Last Updated: September 28, 2023
Welcome to Horizontal Talent. We offer information about our business and access to our Horizontal Talent Platform via our website at horizontaltalent.com.
By providing us with personal information or using the Services, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Services or provide us with your information.
Important Information About This Policy
While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.
To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate, you keep us informed of this so we can amend our records accordingly.
Personal Information We May Collect or Receive About You
For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. The types of personal information we receive includes the following categories.
- Contact information – first name, last name, email address (personal or business), mailing address (personal or business) on resume, billing address (personal or business), telephone number (personal or business), and details including employer and employment details (personal or business).
- Account information – if you register to use our Services, your username, account password, and other information that we may request or that you may provide relating to your account.
- Candidate user information – if you are candidate that creates a profile to use our Services, certain demographic data, such as your date of birth, gender, and ethnicity; employment information, such as job history, compensation history, and qualifications; education information, such as training, certificates, and applicable degrees; experiential information, including those descriptions that would be found on a resume or a cover letter.
- Employer user information – if you are a prospective employer that creates a profile to use our Services, certain information about your company, title, roles you hire for, and types of candidates you are interested in reviewing.
- Transactional information – details about your, or your company’s, transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to the services purchased by you or your company.
- Financial information – if you are required to pay for use of our Services, your bank account, payment card, and billing information. Note, we use third-party payment processors that handle this information on our behalf.
- Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
- In-app communication information – copies of communications and inquiries you transmit or submit via the platform functionality of our Services to other users, including through email, telephone call, video call, chat, and similar features available in our Services.
- Customer support information – details of any communications or inquiries you submit to us, including technical or customer support requests, through email, calls, chat, or other features available in our Services.
- Job applicant information - if you are a Horizontal Talent job applicant, we may also collect information about you that you submit to us in response to our company job posting. In addition to your contact information, we may collect your education and previous employment information, as well as any resumes, cover letters, or other relevant documents, in connection with your application. Please review the information available on our “Find Jobs” page to learn more.
- Device and usage information – details regarding how and when you use our Services, including the device used to connect to our Services, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our Services, and information about your interaction with our Services.
We collect this information when you access, use, or navigate our Services, fill in forms on our Services, request information on our Services, communicate with us (including by phone, email, or otherwise), interact with our Horizontal Chatbot or other features on our Services, visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.
Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”
Other Information We Collect From You
Like most web operators, we use various technologies to automatically collect the following types of information about you:
- Log Files and Device Identifiers. We use log files to track actions occurring on the Services and mobile application and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
- Web beacons, pixels, and other advertising technologies. Our Services may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership. We use Google Adsense, for example, to host and push third-party ads. You can learn more about how to opt-out of user-based advertising via Google here.
The information collected through these technologies may be combined with personal information. We may share information about your use of our Services with our advertising and analytics partners, who may combine it with other information that you previously provided to them or was made available to them through other means.
Information from Other Sources
We may obtain both personal and non-personal information about you from affiliates, business partners, vendors, contractors, suppliers, and other third parties and add it to other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Services, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
Information from Social Media
If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
How We Use Your Information
We (or the service providers acting on our behalf) use the personal information identified above for the following purposes:
- Negotiating, entering into, and managing our business relationship and agreements with you or your company, including providing our Horizontal Talent platform and related services, and processing payments from you or your company.
- Providing and optimizing your experience using our Services and ensuring that our content is presented to you in the most effective manner. This includes by leveraging third-party service providers who may assist with or facilitate our chat features and functionalities to gather analytics and other insights into the users who visit our Services.
- Communicating with you and responding to your inquiries and communicating regarding our services, our agreements with you or your company, and other issues.
- Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
- Managing customer service issues, including issues relating to the performance of our Horizontal Talent platform, and other customer feedback.
- Developing, updating, and improving our Horizontal Talent platform, customer service, and customer experience, and otherwise improving our knowledge and insights regarding customers.
- Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Services or the purchase or use of our services.
- Enforcing our agreements with you or your company, complying with our legal or regulatory obligations, and defending or advancing legal claims.
- Notifying you about changes to our Services, the terms governing our Services, or material changes to this Policy.
- If you are a job applicant, to process your application to our company, including facilitating and scheduling interviews or any other follow up items.
- Providing you with surveys or otherwise soliciting feedback from you.
- Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Collection and Use of Your Information” below.
