Kennect Privacy Policy

Effective September 2015 | Last updated September 16, 2015

Kennect Privacy Statement

This Privacy Policy covers the information practices of the TalentWise website which provides various HR-related services to your employer or potential employer (referred to as "Kennect"). The data controller of Kennect is TalentWise, Inc., whose principle place of business is 19910 North Creek Parkway, Bothell, Washington 98011 ("TalentWise").

TalentWise believes strongly in protecting your privacy and the confidentiality of your Personal Information. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purpose of allowing us to offer and provide our products and services to you. In order to address these concerns, we have developed this Privacy Policy.

Personal information is any combination of information, in the possession of or likely to come into the possession of TalentWise, that can be used to identify, contact, or locate a discrete individual ("Personal Information") and will be treated in accordance with this Privacy Policy. This includes any expression of opinion about such individual. Any information which cannot be used to identify a discrete individual (such as aggregated statistical information) is not Personal Information.

Purpose for Collection, Use and Disclosure of Personal Information

TalentWise collects, uses and discloses your Personal Information in its normal course of business for the following purposes:

  • Providing HR-related services to your employer, or potential employer, assisting you in the completion of application for employment, assessment of your eligibility for any such employment, the processing and maintenance of the service, as well as any applicable activities related to the services acquired by your employer;
  • Enabling your interaction with other employees of your employer via social media services (e.g. newsfeeds, chat, calendaring, etc.);
  • Establishing and maintaining communications with you;
  • Allowing our affiliated companies to notify you of certain products or services offered by our affiliated companies;
  • Processing transactions or services, such as employee benefits, through service providers;
  • Meeting legal, security, processing and regulatory requirements;
  • Protecting against fraud, suspicious or other illegal activities; and
  • Compiling statistics for your employer's management of its workforce, and analysis of Kennect's functionality and usability.

Information Collected

The information gathered by TalentWise via Kennect falls into two categories: (1) information voluntarily supplied by users of Kennect and (2) information automatically gathered as users navigate through Kennect.

Information voluntarily provided by you

When using Kennect, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how the employer chooses to deploy Kennect. As a service provider to an employer, TalentWise will only collect information which is necessary to provide the services the employer has requested.

  • HR-Related Management

    If you register with Kennect, or request a service available on Kennect, we may ask you for your name, email address, country, telephone number, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the service. On any data submission form, we shall indicate which information is optional and which information is mandatory. This information can include:

    • Information you provide on applications or other forms, which may include your name, address, email address, age, personal identification numbers, credit card numbers, credit records, banking information, payment records, medical and health information, employment and income information;
    • Information we acquire from and/or transfer to other persons (such as government agencies, your insurer and your employer) to verify your identity and the accuracy of the information you have provided;
    • Information about you received from TalentWise affiliates, other intermediaries, third party providers and others which are necessary for the provision of our services; and
    • Information we receive from consumer reporting agencies.

    Any Personal Information that you send us will be used for the purpose indicated on Kennect or in this Privacy Policy.

    While enrollment into the service is just one way you may disclose Personal Information via Kennect, your on-going use of Kennect will also result in the collection of your Personal Information. The Kennect platform has a number of HR-related services it can provide to help you manage your work, and your employer manage its workforce. These include expense management, timekeeping, employee screening history, employee records, employee directory hosting, calendaring, and other forms of document management. Either you or other workers of your employer will disclose this information via Kennect, which may include Personal Information about you.

  • Collaboration Services

    Kennect is more than just a HR portal, it is also designed to foster collaboration among its users. As a result, Kennect has a number of social media and sharing features which are designed to allow for closer collaboration between employees. When you use these services, please understand that you may be intentionally disclosing Personal Information to another worker of your employer. TalentWise cannot control the way that other individuals, who you disclose Personal Information to via Kennect, will use this Personal Information. Your employer should have policies around how this kind of collaboration is managed, and we encourage you to review those.

    Finally, if you submit content as a part of your use of Kennect, we will ask for identifying Personal Information, so that we can manage the content in line with our Terms of Use, and any policies your employers have around workforce management.

Kennect Navigational Information

As you navigate around Kennect, we may also collect information through the use of common information-gathering tools, such as cookies and web beacons (collectively "Kennect Navigational Information"). Kennect Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on Kennect (such as the pages viewed and the links clicked).

