NOTE: FOR ALL LOGIN OR SUPPORT QUESTIONS, PLEASE CONTACT: firstname.lastname@example.org.
YOU MAY OPT IN TO OUR SHARING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR THEIR MARKETING AND OTHER LAWFUL BUSINESS PURPOSES BY FOLLOWING THE DIRECTIONS IN THE “OPT IN AND OPT OUT RIGHTS” SECTION BELOW.
“Personal Information,” as used herein, refers to information that may specifically identify You as an individual or allow online or offline contact with You as an individual, such as: Your name; home and/or business address; e-mail address; home and/or business telephone number, race, gender, nationality, citizenship, languages spoken or veteran status. Personal Information amounts to ‘personal data’ for the purposes of and as defined in the GDPR. All references to Personal Information shall be deemed to include ‘personal data’ as defined and used in the GDPR (to the extent applicable).
Opt In and Opt Out Rights
You have the right to “opt in” and “opt out” of certain of our uses of Your Personal Information.
Regardless of whether You opt-out of receiving correspondence from us, we may still contact You, and share Your Personal Information with third parties, in connection with Your relationship, activities, transactions and communications with us, including relating to access or use of the Sites or the Services by You or, if You are an Authorized User, by the Customer with which you are associated.
COLLECTION OF INFORMATION
We collect Data from You when You use our Sites and Services. For example, Data is collected when:
- You register to establish an Account;
- You update Your Profile;
- You submit any feedback, comments or questions to us, or You contact us by e-mail or through any other means;
- You submit information and materials for Services to be performed;
- You complete transactions or surveys on any Site or through the Services;
- You use the interactive features of the Sites, for example, to access, review, clean or manage Your Account;
- You use our blog or other social media sites or portals to communicate with us and/or our personnel;
- You in any other way submit Data to us via the Sites or the Services; or
- You send information about our products, services, or resources to others through the Sites or Services. In some of these cases You may identify such others to us, including by providing an e-mail address of any such person or entity to us, as well as any notes or materials You communicate to such person or entity.
IP Address and Clickstream Data
Our server may collect information about the computer or other device You use to access or use the Sites or the Services. This information may include the Internet address of the computer or other device You use when You access or use the Sites or the Services. Your computer’s Internet Protocol address, or IP Address, is a number that is automatically assigned to Your computer by Your Internet Service Provider (“ISP”) whenever You connect Your computer to the Internet. When You operate Your computer to request and receive webpages or other content from our Sites or Services, our servers may log Your IP Address. We may also log Your domain name, which is a textual identifier for Your computer that also may have been assigned by Your ISP. We use Your IP Address and domain name to help identify You and to gather demographic information about our customers as a whole. We may also record the referring webpage that linked You to us (e.g., of another website or a search engine); the webpages or other content You view on the Sites; the website or webpage You visit after the Sites; the ads You see on the Sites and/or click on; other information about the type of web browser, computer, platform, related software and settings You are using when accessing and/or using the Sites or the Services; any search terms You have entered on any Site or a referral site; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our server, and to administer the Sites and the Services. Such information may also be used to gather demographic information, such as country of origin and ISP. We may link this information with Your Personal Information.
Any or all of this information relating to accessing or usage of the Sites or the Services may be collected, compiled, maintained, processed, or otherwise used on our behalf by one or more service providers, including, for example, analytics vendor(s) and e-mail management partner(s).
USAGE OF INFORMATION
For the avoidance of doubt, the Sites or Services may use third-party service platforms (including to help analyze how users use the Sites or Services). These third-party service platforms may place cookies on Your computer or mobile device. If You would like to disable "third party" cookies, You may be able to turn them off by going to the third party's website.
Here are links to the main third-party platforms we use:
We may use web bugs (aka “web beacons” or “pixel tags”) or similar technologies in the Sites, Services, and/or in communications with You to enable us to evaluate the Sites and Services usage information about users, upgrade user information, and know whether You have visited a webpage or received a message. A “web bug” is typically a one-pixel, transparent image (although it can be a visible image as well), located on a webpage or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a webpage or e-mail message. A web bug may enable us to relate Your viewing or receipt of a webpage or other message to other information about You, including Your Personal Information.
USE OF DATA AND PERSONAL INFORMATION
We will only use Your Personal Information to the extent that the law allows us to do so. Pursuant to the GDPR, legal bases for our processing Your Personal Information may include (without limitation):
(a) where You have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
(b) where it is necessary to perform the contract we have entered into or are about to enter into with You (whether in relation to the provision of the Sites or Services or otherwise); and/or
(c) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing the Sites and the Services and Your interests or fundamental rights and freedoms do not override those legitimate interests.
