PRIVACY POLICY
TABLE OF CONTENTS
OUR PRIVACY PROMISES
Last modified 08.05.20241. Safe and sound
We’ll keep your data safe and protect it as if our lives depended on it.
2. Less is more
We will never collect more data than we need from you.
3. Get the best and forget the rest
No spam. No nonsense. We’ll respect your time, your inbox and your interest areas.
4. No hoarding
We’ll never hold on to your data for longer than we need it.
5. You can’t be bought
We’ll never buy or sell your data.
UK & EUROPE
Respecting your privacy
At Evergreen Talent Partners (”We”) are committed to and hugely passionate about protecting and respecting your privacy. Whether you deal with us as a candidate, client or partner we will always make sure we do the right thing by you and that includes doing the right thing by your data.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The EU GDPR, UK GDPR and Data Protection Act 2018 (DPA) are regulations aiming to harmonise data protection legislation across UK and EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate. We welcome this piece of legislation as it is all about understanding you and putting you first, which is what we do every single day.
This privacy policy explains how Stott and May Professional Search Ltd T/As Evergreen Talent Partners processes and protects personal data for:
- candidates who register with us for roles that we are managing for other employers and for roles at Evergreen Talent Partners, or through our website, job boards, social media sites or other sources;
- prospective candidates,
- business contacts at our clients and suppliers; and
- users of our website
(we will refer to all the above as "you" or “your").
Please read the following carefully to gain a deeper understanding of our views and practices regarding your most precious asset – your personal data. We will let you know all of the ins and outs of how we use it and, more importantly, look after it.
For the purposes of data protection legislation in force from time to time the data controller is Stott and May Professional Search Ltd T/As Evergreen Talent Partners of Cannon Green, 27 Bush Lane, London, EC4R 0AA, United Kingdom.
Who we are and what we do
If you had to put us into a box, we are a recruitment agency as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). Given the nature of what we do on behalf of our candidates and clients we have to collect personal data of the following stakeholder groups to ensure we can deliver (when you see the examples below things will make a bit more sense):
- Prospective and placed candidates for permanent or contract roles (so we can help them find work)
- Prospective and live client contacts (so we can keep in touch throughout the recruitment process & once the candidate has started)
- Supplier contacts to support our services (so we can pay our suppliers and keep them as part of our team)
- Employees, consultants, temporary workers (so we can keep our staff happy and do the right things by them)
If we collect information about you, it will be in order to carry out our core business and ancillary activities.
Information you give to us or we collect about you
This is information about you that you give us by filling in forms on our site www.evergreentalentpartners.com (our site) or by communicating with us by phone, video calls, e-mail, personal meetings or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, enter a promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, company name, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the relevant country, identification documents, curriculum vitae and photograph, emergency information, DBS Checks, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, browser type and version, and if you choose to share it, your location data. We do this to improve your experience on our website and, where relevant, direct you to the appropriate sub directory of our site for your specific geography. The net result should be that you are able to either find jobs easier or get a better understanding of whether we are the right recruitment partner for your organisation.
We will also store information about your visit, including referral information (should you choose to share it), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), along with any personally identifiable information you leave on our contact forms. We keep this information to ensure that the context of our communication with you is as relevant as possible. We also store data from surveys that contribute to our research reports and keep your details in some instances in case you’d like a copy. You contributed to it so why shouldn’t you see the results? Ultimately, you don’t have to give us any of this data if you feel uncomfortable with it. The last thing we’d want to do is make you feel uncomfortable.
Information we obtain from other sources
We also obtain information about you from other sources such as LinkedIn, Xing, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including business partners such as management and umbrella companies, search information providers, credit reference agencies and criminal record checking agencies. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to send market updates directly to you or introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts. To successfully match the candidates with the clients we need to retain information such as name, contact details, location, job title, area of expertise and additionally for candidates, their curriculum vitae, education and training data, identification and right to work documents, salary and rate details.
To deliver our ancillary services we need to detail and map different market sectors with their relevant companies. We make note of organisation’s structures and who is currently employed in certain roles. This then facilitates either an executive search process or provides necessary understanding of who is responsible for the relevant teams and/or who may be the best point of contact to progress things further.
