- GENERAL DESCRIPTION OF HOW TRANSPARENTBUSINESS PROTECTS YOUR PERSONAL INFORMATION
It is of great importance to TransparentBusiness, your right to privacy, and the protection of your personal data. We want you to trust that your personal data is secure when you deal with TransparentBusiness, your personal data is in good hands.
- Which categories of personal information do we collect and how do we process such personal information?
|Category of personal information||Types of personal information captured by category|
|Personal details, contact details, and identifiers.||Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth.|
|Commercial information.||History and records of the services and softwares you have obtained from TransparentBusiness.|
|Marketing and research information||
● Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address.
● Demographic information – (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers)
● Browser/web history information and preferences expressed through selection/viewing/purchase of goods, services, and content.
● Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual.
● Analytics and profiles of the individuals based on the information collected on them
|Sensitive information and biometric information.||TransparentBusiness may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.|
|Audiovisual materials.||Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions).|
|Position and professional or employment-related information.||Professional or employment-related information, such as description of current position, job title, employer, location, and TransparentBusiness contact(s).|
|System and application access information and Internet and electronic network activity information.||Where you are provided with access to TransparentBusiness’ systems, TransparentBusiness may collect information required to access such TransparentBusiness systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using TransparentBusiness systems.|
In addition, for recruitment/employment and vendor selection purposes, TransparentBusiness may process the personal information set out in the below table.
|RECRUITMENT/EMPLOYMENT/VENDOR SELECTION CATEGORIES|
|Category of personal information||Types of personal information captured by category|
|Additional personal details, contact details and identifiers.||In addition to the personal details listed above, TransparentBusiness may collect additional personal details such as, but not limited to, national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.|
|Education information and professional or employment-related information.||TransparentBusiness may collect information about your education and professional or employment-related information, such as your employment history.|
|Sensitive information for recruitment purposes.||TransparentBusiness may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. TransparentBusiness collects this information for specific purposes, such as health/medical information to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.|
|Documentation required under immigration laws.||TransparentBusiness may collect information on citizenship, passport information, and details of residency or work permit (a physical copy and/or an electronic copy).|
|Financial information for payroll/benefits purposes||Your banking, tax (when applicable), and other relevant financial details we need for payroll/benefits purposes.|
|Talent management information.||Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance, and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.|
|Requested recruitment information||Information requested to provide during the recruitment process, to the extent allowed by applicable law.|
|Recruitment information you submit||Information that you submit in résumés/CVs, letters, writing samples, or other written materials (including photographs).|
|Information generated by us during recruitment||Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.|
|Recruitment information received from third parties||Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.|
|Audiovisual information processed during recruitment||Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured during recruitment events or video recruitment interviews.|
|Recommendations||Recommendations related information provided on your behalf by others.|
|Employment history and background checks||Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.|
|Diversity related information||Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the TransparentBusiness workforce, subject to legal limits.|
|Assessment information||Information generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.|
- For which purposes and on which legal basis do we use your personal information?
TransparentBusiness uses your personal information only where required for specific purposes. Please view the table below for (i) a list of the purposes for which TransparentBusiness uses your personal information and (ii) an overview of the legal basis for each such purpose.
|Managing our contractual and/or employment relationship with you.||Necessary for 1) the performance of a contract or similar arrangement to which you are a party or 2) managing your employment relationship with TransparentBusiness.|
|Facilitating communication with you (including in case of emergencies, and to provide you with requested information).||Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.|
|Operating and managing our business operations.||Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.|
|Complying with legal requirements.||Necessary for the compliance with a legal obligation to which we are subject.|
|Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).||Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.|
|Research in general and market research.||Justified on our legitimate interest to gain market insights and insights in business and society in general or, where required, the consent of the relevant subjects.|
|Social listening (Identifying and assessing what is being said about TransparentBusiness and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)||Justified on the basis of our legitimate interest of protecting our assets and our brand on social media|
|Ethnographic videography – this is video recording of the activity of individuals in their natural environment, in order to experience, interpret and understand behavior. This may be part of a campaign or project.||Justified on the consent of the relevant subjects.|
|Improving the security and functioning of our website, networks and information.||Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.|
|Undertaking information analytics, i.e. applying analytics to business operations and information to describe, predict and improve business performance within TransparentBusiness and/or to provide a better user experience.||Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.|
|Marketing our products and services to you||Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.|
|Specific Recruitment/Employment/Vendor Selection Purposes||Legal basis|
|Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Manage your application.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Facilitate communication with you.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring proper communication within the organization and with you.|
|Perform administrative functions (e.g. reimburse you for interview-related expenses).||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Perform information analytics, including analysis of our applicant pool in order to better understand who is applying to positions at TransparentBusiness and how to attract and keep top talent.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it continually improves its recruitment processes.|
|In some cases, record your online interview for review by additional recruiters and hiring managers.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees.|
|If you apply for a position in TransparentBusiness, we may enter you into an information data base to receive future mailings about TransparentBusiness positions and events. You may also receive personalized job recommendations.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Transfer your contact information, education information, employment information, application information and the CV, all as supplied by you to our HR team in order to notify you about new positions that may be of interest to you.||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Administration of employee benefits||Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that our employees receive the applicable benefits.|
|Perform any legally-required reporting and respond to the legal process.||Compliance with a legal obligation.|
Legitimate interest means that TransparentBusiness has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular internal privacy reviews and (iv) the rights you have in relation to the processing activity.