  • Cookies

    Like many companies, we may use cookies on Kennect. Cookies are pieces of information shared between your web browser and Kennect. Use of cookies enables a faster and easier experience for the user. A cookie cannot read data off your computer's hard drive.

    There are different kinds of cookies with different functions:

    • (i) Session cookies: these are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse Kennect without having to log in to each page. They do not collect any information from your computer.
    • (ii) Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by a website that created it when you visit that website again.
    • (iii) First-party cookies: the function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between TalentWise's servers and your computer's hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
    • (iv) Third-party cookies: the function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.

    Except as described in this Privacy Policy, we do not use third-party cookies on Kennect, although we do use third party provided web beacons (please see the section on Web Beacons below).

    Kennect does use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the website analyze how users use Kennect. The information generated by the cookie about your use of Kennect (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of Kennect, compiling reports on Kennect activity, and providing other services relating to Kennect activity and internet usage for TalentWise and its affiliates. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of Kennect. By using Kennect, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

    The major browsers have attempted to implement the draft "Do Not Track" ("DNT") standard of the World Wide Web Consortium ("W3C") in their latest releases. As this standard has not been finalized, TalentWise's Kennect is not compatible with DNT.

    We use cookies for the following purposes:

    • Where strictly necessary

      These cookies are essential in order to enable you to move around Kennect and use its features, such as accessing secure areas of Kennect. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

    • Performance

      These cookies collect information about how visitors use Kennect, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to Kennect, all of which enables us to see how visitors use Kennect in order to improve the way that Kennect works.  These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous and is used to improve how Kennect works.

    • Functionality

      These cookies allow Kennect to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, Kennect may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access Kennect. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as collaborating with your employer's HR function, or commenting on content provided by another user.

    Please consult your web browser's "Help" documentation or visit aboutcookies.org for more information about how to turn cookies on and off for your browser.

  • Web Beacons

    Kennect may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of Kennect and interaction with emails from TalentWise. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. We use web beacons to operate and improve Kennect and email communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about TalentWise and our services. We will conduct this review on an anonymous basis.

  • IP Addresses

    When you visit Kennect, TalentWise collects your Internet Protocol ("IP") addresses to track and aggregate non-Personal Information. For example, TalentWise uses IP addresses to monitor the regions from which users navigate to Kennect. IP addresses will be stored in such a way so that you cannot be identified from the IP address.

Disclosure of Information to Others

We do not disclose any Personal Information about you to any third parties except as stated in this Privacy Policy, as otherwise permitted by law, or authorized by you.

Third parties (besides your employer) to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:

  • To provide the products and services your employer has requested from us;
  • To allow your employer to effectively manage its workforce, including time management, payroll, benefits management, and other such services;
  • To process transactions through data processing service providers; and
  • To integrate Kennect services to other third-party service providers your employer uses for the management of its workforce.

Except for your employer, and any agents providing services to your employer, if any third parties providing services to TalentWise wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us at support@kennect.com or 1-888-341-5607 for more information on these third parties.

Affiliate Sharing

In the normal course of performing services for our clients, Personal Information may be shared within TalentWise and its affiliates for research and statistical purposes, system administration, and crime prevention or detection. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform those services via Kennect for you on the understanding that the individuals to whom the Personal Information relates are reasonably aware of the reason(s) for using their Personal Information, the fact that it may be disclosed to third parties such as TalentWise, and have consented to such disclosure and use.

Service Providers

Because a number of the service providers we use are located in the United States, including certain TalentWise affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.

TalentWise's service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.

Business Transactions

As TalentWise continues to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either TalentWise itself or substantially all of TalentWise assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances.

Other Legally Required Disclosures

TalentWise preserves the right to disclose without your prior permission any Personal Information about you or your use of Kennect if TalentWise has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of TalentWise, a TalentWise client, employees of either TalentWise or a TalentWise client, other users of Kennect, or the public; (b) enforce the terms and conditions that apply to use of Kennect; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.

In this Privacy Policy, the purposes identified above and in "Purpose for Collection, Use and Disclosure of Personal Information" will be referred to as the "Identified Purposes."

California's "Shine the Light" Law

California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. TalentWise does not share any personal information collected from Kennect with third parties for their direct marketing purposes.

