Kira Talent Privacy Policy

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Introduction

At Kira Talent Inc. (“Kira Talent”, “We”, “Our”, or “Us” and terms of similar meaning), We are committed to your (“Your” and “You”) privacy.   “Your” or “You”, in this Privacy Policy,  means a User (defined below under “Scope”) that is age 18 or older or a parent of legal guardian of a User under the age of 18.

We recognize that adults and children who use our Services (as defined in our Terms of Service available at www.kiratalent.com/terms/) are concerned about how Personal Information they provide is collected, used and/or disclosed by Us. PARENTS AND LEGAL GUARDIANS:  Please see the section below entitled “Children Under 13 Years of Age” for more information regarding collection, use and disclosure of Personal Information of such children.  “Personal Information” is any information recorded in any form that identifies or can identify an individual and includes any information provided to Us by you or your Users in using Our Services.

We do not transfer, distribute, disclose, rent or sell any of Your personal information to third parties except as provided for in this policy (the “Privacy Policy”) or as specifically consented by You.

Kira Talent has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.

By using (the word “use” in Privacy Policy will mean “access or use”) Our Website located at www.kiratalent.com (the “Website”), our platform (the “Platform”), or other services that we may offer (collectively, the “Other Services” and together with the Website and the Platform, the “Services”)  , You expressly consent to Our collection, use and disclosure of Your Personal Information in accordance with this Privacy Policy.  This Privacy Policy is incorporated into and subject to Our Terms of Service available at www.kiratalent.com/terms/ (Our “Terms of Service”).

Scope

This Privacy Policy applies to all Personal Information collected, used or disclosed by Kira Talent from Our end-users who are (i) applicants who apply via the Platform to an organization (i.e. a business, educational institution, or volunteer organization) (“Candidates”) that is recruiting or assessing applicants (each, an “Organization”) via the Platform, (ii)  as well as any any other end-user who utilizes Our Website and Other Services, directly or indirectly, as well as  individual representatives of Organizations who use the Platform (such Candidates and other end-users, collectively, “Users”).  It also applies to the management of Personal Information in any form whether oral, electronic or written.

Accountability

Kira Talent is responsible for the Personal Information under its possession and control.  We have designated a Privacy Officer to be responsible for Our compliance with this Privacy Policy and privacy legislation.

Information We Collect

a. Personal Information

Personal Information that We collect includes, but is not limited to:

  • Account and profile information for Organizations’ representatives during their use of the Platform, which may include e-mail, first name, last name, usernames and passwords;
  • Details of interviews conducted and recorded through the Platform between Candidates and Organizations (“Interviews”), including, as applicable, Interview participants’ names, time and length of Interviews, Interview participant contact information, Interview responses, Interview transcripts, and video recordings of the Interviews;
  • E-mail address, first name and last name of Candidates who are older than 13 years of age;
  • First name and last name of Candidates who are under 13 years of age posted by their parents/legal guardians;
  • Any other Personal Information that You may enter when You use the Platform or during the Interview, such as, Personal Information (e.g. telephone number, home address, etc.) included in a resume, cover letter, essay, or other similar Interview ancillary document posted by You (or by You on behalf a child Candidate under 13 years of age), or in any Interview responses by You;
  • Billing and payment information of Organizations;
  • Geo-location information;
  • Technical support records;
  • Service requests and inquiries; and
  • Any information that Kira Talent collects from You that is intended to improve and personalize Our Services.

b. Non-Personally Identifiable Information

Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any User (“NPI”).  This may include Interview detail data that is aggregated among many Users.  Such information by itself or together cannot be tracked to a specific individual’s Personal Information.

How do We use Personal Information?

Kira Talent collects Personal Information only for the following purposes:

  • to make available the Platform to facilitate Interviews between Candidates and Organizations and, in the case of Candidates who are children under 13 years of age, to facilitate Interviews between such children, their parents/legal guardians, and Organizations;
  • to create and administer Organizations’ user accounts, including to authenticate Organizations’ users on log-in, for the Platform;
  • to provide Candidates access to the Platform, and, in the case of Candidates who are children under 13 years of age, to provide their parents/legal guardian with access to the Platform;
  • to establish and maintain responsible commercial relations and to communicate with You in order to provide Services;
  • to respond to any correspondence You may direct to Us;
  • to understand Our Users’ needs and preferences;
  • to retarget advertisements to Users of the Website ;
  • to enforce Our Terms of Service;
  • to provide You with Service or administrative messages;
  • to meet legal and regulatory requirements; and
  • for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.

See “Children Under 13 Years of Age”, below, for more information.

How do We use, collect and share NPI?

We use NPI in an ongoing effort to better understand and serve Our Users, to customize the Services and to improve the content and functionality of the Services.

For instance, We use NPI to provide relevant, targeted advertising to Users of the Website (but not to Users of the Platform); monitor traffic; collect statistical data.

We also conduct research on Our User demographics and behavior based on Personal Information and the NPI that We have collected.  This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

No NPI by itself, or together with aggregated Personal Information (which, as explained below, is treated as NPI under this Privacy Policy), can be tracked to a specific individual’s Personal Information.

We automatically receive and store certain types of NPI regarding our Users’ use of the Services, including IP address, browser type, web pages viewed, domain name of Users’ ISPs, date and time, and how Users interact with Us.  We use different types of technology to collect this information, such as log files, cookies, web beacons, and pixel tags.

We use Google Analytics which uses cookies to track NPI about traffic and visitors to Our Services in the aggregate to compile statistical reports about the activity on the Services as well as to benchmark the Services to other third parties who also use Google Analytics.  This information is used by Us to improve the Services and their functionality.

You may disable cookies using Your browser’s settings. Please consult Your browser’s help function for information on how to disable cookies.  Note that if You disable cookies, certain features of our Services may not function to their fullest potential.