We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to one of our privacy policies, doing so will be considered as providing your consent to process your personal information, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal information will not be your consent but any other applicable legal basis.
We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
- Will we share your personal information with third parties?
We may transfer personal information to our service providers and professional advisors, public and governmental authorities, TransparentBusiness companies/affiliates or third parties in connection with TransparentBusiness’ operation of its business, including any (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal information will be given adequate protection as required by relevant information privacy laws and TransparentBusiness’ internal policies. TransparentBusiness may also transfer your personal information to any of its global affiliates/partners in furtherance of any visits to our TransparentBusiness locations.
For example, we may disclose personal information to third parties for other business purposes as follows:
- We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, information hosting, auditing, and information processing;
- To protect and defend the legal rights, safety, and security of TransparentBusiness, our affiliates, users, or the public, including to protect against fraud and malicious activity;
- In connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
Unless you are otherwise notified, any transfers of your personal information from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal information will take place in accordance with the appropriate international information transfer mechanisms and standards.
- What about sensitive information?
We do not generally seek to collect sensitive information (as defined in the second below) (also known as special categories within the EEA). In the limited cases where we do seek to collect such information, we will do this in accordance with information privacy law requirements and/or ask for your consent.
The term “sensitive information” refers to the various categories of personal information identified by information privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic information, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
- What about information security?
We maintain organizational, physical, and technical security arrangements for all the personal information we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal information and the processing we undertake.
- Where will your personal information be processed?
As a global organization with offices and operations throughout the world, personal information we collect may be transferred or be accessible internationally throughout TransparentBusiness’ global business and between its entities and affiliates.
Any such transfers throughout TransparentBusiness’ global business take place in accordance with the applicable information privacy laws.
- What are the sources we get your personal information from?
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), TransparentBusiness’ actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TransparentBusiness’ affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party information providers).
- How long will your personal information be retained by us?
We will retain your personal information only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal information are deleted after a reasonable time according to the following retention criteria:
- We retain your information if we have an ongoing relationship with you. This includes, for example, TransparentBusiness’ actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TransparentBusiness’ affiliates, subsidiaries and newly acquired businesses, employers of our contractors.
- If you have a user account with us, we will only keep the information while your account is active or for as long as needed to provide services to you.
- We retain your information for as long as needed to comply with applicable law, with our global legal, and contractual obligations.
- Which rights do you have with respect to the processing of your personal information?
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- Request access to the personal information we process about you: this right entitles you to know whether we hold personal information about you and, if we do, to obtain information on and a copy of that personal information.
- Request a rectification of your personal information: this right entitles you to have your personal information be corrected if it is inaccurate or incomplete.
- Object to the processing of your personal information: this right entitles you to request that TransparentBusiness no longer processes your personal information.
- Request the erasure of your personal information: this right entitles you to request the erasure of your personal information, including where such personal information would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your personal information: this right entitles you to request that TransparentBusiness only processes your personal information in limited circumstances, including with your consent.
- Request portability of your personal information: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal information that you have provided to TransparentBusiness, or request TransparentBusiness to transmit such personal information to another information controller.