We will use the Data we collect or that You provide to use for various purposes, including, for example, to respond to Your requests, to foster a positive user experience, to provide You with the Services and features offered on or through the Sites and Services, and to operate and improve our Sites and Services.
By visiting the Site(s) or using the Service(s), including by creating an Account or Profile, by publicly posting information, or by opting in when presented with certain choices, You have consented for HealthcareSource to use Your Data, including Personal Information, in the following ways:
- to maintain our internal record keeping;
- to report information about Your account in connection with our collection process regarding late payments, missed payments or other defaults;
- to enhance Your user experience;
- to create an Account or Profile for You based on the Data You provided to us or based on the Data You imported from other sites or services;
- to allow You to export Your Data to other Sites or Services;
- to allow You to export Your Data to sites or services of third parties;
- to match Data collected from You through different means or at different times, including both Personal Information and Site or Service usage information, and use such Data along with data obtained from other sources, including third parties;
- to compare Your contact information to data in our databases in order to improve the Sites or Services and for marketing purposes;
- to allow You to contact other users, including employers, End Users, colleagues, or friends;
- to allow employers, End Users, colleagues, or friends to find You and connect with You;
- to provide employers with information about You as an End User;
- to make suggestions to You and draw inferences about You;
- to customize advertisements and other content displayed to You on the Sites or through the Services, including sending You new job postings or related Services, based on Your Data;
- to analyze user behavior as a measure of interest in, and use of, the Sites and Services both on an individual basis and in the aggregate;
- to correspond with You, about products, services, companies, job opportunities, training curriculum, and events, sponsored by us and/or others, that we think might interest You; provided that You may opt-out of receiving such correspondence from us by following the instructions in the Opt In and Opt Out Rights section above;
- to provide our customers with benchmarks about the characteristics and trends of the talent management market, including availability, behavior, experience, and performance of talent;
- to give search engines access to publicly posted information; and
- to detect, investigate, and prevent activities that may violate our policies or be illegal.
As mentioned, we may provide You an opportunity to receive offers from other entities that have services, products, and offers that we think might be of interest to You. We do not and cannot control information collected by these entities; the collection and use of that information is subject to any applicable privacy policies of those entities. Further, we will not transfer Your contact information to any unaffiliated third party for the third party’s marketing purposes unless You opt in. If You change Your mind and no longer want to receive third party promotions, follow the instructions to opt out in the Right to Opt In and Opt Out section above.
Please remember that if You post or transmit any of Your Data, including Personal Information, such information may be collected and used by third parties, including HealthcareSource’s customers, over whom we have no control. Data You post in public areas of the Sites or Services or make available to certain third parties or make visible or available in certain databases, such as resume or Profile databases, may be accessed, used, and stored by others around the world, including in countries that might not have legislation that guarantees adequate protection of Personal Information as defined in the country in which You reside. We are not responsible for the use made by such third parties of information You post or otherwise make publicly available.
SHARING OF INFORMATION
We may share Your Personal Information and Data with potential employers, including HealthcareSource’s business customers, including when You apply for a position through the HealthcareSource Job Board.
We may use third parties who help us operate the Sites, deliver our products and Services, provide marketing assistance, process credit card payments, or provide customer service. We may share Your Data with our affiliates, advertisers, service providers and other third parties (“Service Providers”) that provide products or services for or through the Sites or Services or for our business (such as Website or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf). These Service Providers may have access to Your Personal Information as necessary to perform the functions, but may not use that data for any other purpose. Please note in particular that the Sites or Services may use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when You use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage You to visit Google’s website, including its list of currently available opt-out options.
Except with respect to (i) a business transfer (defined below); (ii) compelled disclosure (defined below); (iii) sharing with our Service Providers (defined above); or (iv) as otherwise stated herein, HealthcareSource will not share, disclose, sell, or lease Your Personal Information to any third party without Your consent.
Subject to the “Personal Information” section above, we may use, disclose, or sell Your Data for any purpose including, but not limited to, evaluating and improving the Sites and the Services, providing customer support, developing new features of the Sites, features of the Services, products, or services, or sharing with third parties in connection with the development, marketing, and sale of the Sites or Services.
As mentioned, we may share Your Personal Information with third parties if You consent. For example:
- if You make Your Account, Profile, or other Data, including resumes, assessments, training reports, and other information submitted to us through the Sites or Services, searchable by employers or other users;
- if You opt-in to receive information about opportunities, products, or services of third parties, we will supply the contact information You submitted as part of opting in to such disclosure;
- by applying for a job, providing Your contact information to show interest in a job, or replying to a message from an employer, You affirmatively opt-in and consent to the disclosure of Your Profile information, including Personal Information, to that employer; or
- by providing any Data generated through Your use of certain features of the Sites or Services, including assessment scores, performance appraisals, or course completion reports, to an employer, You affirmatively opt-in and consent to the disclosure of such Data to that employer or to other employers.
