrict processing of your Personal Data. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law. Again, you can exercise these rights by contacting us using the contact details provided under the Contact Us section of this Policy.
- Portability. To the extent the Personal Data you provide to us is processed based on your consent or that we process through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Opt Out. 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 emails we send. You may contact us using the contact details provided under the Contact Us section of this Policy.
- Withdrawal of Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time by closing your account. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- Complaints. You have the right to complain to a data protection authority about our collection and use of your Personal Data in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. For more information, you may contact your local data protection authority. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
You may exercise any of the above rights by contacting us through any of the methods listed under Contact Us below. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
8. Consent to Processing Outside the European Economic Area
In order to provide our Sites, products, and services to you, we may send and store your Personal Data outside of the EEA or other jurisdiction of which you are a resident, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.
9. Closing Your Account and Data Retention Periods
If you’d like to close your CyberSN account, you can do so within your Account Settings on the Sites or using the contact details provided under Contact Us below. When you close your account, you will no longer have access to Sites information and any content you have submitted. After you close your account, we may retain your Personal Data:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
If, after you close your account, you wish to know which Personal Data we keep you may contact us using the contact details provided under Contact us below.
We keep your Personal Data only so long as you keep your account open with us and otherwise as necessary fulfill the purposes described in this Policy. This is also the case for anyone that we share your Personal Data with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When you have closed your accounts and we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.
10. Security Safeguards
We have implemented measures designed to protect your information from accidental loss and from unauthorized access, use, alteration, and disclosure by using industry-recognized security safeguards along with carefully developed security procedures and practices.
We maintain physical, electronic and procedural safeguards that comply with applicable laws and federal standards. We use both internal and external resources to review our security procedures. All information you provide to us is stored on our secure servers behind firewalls. Your payment transactions and sensitive information will be encrypted using SSL technology.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Sites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
If you see a suspicious or fraudulent activity, please contact us.
11. Data Controller, Data Protection Officer, and Representative
The information about you that we collect, process and/or use through the Sites is controlled by CyberSN. CyberSN is the data controller of your Personal Data. CyberSN and the services it provides are hosted and provided outside of the European Economic Area (EEA), including in the United States, for the purposes described in this Policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.
CyberSN has appointed a Data Protection Officer and a representative in the European Union in compliance with the General Data Protection Regulation. CyberSN, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Us” Section of this Policy and you may reach our data protection officer, here.
13. Contact Us
You may contact our Data Protection Officer through the contact information below. If you have any suggestions or questions regarding this Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact both us, and our representative in the European Union at the contact information below or please contact us.
Attn: Chief Security Officer
PO Box 222
North Brookfield, MA 01535-0222