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    Beeline Privacy Notice (Talent Offerings)

    Last updated May 1, 2024

    INTRODUCTION

    Beeline.com LLC and its subsidiaries and affiliates (“Beeline”) is committed to maintaining robust privacy protections for its users. This Privacy Notice, ("Notice") is designed to help you understand how we collect, use, share and safeguard the information you provide to us through Beeline’s Talent Offerings. Information on how we collect, use, share and safeguard the information you provide to us through and via our website at Beeline.com, (“Website”), is available here.

    For purposes of this Notice the terms “we,” “us,” and “our” refer to Beeline, and “you” refers to you as a user of the services that we offer to you directly as an individual, (“Talent Offerings”) through our hosted application that we make available to you (“Talent Application”).

    By accessing the Talent Offerings, you accept the terms of this Notice and consent to our collection, storage, use and disclosure of your Personal Data as described in this Notice.

    This Privacy Notice applies to the terms and conditions that you accept in conjunction with any Talent Offering (“Talent Terms”). In the event of a conflict between the terms of this Notice and the Talent Terms, the terms of this Notice will prevail with respect to the matters addressed herein.

    This Notice will be available to you within the Talent Application as well as via certain communications from us (such as upon login or via e-mails we may send to you in reference to the Talent Offerings). This Notice may change from time to time, in which case we will update the Notice within the Talent Application.

    PRIVACY PRINCIPLES

    We are committed to individual privacy and recognize our responsibility for protecting the Personal Data in our possession and care. This Notice embodies the principles found here.

    PRIVACY PRACTICES

    Information we collect.

    We collect “Non-Personal Data” and “Personal Data” from your activity in the Talent Offerings. Non-Personal Data includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information, preferences that you submit, and preferences that are generated based on information you submit and clicks that you make. Personal Data includes any information that is identifiable to you or by which you can be identified, such as your name, email address, mailing address, phone numbers, or other personal characteristics or attributes. Any information that you elect to upload to your personal profile in the Talent Offerings (“Profile”) and any information that you consent to share with suppliers and customers will be considered Personal Data for purposes of this Notice.

    We process your Personal Data for the purpose of providing you with our Talent Offerings, including tasks as directed or authorized by you in accordance with the Talent Terms and in order to improve and develop these service offerings. This activity will include:

    • Creating and managing user accounts
    • Sharing your Personal Data for the purposes set forth under this Notice and the Terms of Use, including to provide you with transparency on the processing of your Personal Data as a part of your engagement process with customers and suppliers
    • Analyzing, personalizing, improving accuracy, and enhancing your experience with the Talent Offerings and your interactions with us
    • Support services we provide to you
    • Sending communications to you for feedback and other information
    • Protecting Beeline, our Talent Offering users, suppliers and customers

    Information that you share with third parties outside of the Talent Offerings such as suppliers and customers with which you have a relationship (e.g., as contract labor or as a candidate for an engagement, etc.) is not a part of the Personal Data referenced under or covered by this Notice. For information on how those third parties collect, use, and process your personal information, once you have consented to our sharing of your information with them, you will need to contact them directly. A list of those third parties is made available to you in your account.

    We also process transaction and information system usage information from the Talent Offerings. This may include information obtained from cookies, which we use for a variety of reasons, including remembering registration information, survey participation, and to auto-populate correspondence details. We may directly collect Personal Data from you for contact or marketing purposes when you consent to such use in connection with registering for a Beeline event or webinar, create your Profile in any of the Talent Offerings, or otherwise submit Personal Data to us. Such Personal Data may be stored for such period of time until no longer required by us to fulfill its intended purpose or until you choose to have your Personal Data erased. For more information, see “Retention and Disposal of Personal Data” below.

    How We Use and Share Your Personal Data

    Except as otherwise stated in this Notice, we do not sell, trade, rent, or otherwise share your Personal Data with third parties for marketing purposes without your consent. We do share your Personal Data with third parties who are performing services for us in support of the Talent Offerings. Those third parties use your Personal Data only at our direction and in accordance with this Privacy Notice. We only use your Personal Data for the purposes for which it was collected as described herein and any other notice we may provide to you. We do not share your Personal Data for the purpose of targeted advertising by third parties.

    Other Reasons We Share Personal Data

    Use of Personal Data by Our Affiliates: Our affiliates will process your Personal Data in order to provide you with support and other services under the Talent Terms.

    Use of Personal Data by Customers and Suppliers: The Talent Offerings are made available to you in order that Beeline may share your information, including your Personal Data with customers and suppliers to allow them to consider you for possible engagement with those customers. By accepting the Talent Terms, you have agreed to our sharing of your Personal Data with those customers and suppliers for this purpose. Once your Personal Data is shared with customers and suppliers, those parties will process your Personal Data as independent controllers of that Personal Data, subject to the terms of their respective privacy notices. By consenting to such sharing you acknowledge and agree that you accept the terms of and take responsibility for compliance with those privacy notices.