Your knowledge of and, when appropriate, consent to TalentWise's collection, use and disclosure of your Personal Information is important. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:

  • Your voluntary provision of Personal Information to us directly;
  • Your express consent or acknowledgement contained within a written, verbal, or electronic application or form; and
  • Your verbal consent solicited by TalentWise (or our agent) for a specified purpose.

Where TalentWise relies on express consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.

Subject to certain legal or contractual restrictions, and reasonable notice, you may withdraw this consent at any time. In general, refusing to provide certain Personal Information or withdrawing consent for TalentWise to collect, use or disclose your Personal Information will mean that we cannot provide Kennect services or information for you.

However, there are a number of instances where TalentWise does not require your consent to engage in the processing or disclosure of Personal Information. TalentWise may not solicit your consent for the processing or transfer of Personal information for the those purposes which have a statutory basis, such as:

  • The transfer or processing is necessary for the performance of a contract between you and your employer (or one of its affiliates);
  • The transfer or processing is necessary for the performance of a contract, concluded in your interest, between your employer (or one of its affiliates) and a third party;
  • The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
  • The transfer or processing is required by applicable law.

Limiting Collection and Retention of Personal Information

TalentWise will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent (where appropriate), that new purpose will become an Identified Purpose.

TalentWise will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.

Safeguards

We have in place physical, electronic and procedural safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and TalentWise expressly disclaims any such obligation.

Kennect may include links to other websites whose privacy policies we do not control (for example your employer’s website). Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy policy of the operator of the websites you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these websites via a link from Kennect's home page, you should contact the websites directly for more information.

Accuracy, Accountability, Openness and Customer Access

Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us via Kennect directly, or by emailing your employer's HR representative. Please keep your Personal Information up-to-date.

You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect. In general, you will have online access to view or amend your Personal Information in Kennect.

Where consent is used as a basis for processing, you may exercise your right to withdraw your consent to those uses or disclosures of your Personal Information (which may limit or terminate the products and services Kennect can provide to you) by discontinuing the use of Kennect.

Your Choices

Website Visitors and Referrals. If you are a Website Visitor or Referral and wish to opt out of receiving marketing notifications, you can unsubscribe by clicking on the link included in the email we send you, emailing support@kennect.com or calling 1-888-341-5607.

Testimonial Providers. If you are a Testimonial Provider and wish to update or delete your testimonial, please contact us at support@kennect.com or 1-888-341-5607.

Customer Advocacy Program. If you joined the Customer Advocacy Program and wish to cease participation and remove your personal profile and any associated information you have provided, contact us at support@kennect.com or 1-888-341-5607.

Service Requesters. If you are a Service Requester and would like to update your personal information in your account such as your name, email or address, you can do so by logging into your account. If you wish to cancel your account or request that we no longer use your personal information for marketing purposes, contact us at support@kennect.com or 1-888-341-5607.

Employees and Candidates. If you are an Employee or Candidate and would like to update your personal information, please contact us at support@kennect.com or 1-888-341-5607.

We will respond to all requests to access information within 30 days.

Privacy Policy Contact Information

Please feel free to direct any questions or concerns regarding this Statement to us by sending an email to Privacy and Compliance, attention Ele Macapia, at privacy@kennect.com, calling 425.974.8770, or by writing us at Privacy c/o Kennect by TalentWise, 19910 N. Creek Parkway, Suite 200, Bothell, WA 98011, U.S.A.. We will respond to your request promptly.

A copy of this Privacy Policy (and any significant changes) can be obtained from Kennect at http://www.kennect.com/privacy. TalentWise is responsible for all Personal Information under its control and has designated a privacy officer who is accountable to Management for TalentWise's compliance with this Privacy Policy.

Changes to this Privacy Policy

If there is any material change to your rights under this Privacy Policy, TalentWise will provide you with notice of such change 30 days prior to the changes going into effect. As part of this notice, TalentWise may post a notice of the change on Kennect in a clear and conspicuous manner for the 30 day notice period. TalentWise may also communicate the change via email or postal mail if this is the way that TalentWise normally corresponds with you. Please note that your continued use of Kennect or Services once this 30 day period are over indicates your agreement to the changes which were the subject of the notice.