Privacy Policy

This Privacy Policy (“Policy”) sets out how Talent Rewire LLC (collectively, “Talent Rewire,” “we,” “our,” or “us”) collects and uses personal information, and your choices and rights regarding our use of your personal information. Talent Rewire respects your privacy and is committed to protecting it through our compliance with this policy.

Scope of Privacy Policy

This Policy applies when you:

create, activate and use a Talent Rewire user account and/or license;

express an interest in or have signed up for our products including newsletters, apps, extensions, webinars, and e-books;

register for, and attend a virtual webinar or in-person Talent Rewire meeting; or

visit our websites, including our public and/or client websites, or social media sites (collectively, the “Websites”).

It does not apply to websites and mobile applications owned or operated by third parties and are not branded with Talent Rewire logos. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

For purposes of this Policy, Talent Rewire is the controller (or business, as applicable) of personal information collected via our Websites and services. If you are a California resident, we provide additional information about how to exercise your data access rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”) in the “Your California Privacy Rights” section below.

For purposes of this Policy, unless otherwise required by applicable law, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. “Personal information” does not include information that is considered publicly available, aggregated, or deidentified under applicable law.

1. INFORMATION WE COLLECT

1.1 Sources from which we collect personal information

We may collect and process your personal information directly from you or from the following sources:

Communications via our Websites: When you provide it to us through communications via our Websites, including through our contact information, when you register an account with us, and similar situations in which you have chosen to provide the information to us, including for customer services support. Any of our communications with you, including any phone calls, may be monitored and recorded for quality purposes.

Products or services you request: Where you request a good or service from us, we will collect your personal information to process your request and otherwise contact you following a purchase.

Referrals or recommendations: Referrals or recommendations, including from within the Talent Rewire group, from a third party, or from our send-to-colleague functionality, as described further below in Section 1.4;

Social media: Social media sites and other external internet sites, such as Facebook, Twitter, or LinkedIn.

Public resources: Resources such as telephone directories, newspapers, commercially available data resources, public registries, or public records.

Interaction with our Websites and use of our services: We do not use cookies in the provision of our website. So we do not currently collect cookie information which can include IP address, device identifiers, browser details, and information about usage of the Websites and related Internet activity (such as the site you came from, search engine(s) and keywords you used to find our Websites, the pages you view within our Websites, and access times).

1.2 Categories of personal information collected

The categories of personal information we may collect and process (but only to the extent and in a manner consistent with applicable law) are as follows:

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Personal identifiers and personal details

Name, email address, social media handles, address, billing address, zip or postal code, telephone number, unique personal identifier, online identifier, Internet Protocol (IP) address, account name, username, password, and identifiers you post to our Websites.

Demographic information

Age, date of birth, gender, and other similar data you provide as part of your profile or when using features of our services or Websites.

Inferences

Analysis of purchases, preferences, or interactions to create a profile suggesting other products or services of interest.

Information About Others

Information you provide about others, used to fulfil your requests; no marketing communications are sent to your contacts unless they separately opt-in.

1.3 How we use your personal information

We process your personal information only as necessary to enable us to provide our products and services, to perform our contracts entered into between you and us, to support our business functions, to ensure compliance with applicable laws, and for the purposes of our legitimate business interests, which may include the following:

To create, activate and use a Talent Rewire user account and/or license;

To facilitate the business through communication with corporate clients and other business contacts, for example, to communicate about webinars;

For internal analysis and research to help us improve our existing products and services, and create new products and services;

To send marketing to business contacts regarding our services and products which may be of interest and to promote our business and brand;

To administer our Websites, investigate any complaints, and provide more customized customer service;

To monitor social media content to manage relations with our clients and promote our business and brand;

To personalize your experience of our Websites;

To perform statistical and trend analysis to improve the user experience and performance of our Websites;

To detect and prevent fraudulent and/or unlawful use of our Websites, products and services.

Where we collect and use information for our legitimate interests as mentioned above, we will not unfairly place our legitimate interests above what is best for you. Legitimate interests are our business or commercial reasons for using your personal information, such as (i) keeping our records up to date; (ii) providing the services to you; (iii) maintaining or administering the services; (iv) performing business analyses or for other internal purposes to improve the quality of our business and the services we offer; (v) prevention of fraud and financial crime to protect the public; (vi) communicating with you concerning programs or services consistent with our obligations to provide those services or otherwise; and (vii) participating in litigation, investigations, regulatory or governmental inquiries or for other legal or regulatory purposes involving our customers who use or have used our services or other third parties. For more information regarding our legitimate interests as applied to your personal information, please contact using one of the methods listed in Section 13 below.