    Engagement with Technology Vendors: Beeline shares user engagement information derived from the Talent Offerings with third parties who will generate feedback that will allow us to improve the Talent Offerings. Unless we expressly ask for and you grant consent, the data we will provide to our technology vendors will not include your Personal Data.

    Corporate Mergers and Acquisition Activity: In the event that we or our affiliates acquire or are acquired by another business operation, or in the event of a merger, reorganization, or other similar event, your Personal Data will be shared with the acquiring, acquired, or resulting entities and their affiliates including for the purposes of the continued provision of services to you as well as for the provision of additional products or services offered by the acquiring, acquired or resulting entities.

    Legal Requirements: In certain situations, we may be required to disclose Personal Data in response to lawful requests by governmental agencies and supervisory authorities, including as necessary to meet security or law enforcement requirements. We reserve the right to disclose your Personal Data as required by applicable law and when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or similar legal or regulatory process served upon us. We will advise you of any such disclosures of your Personal Data where we are required to do so.

    Communication with you: We or our partners may use your Personal Data to communicate with you to provide you with support for the Talent Offerings, to manage your account, or to seek your feedback regarding the Talent Offerings.

    Updates to this Privacy Notice

    Updates to this Privacy Notice shall be made available as they occur within the Talent Offerings or by other means and will apply to your use of the Talent Offerings after the noted effective date. If you object to any of the changes, you may remove any Personal Data from or close your account under the Talent Offerings (see “Inquiries” below.)

    INFORMATION SECURITY

    Personal Data in our possession is protected by our Information Systems Security Policy, which is designed to prevent unauthorized disclosure, misuse, or alteration of Personal Data. The Information Systems Security Policy includes confidentiality procedures applicable to all of our personnel, security requirements for physical and electronic security, and compliance policies and procedures for information handling. All Beeline personnel are required to acknowledge an understanding of the Information Systems Security Policy, and adherence is enforced.

    General security measures are available to you upon request (see “Inquiries” below.)

    Your Talent Offerings account is protected by your account password, and we encourage you to take steps to keep your Personal Data safe by not disclosing your password and by logging out of your Talent Offerings account following each visit.

    GDPR

    If you are subject to the General Data Protection Regulation, the following apply to your Personal Data.

    • We are acting as a data controller when you access our Talent Offerings, communicate with us, register for events and consent to receive marketing communications from us, and where we are acting under applicable legal or regulatory requirements.
    • When you establish a Talent Offerings account with us, we are the data processor of your Personal Data that you provide in conjunction with the Talent Offerings and enter into your Profile, and you have certain rights with respect to such Personal Data that include: (i) you may request from us access to, rectification, erasure, or restriction of, processing concerning your Personal Data; and (ii) you have the right to object to the processing, the right to data portability, and the right to lodge a complaint with a supervisory authority.
      • We process your Personal Data inside and outside of the United States and rely upon legally approved mechanisms to lawfully transfer information across borders. Countries where we process data may have laws that are different from, and potentially not as protective as, the laws of your own country.
      • We will only collect and process your Personal Data where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., our Talent Terms)), and our legitimate business interests.
      • Where we rely on your consent to process your Personal Data, you have the right to withdraw or decline your consent at any time, and where we rely on legitimate interests, you have the right to object. If you have any questions regarding the lawful bases upon which we collect and use your Personal Data, please contact us (see “Inquiries” below.)
      • We retain some of your Personal Data even after you have closed your Talent Offerings account with us as reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Talent Terms, or fulfill your request to delete your Personal Data.
      • Under the Talent Terms you have consented to the sharing of your Personal Data with suppliers and customers for the purposes set forth therein and as additionally set out under this Notice. Once we release your Personal Data to these third parties as approved by your use of the Talent Offerings, including where you provide additional Personal Data or other information in response to requests you receive from suppliers and customers through the Talent Offerings, these third parties become independent controllers of your Personal Data. It is your responsibility to review the privacy notices of these third parties and address any objections you may have to their processing activity with them directly. A list of these third parties is made available to you in your account.

    EU-U.S. Data Protection Framework

    Transfers of Personal Data from the EU will be made under the adequacy decision adopted on July 10, 2023, by the European Commission. Transfers from the UK (and Gibraltar) will be made under the approved data transfer mechanism issued by the UK to permit the transfer of Personal Data from the UK (and Gibraltar) to the United States under the UK GDPR. Transfers from Switzerland will be made under the Swiss-U.S. DPF.

    The EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) is the data privacy framework launched by the U.S. Department of Commerce on July 10, 2023, which serves as an approved method of data transfers from the EU to the United States in support of the adequacy decision for the United States.

    Where Beeline acts as a data processor, Beeline shall comply with its obligations under Article 28 of the GDPR for all such transfers. For data transfers to countries without an adequacy decision, and in the event that the EU-U.S. DPF ceases to be an approved method of data transfer or where Beeline does not or ceases to adhere to the EU-U.S. DPF, Beeline will promptly select and implement another approved method of data transfer. In the event that Beeline is unable to promptly implement an alternative approved method of data transfer, Beeline shall cease the affected transfers of your Personal Data made by Beeline under the Talent Offerings. Any of your Personal Data previously shared with Beeline customers and suppliers would be subject to the respective privacy notices of those customers and suppliers and would not apply to this section.

