This Policy explains how and why we collect, store, use, and share your Personal Information.  It also explains your rights related to your Personal Information, including how to contact us in the event you have a complaint.

We collect, use, and are responsible for certain Personal Information about you.  When we do, we are subject to various laws in the United States, the European Union, Australia, Singapore, and other countries.  This Policy helps us comply with those laws.

This Policy does not cover the practices of companies we do not own or control or people we do not manage.  For clarity, this policy applies when LeadCrafters acts as a “Controller” as defined in the General Data Protection Regulation (the “GDPR”) or “Business” as defined under the California Consumer Privacy Act (the “CCPA”) or when we otherwise process Personal Information of our leads in connection with our provision of services to customers, in which case we are the processor of Personal Information. If we are the processor or service provider for your Personal Information (i.e., not the Controller or Business), please contact the controller or business to address your rights with respect to such data under the GDPR, CCPA, or other laws.

Please read the following carefully to understand our views and practices regarding your Personal Information as an Applicant, Employee, Customer, or General Consumer/Website Visitor.

1. Key Terms. It would be helpful to start by explaining some key terms used in this Policy:

2. How We Collect Personal Information.  We collect most Personal Information directly from you when you provide such information directly to us and when such information is collected in connection with your application for employment, employment, through our lead generation techniques—in person, by telephone, text, email, web applications, and/or via our website.

We may also collect information:

• From publicly accessible sources (e.g., property records).

• Directly from a third-party “Service Providers” (e.g., background screening providers; toxicology screening providers, credit reporting agencies; current or past employers; current or past educational institutions; analytics providers; providers to improve customer support or service; banks and payment processing services; and insurers and brokers).

• Our subsidiaries and affiliates (together, “Affiliates”).

• From cookies on our website and in conjunction with third-party providers. Please see our Cookie Policy on our website at [https://theleadcrafters.com/cookies-notice/].  This Cookie Policy can be read together with this Policy for the collection, use, and rights associated with Personal Information from cookies.

• Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems, and security systems, such as door-entry systems, receptions logs, CCTV, and other access-control systems.

3. Personal Information We Collect About You. We may collect and use the following Personal Information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with you, a particular consumer or household:

1. Information We Collect from Applicants for Employment and Employees

2. Information We Collect from Customers

1. Information We May Collect from Generated Leads

This Personal Information is required for generated leads to provide qualified lead data to our Customers (referred to herein as a “Qualified Lead”), discussed in further detail below.  We collect, store, and provide your Qualified Lead data to Customers as a Qualified Lead if you have consented to Us to do so.  In countries that require double opt-in consent (e.g. Austria, Germany, Greece, Switzerland, Luxembourg, and Norway), we collect, store, and provide your Qualified Lead data to Customers as a Qualified Lead if you have doubly consented to Us to do so.

2. Information We May Collect from General Consumers and Website Visitors

This Personal Information is required to provide employment or services to you. If you do not provide the Personal Information we ask for, it may delay or prevent us from providing employment or services to you or providing you as a Qualified Lead.

4. Children Under the Age of 18.

Our website, services, and applications are not intended for children under the age of 18 without parental consent.  If you are under the age of eighteen (18) and wish to seek a consultation through our website, your parent or legal guardian must create the account, submit your personal information, and agree to this Policy on your behalf.  If you are under the age of 13, you may only use our services and access our website with the supervision and consent of your parents or legal guardians.  If we learn that we have collected Personal Information from someone under the age of 13 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will promptly delete that information.  If you believe we have impermissibly collected Personal Information from someone under the age of 13, please contact us using the information below.

5. How We Store Your Personal Information.

1. Security.  We take appropriate measures to ensure that all Personal Data is kept secure, including security measures to prevent Personal Information from being accidentally lost, or used or accessed in an unauthorized way, for the duration of your use of our Services.  We limit access to your Personal Information to those who have a genuine business need to know it.  Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.  We impose contractual obligations on Service Providers to ensure they only use Personal Information to provide services to us and to you.  For generated leads, we also impose contractual obligations on Customers to ensure they only use any Personal Information shared in qualified lead data to market, advertise, or sell to you, or in another way allowable by laws and regulations.

We also have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to us or our website, therefore any transmission remains at your own risk.  Once we have received your information, we will use strict procedures and security features in order to prevent unauthorized access.

2. Keeping Your Personal Information Up to Date.  If your personal details change, you may update them by contacting us at [dataprotection@theleadcrafters.com].

We will attempt to update your Personal Information within thirty (30) days of any new or updated Personal Information being provided to us, in order to ensure that the Personal Information that we hold about you is as accurate and up to date as possible.  For more information about this process, please see the section about “Your Rights” below.

