Updated September 22, 2016
EU – U.S. Privacy Shield
Scout Exchange LLC participates in and has certified its compliance with the EU – U.S. Privacy Shield Framework. Scout Exchange LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
Scout Exchange LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Scout Exchange LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Scout Exchange LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Scout Exchange LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
U.S. – Swiss Safe Harbor
Scout Exchange is committed to safeguarding the privacy of its employees, applicants, clients, and users of its website, software and services. Scout Exchange complies with the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. Scout Exchange has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Scout Exchange’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
All individuals who provide personal information in connection with their use of the Software (as defined below), such as customers, business partners, and others;
all locations where we operate, even where local regulations do not exist; and
all methods of contact, including in person, written, via the internet, direct mail, telephone or facsimile.
The Scout Software
Scout is a hosted software product provided and hosted by Scout Exchange that acts a venue for employers, on the one hand, and search firms, on the other, to match qualified and interested candidates with unfilled employment positions (the “Software”). The Software is integrated with and accessed through your Applicant Tracking System (ATS).
The Scout Exchange Website
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. On our Site, we are using session cookies to measure user activity, tracking and analysis such as for email campaign effectiveness. In the Scout Software, session cookies are used to maintain authentication and authorization for Scout users. We use persistent cookies to make it easier for you to navigate the Software. Specifically, we use persistent cookies to track whether you are logged into the Software. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.
This Site and our Software are not directed to person under the age of 13. If you become aware that your child has provided us with personal information without your consent, please contact us firstname.lastname@example.org. We do not knowingly collect or solicit information from, market to or accept services from children. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information.
Notice and Information we collect
In the course of conducting its business and to provide the Software, Scout Exchange collects and stores certain personal data, including (i) the personal information of persons whose information has been submitted by an application and/or resume to a third party search firm (“Candidates”), including Candidate names, home addresses, email addresses, and employment history (this information is collectively referred to as “Candidate Resume Data”) and (ii) contact and billing information of certain business partners and customers, including applicant tracking systems, staffing agencies and employers who have registered to use the Software (“you” or, collectively with other individuals and entities who have registered to use the Software, “Users”), including job description data, historical placement data, contact information and bank routing information (this information is collectively referred to as “User Data”).
The personal information we collect may be stored on our servers, and on the servers of third party service providers.
Use of Collected Information
Collected User Data is used to make available and to improve our high standard of reliable services. We use User Data to:
- respond to inquiries or service requests and monitor such responses;
- provide information about and market our products and services;
- resolve problems; and
- manage the Site and assess usage of the Software.
Candidate Resume Data supplied by Users is used solely to provide and make available the Services.
Onward Transfer and Disclosure
Certain User Data that you provide, including your name, job posting descriptions and staffing history, may be viewed by other Users of the Software. In addition, we may disclose personal information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products and services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our Users and visitors (such as the number of Users of our Software, the geographic distribution of our Users, the amount of information located and/or removed, etc.).
As an integral part of the Software, information regarding the professional background and contact details of individual Candidates may be shared with Users who may consider utilizing such individuals. Candidate Resume Data supplied by you, if applicable, is not initially viewable by other Users of the Site in personally identifiable form. Instead, employer Users will see non-personally identifiable extracts of Candidate Resume Data, including the Candidate’s first name and last initial, industry experience and general location. If the employer User expresses interest in such Candidate, that User will automatically be permitted to view full Candidate Resume Data for such Candidate, including personal information. If you upload or otherwise supply Candidate Resume Data to the Software, you agree and acknowledge that you have read and understand the foregoing, and represent that you have obtained all the necessary consents from Candidates to disclose such information. You understand that in providing the Software, we must rely upon your representation and warranty that you have all the necessary rights to provide the Candidate Resume Data for incorporation, use and, potentially, disclosure, as necessary for Users to make use of the Software.
We may disclose information, including User Data and Candidate Resume Data, that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activities, or to conduct investigations of violations of the terms of any agreement you may have entered into with Scout Exchange with respect to your use of the Software. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s User Data contact information to victims who request it.