- To the extent that the processing of your personal information is based on your consent, request the withdrawal of such consent at any time. Please note that this will not affect TransparentBusiness’ right to process personal information obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
In addition, you every California resident is entitled to the following rights:
- California law also affords California residents a right to opt out of the “sale” of your personal information. This right is applicable to the extent that TransparentBusiness is engaging in a “sale” of your personal information as that term is defined under applicable law. While TransparentBusiness generally is not in the business of selling information, there are limited circumstances where we share personal information with our clients, third-party partners, or others that we treat as a sale for which California residents have the right to opt out. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
- If you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your personal information or otherwise permitted by law. Contact us to opt out of the “sale” of your personal information. If at any time you would like to opt back in and allow TransparentBusiness to sell your personal information, please contact us.
- To exercise any other rights available to you under California law, please contact us. TransparentBusiness has 45 days to respond to your request. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. Where necessary, this may include asking you for a copy of your passport or driver’s license. If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests from authorized agents in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
- TransparentBusiness may offer certain financial incentives for the collection, sale, or deletion of personal information. Where we would do so, we will provide California residents additional information where required by California law.
If, despite our commitment and efforts to protect your personal information, you believe that your information privacy rights have been violated, we encourage and welcome individuals to come to TransparentBusiness first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against TransparentBusiness with a competent court (either in the country where you live, the country where you work or the country where you deem that information privacy law has been infringed).
- HOW DO WE USE PERSONAL INFORMATION WHEN YOU VISIT TRANSPARENTBUSINESS’ WEBSITE?
In addition to the information set out above, this section describes how we use personal information when you visit TransparentBusiness’ website:
- Which personal information do we gather?
TransparentBusiness collects personal information at its websites in two ways: (1) directly (for example, when you provide personal information to sign up as a user, register as an investor or as an ambassador or provide contact information); and (2) indirectly (for example, through our website’s technology).
We may collect and process the following personal information:
- Personal information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, registering as an investor, registering as an ambassador, newsletters, and alerts, or requesting further information. It is completely up to you whether you want to provide it.
- If you contact us, we may keep a record of that correspondence.
- We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Any postings, comments, or other content that you upload or post to a TransparentBusiness website.
- Our website collects personal information about your computer, including (where available) your IP address, operating system, and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
- Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic information, location information, web blogs and other communication information. Please see the Cookies Policy for more information.
- Do we include (links to) websites and programs of third parties?
Our websites may include:
- Links to and from the sites of our partner networks, advertisers, and affiliates.
- How do we use personal information that we collect from our websites?
We use personal information for the purposes described in section 2.2 above, as well as to provide you with information you request, process user accounts, create investor and partners profiles.
We also analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it, make it more effective and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.
- HOW DO WE USE PERSONAL INFORMATION FOR MARKETING PURPOSES?
In addition to the information set out above, this section describes how we use personal information for marketing purposes:
- Do we send targeted e-mails?
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from TransparentBusiness, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from TransparentBusiness may include additional information privacy information, as required by applicable laws.
- Do we maintain Customer Relationship Management (CRM) information bases?
Like most companies, TransparentBusiness uses customer relationship management (CRM) information base technology to manage and track our marketing efforts. Our CRM information base include personal information belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal information used for these purposes includes relevant business information, such as: contact information, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by TransparentBusiness professionals based on their personal interactions with you.
- Do we combine and analyze personal information?
- Do we share personal information with third parties?
In addition to the third parties mentioned in section 2.3. above, we may share your personal information with marketing agencies and service providers.
- What are your rights regarding marketing communications?
You can exercise your right to prevent marketing communications to you by not checking certain boxes on the forms we use to collect your personal information, or by utilizing opt-out mechanisms in e-mails we send to you.
You can exercise the right to discontinue marketing communications to you, or to have your personal information removed from our customer relationship management (CRM) information bases at any time by communicating to the link indicated in section “6. CONTACT” below. In such cases, we will retain minimum personal information to note that you opted out to avoid contacting you again.
- HOW DO WE USE PERSONAL INFORMATION FOR PRODUCTION ACTIVITIES?
In addition to the information set out above, this section describes how we use personal information in connection with content creation/production purposes.
Some TransparentBusiness entities are in the business of content production. We may process your personal information for these TV, film, marketing, advertising or other related content creation, production, and distribution activities.
The personal information that we process for production purposes include images and footage of you and may include your location at the time of filming.
If you are a member of the public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.
If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.
We may also collect and process special categories of information such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.
- CONTACT US
Please send an email to email@example.com if:
- You have a general question about how TransparentBusiness protects your personal information.
- You wish to exercise your rights in relation to your personal information rights.
- You wish to make a complaint about TransparentBusiness’ use of your information.
LAST UPDATED: March 23, 2021