The NPI collected by Us will not be shared with third parties, except as expressly indicated in this Privacy Policy, or with Our Affiliates (as defined below), business partners and other third parties to describe Our Services and for other lawful purposes.

Children Under 13 Years of Age

We recognize there are unique issues raised about the protection of children’s privacy over the Internet.   The Website and other Services are not directed at children under the age of 13 years and We will not knowingly collect Personal Information about a child under the age of 13 via the Website or Other Services.

Nevertheless, there are some circumstances where Organizations may, via the Platform only, Interview Candidates who are children under the age 13 simultaneously with such child’s parents and/or legal guardians (e.g. as part of the admissions process to an education institution).

The Services are designed to comply with the requirements of the PIPEDA and other relevant privacy laws for online services gathering Personal Information from individuals, including from children 13 years of age in such Interview circumstances.  We do NOT: (a) collect Personal Information from children under 13 years of age without prior parental or legal guardian consent; (b) collect, use, or distribute or disclose to third parties, any Personal Information of a child without prior parental consent and other than in connection with such Interviews conducted via the Platform, as described above under the headers “How do We use Personal Information”, “How do We use, collect and share NPI”,  “Disclosure, Retention and Limited use of Personal Information”, and under the header “Law Enforcement Requests”); (c) entice children to divulge more information than is needed to participate in Interview with Organizations via the Platform, such as, by offering extraneous fields that might encourage Users to enter more Personal Information than is needed;  (d) enable children to publicly post or otherwise distribute Personal Information; or (e) allow minors to create accounts or register to use the Platform without their parent/legal guardian.

As with those whose Personal Information has been collected, parents and legal guardians can always ask to review any Personal Information about their child that has been collected via the Platform and have Us delete or destroy any such Personal Information. To do so, simply contact Us following the procedure outlined below in “Inquiries; Challenging Compliance”.

Consent

We respect Your privacy and, unless otherwise required by law, We will not collect, use or disclose Your Personal Information without Your prior consent.

With respect to consent regarding children under 13 years of age, please see above under the heading “Children Under 13 Years of Age”.  We do NOT collect Personal Information from children under 13 years of age without prior parental or legal guardian consent.

Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means.  In certain circumstances, Your consent may be implied by Your actions.  For example, participation in an Interview or providing Us Personal Information to register for Our Services is implied consent to use and disclose such information to provide You the associated services, such as for conducting and/or participating in Interviews.

Where appropriate, Kira Talent will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Kira Talent wants to use information for a purpose other than those identified above).  In obtaining consent, Kira Talent will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Kira Talent may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Kira Talent shall take into account the sensitivity of the Personal Information and the reasonable expectations of Our Users.  Kira Talent will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to Kira Talent in writing.   Candidates may contact Us (see the section under the heading “Inquiries; Challenging Compliance” below) to have their Personal Information destroyed or erased from Our records.

Disclosure, Retention and Limited Use of Personal Information

Unless as part of the Interview process between Candidates and Organizations (or, for children Candidates under 13, among such children, their parents/legal guardians and the Organization) via the Platform, or as required by law, or in connection with a business transaction, Kira Talent shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining Your consent, where such consent may not reasonably be implied.

Except as noted above, Kira Talent does not disclose Your Personal Information to third parties.  Notwithstanding, Your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by Kira Talent to assist it in providing and developing products and services.  Such Affiliates will only use Your Personal Information for the purposes identified in this Privacy Policy.  In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, Kira Talent will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Kira Talent’s and Our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about Our Users.   All such employees will be required as a condition of employment to contractually respect the confidentiality of Our Users’ Personal Information.

Kira Talent will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Kira Talent.

Law Enforcement Requests

We will disclose Personal Information without Your knowledge or consent if We receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If We receive a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, Our policy is to provide the requested information.

Storage Outside of Canada

Your Personal Information may be used or stored by Us or Our service providers outside of Canada, unless You have contracted with Us to ensure Your Personal Information is only stored in Canada. We require that Our service providers safeguard Your Personal Information. However, if Your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.

Links to Other Websites

Our website may contain links to other websites that may be subject to less stringent privacy standards.  We do not assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites.  We are not responsible for how such third parties collect, use or disclose Your Personal Information. You should review the privacy policies of these websites before providing them with Personal Information.

How can I Access my Personal Information?

Upon request, Kira Talent will provide information to You or a User regarding the existence, use and disclosure of his or her Personal Information.  Kira Talent will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. 
A User may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Kira Talent may not be able to provide access to all the Personal Information it holds about a User.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Kira Talent will provide the reasons for denying access upon request.

Safeguards

Kira Talent protects Your Personal Information by security safeguards appropriate to the sensitivity of the information.  Kira Talent will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Our methods of protection include:

  • Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to Kira Talent’s place of business in general and to internal offices as well;
  • Organization measures, such as security clearances and limited access on a need to know basis; and
  • Technological measures, such as the use of passwords, firewalls and encryption.

Inquiries; Challenging Compliance

An individual will be able to make inquiries and/or address a challenge concerning compliance with this Privacy Policy to Kira Talent’s Privacy Officer.

Kira Talent will maintain procedures for addressing and responding to all inquiries or complaints from Our Users about Kira Talent’s handling of Personal Information. Kira Talent shall investigate all complaints. All inquiries or complaints involving Kira Talent’s handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to Kira Talent’s Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt.  The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Kira Talent finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact Our Privacy Office as follows:

E-mail: privacy@kiratalent.com

Mail:

Kira Talent Inc.

Attn: Privacy Officer

48 Hayden Street
Toronto, ON
M4Y 1V8

General

Kira Talent reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Website and will be effective as of the date of posting.

Last Revised: ­June 8, 2017