EU-US PRIVACY SHIELD FRAMEWORK
US-SWISS SAFE HARBOR FRAMEWORK
The Websites are only for users over 13 years of age and GradLeaders does not knowingly collect the personal information of any person under 13 years of age. When you visit the Websites, the Websites will collect personal information about you to give you the best user experience possible. During the registration process you will be asked to input personal information to create an account such as name, email address, city, state and zip code and may be asked additional profile questions regarding your use of the Websites. We also collect credit card information to complete any purchases you make from the Websites. We use Secure Sockets Layer (SSL) which encrypts or codes all the credit card information we collect and transmit to protect against unauthorized access to your credit card information. GradLeaders collects such information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with the Websites.
When you visit the Websites, the Websites may collect anonymous, aggregated data regarding your activities. This anonymous, aggregated data cannot be linked or otherwise used to identify you. We may share aggregated information that includes non-identifying information with third parties for industry analysis and demographic profiling. Users of the Websites shall not be entitled to any compensation stemming from the use of such aggregated or non-identifying information.
Resume and Career Profile
You may also choose to upload additional information, such as your resume and career profile, to improve your experience and use of the Websites. When you upload your résumé it will integrated into GradLeaders' School Résumé Database that is available for purchase by other users of the Websites. Information you submit to the Websites and make public via any public posting or application process, may also be available to other Users or those using the Websites and may be available to third party search engines. We recommend that you guard your anonymity and sensitive information to the extent that you upload any applications. We are not responsible for any Personal Information you chose to disclose on the Websites. Each User with access to your information will be permitted to use the information in the same manner as if you submitted the information directly to that User. GradLeaders makes no endorsement or representations and is not responsible regarding the information privacy practices of any User. Any information you choose to make publically available may reveal, or allow others to identify, your nationality, ethnic origin, gender, age, and other aspects of your life. Publically posting any information on the Websites is entirely voluntary on your part. You may choose not to allow any of your information to be accessible or transferred to third parties, however, this choice may limit your access to the full use of the Services.
As you use the Services, certain information may also be collected passively, including your Internet protocol (IP) address and the browser that you use to visit the Site. GradLeaders may also store a small text file called a "Cookie" on your computer to store your login information (if any) and your personal preferences for the Websites. GradLeaders may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). While you will still be able to use the Websites if you disable Cookies in your browser, certain parts of the Websites may not function as effectively. After you register and enable Cookies, we may associate this information with personal information that we have collected from you.
Use and Disclosure of your Personal Information
GradLeaders will use the personal information you submit to us to provide you full access and functionality of the Websites. Accordingly, personal information may be used for the following purposes: (i) to provide and improve our services, features and content; (ii) to administer your use of our services and accounts; (iii) to enable users to enjoy and easily navigate the Websites; (iv) to better understand your needs and interests; (v) to fulfill requests you may make; (vi) to personalize your experience; (vii) to provide you with announcements, notifications related to your use of the Websites and other communications such as electronic newsletters, promotional e-mails or similar messaging; (viii) to provide service announcements; (ix) to protect against users seeking to hack into the Websites; and (x) to assess the level of general interest in the Websites and specific information included in the Websites.
Except as provided elsewhere in this policy GradLeaders will not disclose your personal information to third parties outside of GradLeaders and its service providers, affiliates, vendors and business partners unless GradLeaders has the good faith belief that disclosure is reasonably necessary to:
During the normal course of doing business, we may share your information among our business units, our affiliates and unaffiliated third parties as necessary in order to service your accounts or orders you place with us. If GradLeaders discloses your personal information pursuant to one of the above-mentioned conditions, it will do so only to the extent necessary.
In some instances, you may opt out of particular third party disclosures or uses of your data by reaching out to email@example.com to opt out of employer access to your data.
GradLeaders acknowledges the individual’s right to access their personal data for the purpose of updating, editing or deleting it. You can access the information that we collect online and maintain through normal updating methods. To update, correct or delete this information, you can contact our Privacy Officer Sean Arata via email (firstname.lastname@example.org) or via telephone (614.376.0721). We reserve the right to take appropriate steps to authenticate an applicant’s identity, to charge an adequate fee before providing access and to deny requests, except as required by the EU-U.S. Privacy Shield Framework.
Your account can be deleted or deactivated, but doing so may result in your not being able to access or receive certain services.
Destruction of Your Personal Data
GradLeaders will store your personal information only so long as necessary to fulfill the purpose for its collection. Once the storage of your personal information is no longer necessary, GradLeaders will securely destroy your data to protect it from unauthorized use or disclosure.
GradLeaders is committed to protecting your personal information. We regularly test our facilities and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure.
The Websites may contain links to other web sites that are not owned or controlled by GradLeaders. The provision of such links is for your convenience and does not signify our endorsement of such web sites or location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other web sites.
GradLeaders may be potentially liable for the onward transfer of personal data to third parties. GradLeaders will not transfer any personal information to a third-party without first ensuring that the third-party adheres to the Privacy Shield principles. GradLeaders does not transfer personal information to unrelated third parties, unless lawfully directed by a client, or in certain limited or exceptional circumstances in accordance with the EU-U.S. Privacy Shield Framework.
In the event that GradLeaders is requested to transfer personal data to an unrelated third party, GradLeaders will ensure that such party enters into a written agreement with the third party requiring them to provide protections consistent with the EU-U.S. Privacy Shield Framework.
Personal information is accessible only by those employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into strict confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of personal information.
GradLeaders assures compliance with this EU-U.S. Privacy Shield Policy and the EU-U.S. Privacy Shield Framework by utilizing the self-assessment approach as specified by the U.S. Department of Commerce. The assessment is conducted on an annual basis to ensure that all of GradLeader’s relevant privacy practices are being followed in conformance with this EU-U.S. Privacy Shield Policy and the EU-U.S. Privacy Shield FrameworkAny employee that GradLeaders determines is in violation of these policies will be subject to discipline, up to and including termination of employment and/or criminal prosecution.
GradLeaders is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
If you have questions, please contact GradLeaders’ Privacy Officer, e-mail: email@example.com. Or you may call us at: 614.376.0721. We will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Policy.
If you are not satisfied with our response, or if contacting us does not resolve your complaint, you can contact BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus – an independent dispute resolution mechanism, pursuant to the EU-U.S. Privacy Shield Framework. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint/
Finally, and as a last resort and under limited circumstances, EU individuals with unresolved privacy complaints can appeal to the Privacy Shield Panel, a binding arbitration mechanism.
EU-U.S. Privacy Shield Policy Effective Date: 1/23/2017
GradLeaders has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
For users outside the United States, please note that any personally-identifiable information you enter into the Websites will be transferred out of your country and into the United States. You consent to such transfer through your use of the Websites. You also warrant that you have the right to transfer such information outside your country and into the United States.
A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties' direct marketing purposes.
If you are a California resident and would like to make such a request, please send an email to firstname.lastname@example.org.
You have the right to access your information to verify its accuracy. To access your information, ask questions about our privacy practices, or issue a complaint, contact our Privacy Officer Sean Arata at:
5980 Wilcox Place,
Dublin, Ohio, 43016 U.S.A.
Email Address: email@example.com