3. Where We Store Your Personal Information.  Personal Information may be held at our offices and those of our service providers, representatives, agents, and third parties as described above.  For generated leads, your Personal Information may also be held at the offices and technology of our Customers that purchased your generated lead data.  For more information about who may store your Personal Information, see the section about “Who We Share Your Personal Information with” below.

If you are a subject of the European Union, the data that we collect from you and process as a result of an application for employment, employment, lead generation, use of our services, or use of our website may be transferred to, and stored at, a destination in the United States, Mexico, India, Australia, or other countries—areas outside the UK or the European Economic Area (“EEA”).  It may also be processed by staff operating in the United States, Mexico, India, Australia, or other countries—areas outside the UK or the EEA who work for us or for one of our suppliers.

Such staff maybe engaged in, among other things, lead generation, the fulfilment of your service, the processing of your payment details, or the provision of support services.  By submitting your Personal Information, you agree to this transfer, storing, or processing.  Some of these third parties may be based outside the EEA.  For more information, including on how we safeguard your Personal Information when this occurs, see “Transferring Your Personal Information Out of the EEA” below.

4. How Long Your Personal Information Will Be Kept.  We will keep your personal information while you have an application for employment, employment, or an account with us or while we are providing services, employment screening, or employment to you.  For generated leads, we will keep your information as long as you fit our current or prospective Customers’ lead profile. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;

• To consider applicants for other future employment opportunities that may arise;

• To show that we treated you fairly; or

• To keep records required by law.

5. Transferring Your Personal Information Out of the EEA.  To deliver services to you or provide your lead data to our Customer, it is necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• With our offices outside the EEA;

• With your and our service providers located outside the EEA;

• If you are based outside the EEA;

• Where there is an international dimension to the services we are providing to you; or

• To our Customer outside of the EEA if you are generated lead for them.

These transfers are subject to special rules under European and UK data protection law.

6. Why We Use Your Personal Information.  Under data protection laws, we can only use your personal information if we have a proper reason for doing so, e.g.,

• To comply with our legal and regulatory obligations;

• For the performance of our contract with you or to take steps at your request before entering into a contract;

• For our legitimate interests or those of a third party; or

• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your Personal Information for and our reasons for doing so:

The sources for the Personal Information identified above can be found “How We Collect Personal Information” above.  To see who we share Your Personal Information with, see “Who We Share Your Personal Information With” below.

In the case of our generated leads, you provided affirmative consent—through your activity on our website or our affiliates website; via email; over the telephone; by writing; or in person—for LeadCrafters and its affiliates to transfer and share your Personal Information with our Customers as Qualified Leads and transfer your Personal Information outside of the EEA when applicable.

1. E-mail and Text Communications. We may use your personal information to send you updates or communications by email, text message, telephone or post about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes, as explained above in “How We Use Your Personal Information.”  This means we do not usually need your consent to send you promotional communications.  However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by contacting us at dataprotection@leadcrafters.com or by using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

7. Who We Share Your Personal Information With.  We routinely share Personal Information for Employment Applicants, Employees, Generated Lead, Customers, and General Consumers and Website Visitors:

1. Information for Employment Applicants.  To process an applicant’s employment application, we routinely share Personal Information with:

• Our third-party Applicant Tracking System;

• Our talent acquisition team including, but not limited to, our hiring managers, operational leaders responsible for any role(s) that you have applied and for future positions that may become available, and other employees that may interview or consider you for employment for either a position that you have applied or future positions that may become available;

• Affiliates;

• Service Providers necessary for pre-employment screening including social media sites; and

• Other third parties we use to help run our business and are necessary for pre-employment screening, including customers in the instance where we plan to place an Employment Applicant at a customer’s location for a significant time.  However, when we share an Employment Applicant’s Personal Information with customers for pre-employment screening purposes, we only share the Employment Applicant’s name and employment history—we do not share any Sensitive Personal Information.

2. Information for Employees and Their Provided Spouses, Partners, Children, and Beneficiaries.  To process an employee’s information (including information provided by the employee regarding their spouses, partners, children, or beneficiaries), we routinely share Personal Information with:

• Our third-party Employee Benefits System;

• Our talent acquisition team and other employees necessary to provide human resources services;

• Affiliates;

• Service Providers necessary to provide employment and other human resources support; and

• Other third parties we use to help run our business and are necessary to provide employment and other human resources support.

3. Information for Generated Leads and Qualified Leads.  To Generate Leads for Customers, we routinely share Personal Information with:

• Our employees necessary to generate leads, provide leads to our Customers, provide our services and customer support.;

• Service Providers necessary to provide and help deliver our services;

• Affiliates;

• Customers as Qualified Leads;

• Other third parties we use to help run our business and necessary to provide our services and support customers.