We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified User or limited group of Users, we’ll make reasonable business efforts to contact the User(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the User(s) in all cases, whether because of a time limit, court order, inability to effectively contact a User, or for any other reason.
We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, services, Software and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect your information and are prohibited from using your personally identifiable User Data or Candidate Resume Data for their marketing purposes.
Deleting or Correcting Personal Information
Upon request Scout Exchange will provide you with information about whether we hold any of your personal information. If you would like to have your personal information removed from Scout Exchange’s database, or would like to correct or delete an error in such information, please contact us at email@example.com, and we will use reasonable efforts to comply with your request. We will respond to your request to access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Choice and Opt-Out
We provide you the opportunity to “opt-out” of having your User Data used for certain purposes when we ask for this information. For example, if you do not wish to receive marketing material from us, you can indicate your preference in the Site’s option area. If you no longer wish to receive our promotional communications, you may opt-out of receiving them by following the unsubscribe instructions included in each communication.We may send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.
Information Related to Data Collected through the Scout Software
Information Related to Data Collected for our Clients
Scout Exchange collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a Candidate whose information has been provided to us for inclusion in the Software and you would like to request not to be contacted by one of our Clients that use the service or have your Candidate Resume Data be removed or updated, please contact the recruiter or application tracking service that is responsible for supplying your information. If you are not sure which third party(ies) has supplied your information, please contact us via email at firstname.lastname@example.org and we will attempt to provide you with all the necessary contact information to initiate the removal or update of your information within a reasonable timeframe. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
If you are a User who has provided Candidate Resume Data, by using the Software and uploading such Candidate Resume Data, you agree that in the event you are contacted by any Candidate requesting the removal or update of that Candidate’s information, you will promptly take all necessary actions to give effect to such update or removal.
Access and Data Integrity Controlled by our Clients
Scout Exchange acknowledges that you have the right to access your personal information. You must immediately update your User Data when and if it changes so that we can maintain accurate data about you. Clients registered to use the Software designate an account administrator responsible for managing the Client account. You may contact your account administrator to update, correct or delete the content and accuracy of your information. Although you may change your User Data, Scout Exchange may retain in backup or inactive files the uncorrected or outdated User Data. Such User Data may be retained for several reasons, including backups for disaster recovery planning, dispute resolution purposes, troubleshooting, enforcement of agreements and to comply with our legal obligations, resolve disputes, and enforce our agreements. Therefore, you should not expect that all of your historical User Data will be removed from our databases at the time you notify us of changes. Scout Exchange reserves the right to correct personally identifiable User Data to make it current and consistent with data directly provided by you.
Scout Exchange takes reasonable security measures such as password protection, encryption, physical locks, etc. as it deems appropriate to protect the information it collects from loss, misuse, unauthorized access, disclosure, alteration and destruction. Employees authorized to access User Data and Candidate Resume Data are required to take the appropriate safe guards to protect the User Data and Candidate Resume Data. Information gathered on the Site and by the Software is encrypted and protected with secure socket layer (SSL) encryption. Only the individual User and Scout Exchange personnel (solely on a need-to-know basis) have access to User Data, (except job posting descriptions or other User Data required for Scout Software to provide its function, which are accessible by other Users) All information collected from Users by Scout Exchange is stored on servers hosted in a physically secure environment. Questions about the security of the website or Software should be directed to email@example.com. Notwithstanding the foregoing, users should keep in mind that the Site and Software are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security. Users are required to keep their Scout Exchange passwords confidential. Scout Exchange is not responsible for misuse of passwords. Users should advise Scout Exchange immediately if they believe their passwords have been compromised.
Social Media Widgets
If you choose to use our referral service to tell a friend about our Web site, we will ask you for your friend’s name and email address. We will add your friend’s name and address to our database. They will have the option to unsubscribe whenever they receive an email from us.
Your friend may contact us at firstname.lastname@example.org to request that we remove this information from our database.