Our Marketing Efforts
We may send you direct marketing communications from time to time including news, updates, offers, and other announcements relating to our platform and business. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe using the option provided in the communication you have received (e.g., in the footer of the email) or by contacting us using the information below.
Disclosure of Your Information
When the information we collect is aggregated, anonymized, or otherwise does not identify you, it is no longer considered “personal information.” We may use such information for any purpose or disclose it to third parties, to the extent permitted by applicable law.
In addition, we may disclose your information to the following types of entities:
- Service providers and third-party vendors we use to administer our business and as are necessary for the provision of our Services and performing any contract with you or your company. For example, our IT providers, secure payment processing providers, email, chat, and phone communication providers, customer contact center providers, insurance providers, and document storage providers.
- Other users of our Services when you direct us to make that information available or otherwise consent to us making the information available by virtue of using the Services (e.g., candidates’ profile information is available for employer-users to view and access).
- Affiliates, related entities, and business partners who may offer products or services that are relevant to you.
- Marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
- Analytics vendors in order to understand our Services traffic and usage patterns, optimize our Services, and identify potential new clients. Some of these vendors provide us with technologies that are deployed on our website and automatically collect information from and about your use of the website.
- Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
- Our professional advisors, such as lawyers, accountants, and other similar advisors.
- Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
- Other parties for any purpose we disclose at the time you provide the information.
Protection of Personal Information
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.
Your Choices About Collection and Use of Your Information
We respect your right to make choices about the ways we collect, use, and disclose your information, so we try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following.
- Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out,” “unsubscribe,” or similar link in any such promotional emails and following the instructions provided.
- Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Services.
- Google Analytics – As discussed above, we use Google Analytics in connection with the Services. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use. You can find more information on how Google uses information it collects here.
- Declining to Provide Information – You can choose not to provide us with information we may request through our Services, but that may result in you being unable to use certain features of our Services, request information about our services, apply for or fund Jobs, or initiate other transactions with us.
- Do Not Track Mechanisms – Please note that our Services does not honor “Do Not Track” signals, and such signals will not impact the operation of the Services.
- Jurisdiction-specific Choices – See below for additional choices that may be afforded to you under the laws of your place of residence, see our “Rights Afforded to Certain Individuals” section below.
In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.
Rights Afforded to Certain Individuals
A. EU/UK Residents
1) Rights under GDPR
The European Union’s General Data Protection Regulation and the United Kingdom’s version of the same (collectively, the “GDPR”) afford certain rights to individuals in the European Economic Area (“EEA”). If you are in the EEA, you have the following rights. Note, however, that not all rights apply in all circumstances.
- Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you.
- Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
- Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute, and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
- Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
- Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
- Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR. As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to email@example.com with the subject line, “GDPR Request.” This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months. Please note that we may need to request specific information from you to help us confirm your identity. If you are located in the EEA or UK and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA or UK.
2) Lawful Basis under GDPR
We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so. We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.
|Purpose/Activity||Type of Information||Basis of Processing|
To enter into and subsequently to manage our business relationship with you or your company, including:
To administer and protect our business and services including:
|To make decisions about how best to deliver relevant content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts||
||Necessary for our legitimate interests (better understanding website and platform functionality and how website users navigate and interact with the site)|
|To advance and promote our business interests including contacting you regarding products, services, or promotions that may be of interest to your company, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our products/services, customer service, and marketing efforts||
||Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)|
|To process and respond to applications from prospective employees of Horizontal Talent||
If we transfer personal information from the EEA, Switzerland, or UK to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.
B. Nevada Residents
Nevada residents have the right to direct Horizontal Talent to not make any sale of certain personal information to third parties. Horizontal Talent does not engage in any “sales” as defined by Nevada laws.
Links to Third-Party Services
Our Services may contain links to third-party Services. Such Services have separate privacy policies that you should review. We cannot take responsibility for the content of linked Services or those companies’ data-handling practices.
Our Services is a general audience Services and is not directed at children under the age of 16. Accordingly, we do not knowingly collect personal information from children under age 16 through the Services. Should we discover that a child under age 16 provided us with personal information, we will use that information only to inform the child that we must have parental consent before receiving such information.
Horizontal Talent is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States. You understand and consent that information you provide may be transferred to the United States. You also understand that the data protection laws in the United States may be different from those of the country where you reside. When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.
Changes to this Policy
Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the Services after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
How to Contact Us
1660 Hwy 100 South, Suite 200
St. Louis Park, MN 55416