4. Information for Customers.  To process Customers’ information, we routinely share Personal Information with:

• Our employees necessary to provide our services and customer support;

• Service Providers necessary to provide and help deliver our services;

• Affiliates; and

• Other third parties we use to help run our business and necessary to provide our services and support customers.

5. Information for General Consumers and Website Visitors.  To process information for general consumers and website visitors, we routinely share Personal Information with:

• Affiliates;

• Service providers we use to help deliver our services and maintain our website; and

• Other third parties we use to help us run our business, such as social media sites, search engines, marketing agencies or website hosts.

As explained in “How We Store Your Personal Information” above, we impose contractual obligations on Service Providers to ensure they only use Personal Information to provide services to us and to you.  For generated leads, we also impose contractual obligations on Customers to ensure they only use Personal Information shared as Qualified Leads to market, advertise, or sell to you, or in another way allowable by laws and regulations.

6. General Information Sharing.  We may also share Personal Information with:

• External auditors;

• Law enforcement agencies;

• Courts as required by a court order or required by litigation;

• Regulatory bodies to comply with our legal and regulatory obligations; and

• Other parties, such as potential buyers of some or all of our business or during a re-structuring.  In this event, we will typically anonymize information, but this may not always be possible.  The recipient of the information will be bound by confidentiality obligations.

7. Sales of Personal Information.  In the last 12 months, we have not sold Personal Information of employee applicants, employees, Customers, or general consumers or or website visitors to any third parties that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.  However, with your affirmative consent, we do sell Qualified Lead information, which may include Personal Information of generated leads, to our Customers. For generated leads, in the last 12 months, we have sold to one or more customers the following categories of Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household:

• Identifiers (including Sensitive Personal Information under some laws and regulations);

• Characteristics of protected classifications under some laws and regulations;

• Internet or other electronic network activity information;

• Professional or employment-related information; and

• Inferences drawn from any of the Personal Information identified above to create a profile about an individual, group of, or aggregate lead(s) and consumer(s) reflecting preferences, characteristics, psychological or other trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes, or any other necessary business purpose.

8. Disclosure of Personal Information for Business Purposes.  As described in subsections (a) through (e) above, in the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular employment applicant, employee, customer, consumer, website visitor, individual, or household:

• Identifiers (including Sensitive Personal Information under some laws and regulations);

• Characteristics of protected classifications under some laws and regulations;

• Biometric information;

• Internet or other electronic network activity information;

• Professional or employment-related information; and

• Inferences drawn from any of the Personal Information identified above to create a profile about an individual, group of, or aggregate employment applicant(s), employee(s), customer(s), general consumer(s), and website visitor(s) reflecting preferences, characteristics, psychological or other trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes, or any other necessary business purpose.

8. Your Rights to Your Personal Information

1. Under the European Union (i.e. the GDPR).

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

2. Your Rights Under North American Privacy Laws (including but not limited to the laws of Canada, the United States, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Montana, New Hampshire, Nebraska, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia), Under South American Laws (including Argentina, Brazil, and Colombia), and Under Asia-Pacific Laws (including Australia, New Zealand, China, Hong Kong, Philippines, Singapore, South Korea, Armenia, Israel, and Turkey), and Under African Laws (including Benin Republic, Kenya, Nigeria, and South Africa).   While all of these countries and states do not have the same rights, we provide these rights that meet or exceed the rights of these countries or states.  Therefore, you have the right under the California Consumer Privacy Act (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

3. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

• Complete a data subject request form available on our website at OPT-OUT ;

• Call us at + 1 (205) 578-7579;

• Email us at dataprotection@theleadcrafters.com; or

• Write to us at: info@theleadcrafters.com

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address, and email address);

• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

• A description of what right you want to exercise and the information to which your request relates.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.  We are not obligated to make data access or data portability disclosures if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

4. How to File a Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

Many laws also give you the right to lodge a complaint with a supervisory authority.  For example, in the European Union (or EEA), you can lodge a complaint in the state where you work, normally live, or where any alleged infringement of data protection laws occurred.  Similarly, under the CCPA in California, you can lodge a complaint with the California Attorney General’s office.  If you need help finding the proper authority to lodge a complaint, please contact us at [dataprotection@theleadcrafters.com], and we will respond with the appropriate authority, if applicable, within 30 days.

9. Changes to this Privacy Policy. We may change this Policy from time to time.  We are required by the CCPA, GDPR, and other privacy laws to review and update this Policy once every 12 months.  We will notify employment applicants, employees, customers, and generated leads of changes or updates to this Policy that reflect a substantial or material change to this Policy.  We will send such notifications before the changes to this Policy take effect.

10. How to Contact Us. Please contact us by post, email or telephone if you have any questions about this Policy.  Our contact details are shown below:

11. If You Need Extra Help or Disability Accommodations? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).