Where you consent to our collection and use of your personal information (when required under applicable law), and we rely on your consent, you have the right to withdraw consent by contacting us using one of the methods listed in Section 13 below.

In certain circumstances, if you do not provide personal information which is required (for example, in relation to activating your Talent Rewire license), we will not be able to perform our contractual obligations or provide you with products and services. When this is the case, we will make it clear.

1.4 Additional information

Recorded Communications with Talent Rewire

We may ask to record calls for training, quality and research purposes. All recordings will be treated as confidential. If you do not want us to record your call, you will be given a chance to opt out. If your call is already in progress, you may ask us to turn off the recording at the start of the call.

2. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

Email: [email protected]

Mailing Address: Talent Rewire, ATTN: Privacy Team, 1515 Mockingbird Ln, Ste. 200, Charlotte, NC 28209.

We may disclose your personal information to third parties as follows:

Talent Rewire Group Companies

To process data for the purposes outlined in the Privacy Policy.

Consent-Based Recipients

When we have the individual's consent or authorization to share their personal information.

Service Providers (IT Systems)

To maintain or service business contact databases and IT systems (e.g., IT suppliers and technology vendors).

Professional Advisors

To provide necessary services, such as auditing and legal advice.

Public Authorities

To comply with applicable laws, protect rights, safety, and property, and respond to lawful requests (e.g., national security or law enforcement).

Mergers, Sales, or Corporate Changes

To facilitate transactions such as mergers, acquisitions, or asset transfers, including pre-transaction reviews.

Anonymized/Aggregated Data Recipients

Personal data may be shared in anonymized or aggregated form, as it is no longer considered personal information.

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Talent Rewire may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Utilization Information

We may share information with our organizational clients about how their employees use the Websites and the resources available to them through the Websites (e.g., how employees used certain features of the Websites, utilization trends, which features were most popular with the client’s employees).

3. CHOICES ABOUT YOUR INFORMATION

Talent Rewire respects your rights to limit the use and disclosure of your personal data. In accordance with the US Data laws and the GDPR , we offer the following options:

3.1 Opt-Out Choices

You have the right to choose (opt out) whether your personal information is:

Disclosed to third parties for purposes other than those described in this policy or for materially different purposes from those for which it was originally collected or subsequently authorized by you.

Used for purposes materially different from those for which it was originally collected or subsequently authorized by you.

To exercise your opt-out rights, you may contact us via:

Email: [email protected]

Writing to us at the address below

3.2 Opt-In Requirements for Sensitive Information

For sensitive personal information, Talent Rewire requires your affirmative express consent (opt-in) before:

Disclosing such information to third parties.

Using such information for purposes other than those originally collected or authorized by you.

If you have any questions or need assistance with managing your sensitive information, please contact us at [email protected].

3.3 Third-Party Agents

Disclosure of personal data to third parties acting as agents on Talent Rewire’s behalf does not require an opt-out mechanism. These agents are bound by contractual agreements to process personal information only under our instructions and in compliance with applicable privacy laws and the DPF Principles.

3.4 Clear and Conspicuous Mechanisms

Talent Rewire provides clear, conspicuous, and readily available mechanisms to exercise your choices regarding the use and disclosure of your personal data. You may update your preferences at any time by contacting us via:

Email: [email protected]

Mailing Address: Talent Rewire, ATTN: 1515 Mockingbird Ln, Ste. 200, Charlotte, NC 28209

Marketing Communications

We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us using one of the methods listed in Section 13 below. If you gave us your email address to receive marketing communications, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information with third parties for their own promotional or marketing purposes unless you give us consent to do so or where permitted by applicable law.

4. SECURITY

We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.

5. RETENTION PERIODS

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained, and/or whether additional legal/regulatory obligations require us to retain it.

In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:

the period required by tax and company laws and regulations; and

as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.

6. COOKIES AND SIMILAR TECHNOLOGIES

Talent Rewire Websites is hosted on Go High Level, which does not use or allow cookies.

We may change our use of cookies over time, and will update the Privacy Policy accordingly.