Consent
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
- Use of our website;
- To notify you about changes to our service;
- To ensure that content from our site is presented in the most effective manner for you and for your computer or other device.
We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer or other device;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookies Notice.
Disclosure of your information
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
- Clients for the purpose of introducing candidates;
- Candidates for the purpose of arranging interviews and engagements;
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies, our insurance broker, compliance verification partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you;
- Companies hosting personal data for us;
- Partners carrying out testing and development work on our business technology systems;
- Companies offering professional advice to us;
- Suppliers assisting us to communicate with you
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If Stott and May Professional Search Ltd T/As Evergreen Talent Partners or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply of services and other agreements; or to protect the rights, property, or safety of Stott and May Professional Search Ltd T/As Evergreen Talent Partners, our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third-party processing will include:
- Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- Satisfaction of their contractual obligations to us as our data processor;
- For the purpose of a contract in place or in contemplation;
- To fulfil their legal obligations.
We keep your personal data secure
We have implemented and maintain appropriate technical and organisational measures to protect your personal data from accidental or unlawful destruction, alteration, loss, unauthorised disclosure or access. Only authorised personnel and third-party service providers are provided with access to personal data on a minimum need-to-know basis, and these employees and service providers are contractually obliged to treat this information as confidential.
Where we store and process your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the UK or the European Economic Area (”EEA”). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to strive to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you haven’t requested your data to be removed. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
- Prior to making an introduction we check that we have accurate information about you
- We keep in touch with you, so you can let us know of changes to your personal data
- We will contact you at least once every two years in an attempt to update your information on our database
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
- The nature of the personal data;
- Its perceived accuracy;
- Our legal obligations;
- Whether an interview or placement has been arranged; and
- Our recruitment expertise and knowledge of the industry by country, sector and job role.
We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if, legally required, prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise your rights at any time by contacting us at privacy@evergreentalentpartners.com
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Data Protection Act provides you with the following rights to:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which, in the United Kingdom, is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Data Protection Act 2018 and GDPR.
A subject access request should be submitted to privacy@evergreentalentpartners.com
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Contact
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to privacy@evergreentalentpartners.com
USA
Respecting your privacy
Stott and May Inc DBA Evergreen Talent Partners (“Evergreen Talent Partners”, “We” or “Us”) is committed to respecting and protecting your personal data. Whether you deal with us as a candidate, client or partner we will always make sure we do the right thing by you and that includes doing the right thing by your data. This privacy notice is applicable for California residents. This notice applies to and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”).
We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and other applicable California privacy laws, including the California Privacy Rights Act ("CPRA") effective January 1, 2023. Any terms defined in the CCPA and CPRA have the same meaning when used in this notice.
Please read the following carefully to get a deeper understanding of our views and practices regarding your most precious asset – your personal data. We’ll let you know all the ins and outs of how we use it and, more importantly, how we protect it.
For the purpose of data protection legislation in force from time to time, the data controller is Stott and May Inc DBA Evergreen Talent Partners, 45w 27th Street, 10th Floor, New York, NY 10001.
Who we are and what we do
Evergreen Talent Partners is a global recruitment and executive search agency. Given the nature of what we do, on behalf of our candidates and clients, we collect personal data of the following stakeholder groups to ensure we can deliver (when you see the examples below things will make a bit more sense):
- Prospective and placed candidates for permanent or contract roles (so we can help them find work)
- Prospective and live client contacts (so we can keep in touch throughout the recruitment process & once the candidate has started)
- Supplier contacts to support our services (so we can pay our suppliers and keep them as part of our team)
- Employees, consultants, temporary workers (so we can keep our staff happy and do the right things by them)
If we collect information about you it will be primarily in order to carry out our core business and ancillary activities.
Information you give to us or we collect about you
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We are committed to ensuring that this information is used in compliance with all applicable laws and only for legitimate business purposes.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
E. Biometric information. | Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | NO |
G. Geolocation data. | Physical location or movements. | NO |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | YES |
K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. | YES |
Information we collect about you when you visit our website
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, browser type and version, and if you choose to share it, your location data. We do this to improve your experience on our website and where relevant direct you to the appropriate sub directory of our site for your specific geography. The net result should be that you are able to either find jobs easier or get a better understanding of whether we are the right recruitment partner for your organization.