    All transfers of Beeline Data to a third country or an international organization will be subject to appropriate safeguards as described in Article 46 of the GDPR, and such transfers and safeguards will be documented according to Article 30(2) of the GDPR.

    To learn more about the EU-U.S. DPF , and to view our certification (Beeline.com, LLC is a covered entity of IQNavigator, Inc.), please visit the U.S. Department of Commerce’s Data Protection Framework website.

    You may have the option to select binding arbitration under the EU-U.S. DPF for the resolution of any complaint under certain circumstances. For further information please see “Alternative Dispute Resolution” below.

    ADDITIONAL STATE-SPECIFIC DISCLOSURES

    Our required state-specific disclosures can be found here.

    Automated Decision Making

    As a part of our Talent Offerings, we offer you the ability to make your Personal Data available to suppliers and customers with your consent for the purpose of having that information submitted as a candidate for engagement with customers. While we may use artificial intelligence (“AI”), including machine learning, as a part of our business operations, we will not use your Personal Data to make business decisions (including for assessing your qualifications for an engagement), nor will we use your Personal Data to train AI.

    THIRD-PARTY INFORMATION THAT YOU PROVIDE

    If you choose to provide us with a third party's Personal Data (such as name, email, or phone number), you represent that you have that third party's permission to do so. If at any time such consent is withdrawn, it is your responsibility to remove that third-party Personal Data from the Talent Offerings. Examples include but would not be limited to references or emergency contacts that you include within your Profile.

    SENSITIVE PERSONAL DATA

    We may ask, and you may consent to provide certain diversity, equity, and inclusion (“DEI”) information within your Profile, such as ethnicity, nationality, military affiliation, sexual orientation, and transgender or disability status. We do not require you to provide this type of sensitive personal data in order for you to activate or maintain an account for the Talent Offerings. Any such Personal Data that you provide is completely voluntary and will never be viewed by or shared with any third party. We collect this information so that we can provide anonymized and aggregated metrics to suppliers and customers. You may amend or delete any DEI information that you elect to provide at any time via the Talent Application.

    RETENTION AND DISPOSAL OF PERSONAL DATA

    We will retain your Personal Data within the Talent Offerings for so long as you maintain your account. Using the features and functionality of the Talent Offerings, you are responsible to delete or update your Personal Data and that of any third party that you have provided as you determine in your sole discretion. By entering your Personal Data into the Talent Offerings, you are consenting to the sharing of your Personal Data (excluding DEI information) with suppliers with which you are engaged and with customers for the purpose of furthering an engagement with customers. If at any time you no longer wish to share your Personal Data with any one supplier, you may delete your connection to that supplier using the features and functionality of the Talent Application. If you wish to no longer share your Personal Data with any supplier or customers, this can be accomplished by closing out your account at any time by using the features and functionality of the Talent Application. If you wish to no longer share any DEI information with us, you may delete any or all of this information from your Profile at any time using the features and functionality of the Talent Application.

    During reasonable periods of account inactivity, we may contact you to confirm your continued interest in maintaining your account under the Talent Offerings. Without such confirmation, we will delete your account and all of your Personal Data in accordance with our data retention practices.    

    CHILDREN’S PRIVACY

    We are committed to protecting the privacy of children. The Talent Offerings and any accompanying services offered are not directed at children who are under 16 years of age. We require that individuals requesting information on or contracting for our products or services be 18 years of age or older. Should we receive personal information from a person whom we know is under 16 years of age, we will endeavor to delete such information from our systems, and the information will not be used for any purpose. If you believe that a person under 16 years of age has provided us with their Personal Data, please notify us so that we can take reasonable steps to remove the information from our systems.

    ALTERNATIVE DISPUTE RESOLUTION (ADR)

    In compliance with the EU-U.S. DPF principles, we commit to resolving complaints about our collection or use of your Personal Data. Inquiries regarding our EU-U.S. DPF compliance or complaints regarding the handling of your Personal Data should be directed to privacy@beeline.com.

    We have further committed to refer unresolved EU-U.S. DPF complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please email privacy@beeline.com for more information. The services of JAMS are provided at no cost to you. To learn more about JAMS, click here. To learn more about binding arbitration under the EU-U.S. DPF regulation, click here.

    COOKIE NOTICE

    What Are Cookies?

    A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size, and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

    How We Use Cookies

    Our Talent Offerings use “session cookies” that contain information that is stored in a temporary memory location on your device, which is then subsequently deleted after the session is completed or the web browser is closed. This cookie stores information that you have input and tracks your movements within the Talent Application. These cookies do not store and/or collect any Personal Data or any of your device data.

    INQUIRIES

    To inquire about any aspect of this Notice, your Personal Data or Personal Information held, or uses of the Personal Data or Personal Information, please contact us at talentprivacy@beeline.com.

    For support with your account, Profile, or any features or functionality of the Talent Offerings, including but not limited to taking steps to amend or remove any Personal Data from your Profile, please contact us at talentofferings@beeline.com.