7. CHILDREN

Our Websites are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18. Talent Rewire does not knowingly collect personal information from individuals under the age of 18. If we discover that we have inadvertently collected personal information from anyone younger than the age of 18, we will delete that information. We do not sell personal information for valuable consideration or share the personal information for behavioral or targeted advertising of any individual we know to be under the age of 18. Talent Rewire takes reasonable steps to verify the age of users during the account creation process and implements parental consent mechanisms where applicable to ensure compliance with relevant laws and regulations.

8. YOUR DATA SUBJECT RIGHTS

In certain circumstances and jurisdictions, you have certain rights regarding your personal information. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. A summary of each right and how you can exercise it is set out below. To opt out of receiving commercial communications, please send an email to [email protected]. You may be able to use the Website to access and update the information that you have provided to us through your use of the Website or otherwise.

When you make a request, we may require that you provide information and follow procedures so that we can verify a request you make and your jurisdiction before responding to it. The verification steps we take may differ depending on your jurisdiction and the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.

Where we receive your request to exercise one of these rights, we will respond without undue delay and within the time required by applicable law. This may be extended in certain circumstances, e.g., where requests are complex or numerous.

We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request.

8.1 EU Privacy Rights

If you are a European Union resident, in accordance with Talent Rewire’s policies and procedures, you have the right to review, verify, correct, and request erasure of the personal information that we hold about you under certain circumstances. You also have the right to limit, restrict, or object to the processing of your personal information under certain circumstances. You may also have the right to request that we transfer your personal information to another party to the extent provided for under applicable data privacy laws. For more information on your rights, please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

If you want to review, verify, correct, or request erasure of your Personal Information; limit, restrict, or object to the processing of your Personal Information; or request a transfer of your Personal Information to another party, please contact us at [email protected] or write to us at

Talent Rewire

ATTN: Privacy Team

1515 Mockingbird Ln, Ste. 200

Charlotte, NC 28209

To protect your privacy and security, we also will take reasonable steps to verify your identity before granting access, making corrections, or following such a request to correct or delete your data.

When you contact us, we will respond as soon as possible and where possible within one month. If your request is more complicated, it may take longer to respond to you, but we will respond within three months of your request.

8.2 Your California Privacy Rights

California law requires us to provide California residents with additional information regarding how we collect, use, and share your personal information (“California Privacy Notice”). Persons with disabilities may obtain this notice in alternative format upon request by contacting us at [email protected].

California Shine the Light. Although we do not currently share your information for other companies’ direct marketing purposes, residents of California have the right to request information from us regarding other companies to whom we have disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email [email protected] or write to us at:

Talent Rewire

ATTN: Privacy Team

1515 Mockingbird Ln, Ste. 200

Charlotte, NC 28209

Categories of personal information sold to or shared with third parties. We do not sell and have not sold your personal information or transferred personal information to third parties to use for their benefit in the past twelve (12) months. We do share and have shared certain personal information for targeted or cross-context behavioral advertising in the past twelve (12) months. However, we do not sell or share the personal information of minors under 16 years of age.

For purposes of this Policy, “sell” means the sale or transfer of your personal information to a third party for monetary or other valuable consideration, subject to certain exceptions in applicable law. For purposes of this Policy, “share” means transferring, making available or otherwise disclosing your personal information to another party for purposes of sending advertising to you based on your personal information obtained from your activities across distinctly-branded sites. “Share” and “sharing” as used in this section, does not include transfers of personal information described in this Policy as part of a corporate business transaction, such as a merger, acquisition, or joint venture, or in the event of insolvency, bankruptcy, or receivership. Should such an event occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy.

In the past twelve (12) months, we have shared the following categories of personal information with data analytics providers, operating systems and platforms, social networks, and cookie providers for the purposes described in Section 1.3 above:

Personal identifiers and personal details

Internet or Other Electronic Network Activity Information

Geolocation Data

Inferences

Please see Section 6 on “Cookies and Similar Technologies” above for information about the collection and use of personal information by third parties who process information collected by cookies and similar technologies that we permit them to use on the Websites.