We will also store information about your visit, including referral information (should you choose to share it), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), along with any personally identifiable information you leave on our contact forms. We keep this information to ensure that the context of our communication with you as relevant as possible. We also store data from surveys that contribute to our research reports and keep your details in some instances in case you’d like a copy. You contributed to it so why shouldn’t you see the results? Ultimately, you have the option to opt-out of non-essential data collection by contacting us directly. The last thing we’d want to do is make you feel uncomfortable.
Information we obtain from other sources
We also obtain information about you from other sources such as LinkedIn, Xing, corporate websites, job board websites, online CV libraries, your business card and personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including business partners such as management and umbrella companies, search information providers, credit reference agencies and criminal record checking agencies. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Compliance with State Privacy Laws
In addition to the CCPA, our privacy practices also comply with other state-specific privacy laws including the Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and Utah Consumer Privacy Act (UCPA). These laws provide state residents with specific rights regarding their personal information, which are respected and upheld by our organization in accordance with applicable law.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Directly from you as the candidate or client via Job boards, social networking events, social media and personal recommendations.
- Directly and indirectly from activity on our website (www.evergreentalentpartners.com). For example, from submissions through our website portal or website usage details collected automatically.
Purpose of the processing
We may use or disclose the personal information we collect for one or more of the following business purposes:
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To Match Opportunities: To assess data about you against vacancies which we judge may be suitable for you, enhancing your career prospects and job placements. This includes actively searching for opportunities that align with your skills and career goals, providing personalized job alerts, and helping you navigate the job market more effectively.
- To Enhance Communication: To send you emails, SMS messages and or text messages (where permitted by law and unless opted out), to keep you informed about job opportunities and updates relevant to your career and potential employment.
- To Utilize Third-Party Services: To engage third-party vendors to assist in hosting, managing, and operating our websites; to provide data analysis, and to enhance the functionality and security of our services.
- For Marketing and Development: To develop and market other products and services, improve our customer service, and send you surveys, reports, event details, promotions, offers, and general information about industry sectors that may interest you.
- To Manage and Respond to Inquiries: To identify you, respond to and process your requests for information, and provide you with requested products and or services.
- To Maintain Records: To amend records to remove personal information or to anonymize it for compliance monitoring and marketing materials creation.
- Contractual Obligations: To carry out our obligations arising from any contracts entered into between you and us, which include everyday business purposes that involve the use of personal and sensitive personal information.
- For Job Placement and Candidate Support: To help find you a job, contact you about potential opportunities, and provide you and or your company with relevant job market information. This includes supporting you with any job-related concerns and or adjustments.
- Legal and Compliance Activities: To establish, exercise, or defend legal claims, collect outstanding payments, and or ensure compliance with contractual obligations.
- Client Relationship Management: For individuals working with Evergreen Talent Partners’ clients (i.e., a "client contact"), to fill vacancies, negotiate contracts, resolve issues, and maintain ongoing communication to ensure satisfactory contractual fulfillment and problem resolution.
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organization.
To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organization or any other contract to provide services to you or receive services from you or your organization.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To improve our website and present its contents to you.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may also share personal information with third parties for other purposes permitted by applicable laws, or as part of a merger, acquisition, or other corporate transaction.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Data Retention and Deletion
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to meet legal, regulatory, or operational requirements. We have implemented policies and procedures to securely delete or anonymize personal information that is no longer needed, subject to applicable exceptions and legal requirements.
When we receive a verifiable request to delete personal information, we will take reasonable steps to delete the requested information from our systems, unless an exception applies under the CCPA and or other applicable laws.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Additionally, the CPRA, effective January 1, 2023, provides California residents with additional rights, including the right to limit the use and disclosure of sensitive personal information and the right to correct inaccurate personal information. Our practices and this notice comply with the CPRA requirements.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at our toll free number: 888 998-9366
- Privacy@evergreentalentpartners.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavour to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CPRA rights, including the rights to limit the use of sensitive personal information and or to correct inaccurate personal information.
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 929 575-5235
Website: www.evergreentalentpartners.com
Email: privacy@evergreentalentpartners.com
Postal Address: Stott and May Inc. DBA Evergreen Talent Partners
45 West 27th Street, 10th Floor,
New York, NY 10001