Categories of personal information disclosed to service providers. We disclose personal information to certain third parties to enable them to fulfil the purposes described in Section 1.3 above. The personal information provided to our service providers is limited to that personal information which is necessary for them to fulfil these purposes. Our service providers have contractually agreed not to use your personal information other than as necessary to fulfil the applicable purposes and in accordance with California law. Additionally, service providers must implement robust technical and organizational measures, comply with all applicable data protection regulations and fulfil their responsibilities to ensure data security, privacy, and effective incident management. In the preceding twelve (12) months, we have disclosed the categories of personal information described in Section 1.2 above, with the following categories of service providers:

Data Analytics Providers

Operating Systems and Platforms

Customer Support Providers

Social Networks

Workforce Management and Human Resource Management Providers

Government Entities

We disclose personal information to our service providers in accordance with the purposes described in Section 1.3 above.

Individual Rights. California law may provide you with the following privacy rights:

Right to Know and to Access. Subject to certain exceptions, and legal obligations, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, including whether we sell or share such information. You also have the right to request access to personal information collected about you and information regarding the following:

The categories of personal information we collected about you;

The categories of sources of that information;

The business or commercial purposes for which we collect, sell or share personal information about you;

The categories of personal information about you that we have disclosed about you and the categories of persons or vendors to whom it was disclosed for a business purpose; and

The specific pieces of personal information we have collected about you.

This information is disclosed in Section 1 above. You may also submit a request for this information as described below. To protect your personal information, we may request additional information to verify your identity before we act on your request. To the extent legally required, we will provide a copy of the personal information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We may provide this data to you via email to the email address you have provided with your request.

Right to Correction. You have the right to request that we correct any inaccurate personal information we maintain about you. In response to your request, we may request additional information showing that the information you want to correct is inaccurate.

Right to Deletion. You may request that we delete your personal information. This right is subject to certain exceptions, and legal obligations imposed by state or federal privacy and employment laws. We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt-Out of the Sale or Sharing of Personal Information to Third Parties. You have the right to opt out of the sale or sharing of your personal information by Talent Rewire to third parties.

Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to fulfill the purposes reasonably expected by an average consumer who requests those goods or services. California law considers the following pieces of personal information to be “sensitive:” social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data. We do not knowingly collect or use sensitive personal information for any purposes, including to infer characteristics about you.

Non-Discrimination or Retaliation. We will not discriminate or retaliate against you for exercising any of your data privacy rights.

How to submit a request. You or an authorized agent may submit a request to exercise your rights through one of the following means:

By filling out a Consumer Data Request Form.

By emailing us at [email protected].

California Online Privacy Protection Act Notice Concerning Do Not Track Signals. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please visit: www.allaboutdnt.org.

8.3 Nevada Residents

Nevada law requires us to provide certain Nevada consumers the ability to opt out of the “sale” of “personally identifiable information” as such terms are defined under Nevada law. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing [email protected]. Once verified, we will maintain your request in the event our practices change.

9. INTERNATIONAL TRANSFERS

Talent Rewire is a global company and we may transfer personal information to other Talent Rewire group companies or suppliers outside your country. Talent Rewire will take reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.

Talent Rewire may transfer and maintain the personal information of individuals covered by this Policy on servers or databases outside the European Economic Area (“EEA”). Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA. For transatlantic data transfers, Talent Rewire relies on safeguards such as Standard Contractual Clauses (SCCs) or other mechanisms recognized under applicable data protection laws to ensure the lawful and secure transfer of personal information.

The countries to which we transfer data outside of the EEA may include any of the countries in which Talent Rewire does business.

All Talent Rewire entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of information.

10. LINKS TO EXTERNAL WEBSITES

Talent Rewire’s services and technologies, including its Websites, may contain links to other websites or resources that are not part of the products, programs, or services run by Talent Rewire. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the privacy policies of those sites and are not covered by this Policy. We encourage you to read the privacy policies of those other websites.

11. CONTACT US

If you’d like more information about our privacy practices, feel free to contact us by emailing us at [email protected], or by writing to us:

Talent Rewire

ATTN: Privacy Team

1515 Mockingbird Ln, Ste. 200

Charlotte, NC 28209

12. CHANGES TO THIS POLICY

From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on this Website. We recommend you regularly review this Website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page. If you use our Website after any changes are effective, you are agreeing to comply with and be bound by them. To enhance transparency, we will notify users of any crucial or material changes to this Policy through a banner displayed on the Website.

Address:

1515 Mockingbird Ln, Ste. 200, Charlotte, NC 28209

Contact:

[email protected]