We reserve the right to disclose any Data (including Personal Information) or information concerning You as necessary or appropriate to satisfy any law, regulation or other governmental request, to properly operate the Sites and Services, or to protect or defend our rights or the rights or well-being of our users or if You are involved (or are reasonably suspected to be involved) in any illegal or harmful activity, even without a subpoena, warrant or court order. We may release certain Data (including Personal Information) when we believe that such release is reasonably necessary or proper to protect the rights, property, and safety of others and ourselves. We also may disclose Data (including Personal Information) in connection with investigations by us or by a government agency or when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Sites or Services, or anyone else that could be harmed by such activities.
From time to time, we may be required to provide Personal Information or other Data in response to a valid court order, subpoena, government investigation, lawful request by public authorities, including to meet national security or law enforcement requirements, or as otherwise required by law.
We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
We reserve the right to make any such compelled disclosures or reporting of unlawful activities without any notice (including any prior notice or any subsequent notice) to You.
HealthcareSource regards its databases (including Your Data and Personal Information) as a valuable asset. In the event that HealthcareSource is or substantially all of its assets are, acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Personal Information and other Data may be one of the transferred assets. In using the Sites and the Services You consent to such transfer of Your Data, including Your Personal Information.
Publicly Provided Information
You acknowledge and agree that You have no expectation of privacy with respect to Your postings on any public areas of the Sites or Services, including, without limitation, related blogs, message boards, job posting, or social media sites.
Third Parties Generally
If you opt in, we may also provide Your Personal Information to third parties. For example, we might share our users’ Profile information with third parties (including without limitation consultants, partners, schools and other courseware providers), in order for third parties to contact users about products, services and information that may be of interest, including in order to send accreditation information.
ACCESS AND SECURITY OF INFORMATION
We retain all Data we gather about You in an effort to make Your repeated use with us more efficient and relevant.
You may review, edit, and delete the Personal Information and certain other Data that is stored in Your Account or Profile on any Site or Services (e.g., Your passwords, resumes, and other contact information) by visiting a “My Profile” or similar area of Your Account or by e-mailing email@example.com. Upon written request, we will send You a copy of the Personal Information we have on file in Your user account (if any). You may send us new or updated Personal Information at any time. We will respond to Your request to access, update or delete Your information as soon as practicable. Before we are able to provide You with any Personal Information, correct any inaccuracies, or delete any information, we may ask You to verify Your identity or to provide other details to help us to respond to Your request.
Please be aware that HealthcareSource is a data processor of certain information, which may include Your Data or Personal Information, for our Customers. We may also be a processor of certain information on behalf of our enterprise customers. If HealthcareSource received Your Data in this way, You may be advised to contact the Customer instead of HealthcareSource with any request to access, review, correct, or delete Your Data, Personal Information, Account or Profile. Access to, or correction, update, or deletion of Your Data, Personal Information, Account or Profile may be denied or limited by HealthcareSource if it would violate another person’s rights and/or as otherwise prohibited by applicable law.
Under certain circumstances, and in compliance with the GDPR, You may have the right to:
Request access to Your Personal Information (commonly known as ‘subject access request’). This enables You to receive a copy of the Personal Information we hold about You and to check that we are lawfully processing it;
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 Your Personal Information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of Your Personal Information in certain circumstances;
Object to processing of Your Personal Information where we are relying on a legitimate interest (or that of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground;
Request the restriction of processing of Your Personal Information. This enables You to ask us to suspend the processing of Your Personal Information, 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; or
Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). If You have any complaints about the way we process Your Personal Information, please do contact us. Alternatively, You may lodge a complaint with the supervisory authority which is established in Your country.
If You want to review, verify, correct or request erasure of Your Personal Information, object to the processing of Your Personal Information, or request that we transfer a copy of Your Personal Information to another party, please contact firstname.lastname@example.org.
You should be aware that it may not be technologically possible to remove each and every record of the information You have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of Your Personal Information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving Your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all Personal Information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
HealthcareSource will take reasonable steps to protect the security and integrity of Your Personal Information from loss, misuse, alteration or destruction, including making sensitive information available to our employees and agents on a need-to-know basis. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be free or absolutely safe from unauthorized access or intrusion by others, such as hackers. By using the Sites or Services, You acknowledge that You understand and agree to assume these risks.
If You contact us by e-mail or a “contact us” or similar feature on the Sites or Services, You should be aware that Your transmission might not be secure. A third party could view information You send by these methods in transit.
You may be able to create an account on the Sites or in the Services with a username and password. HealthcareSource policies preclude access to passwords by anyone at HealthcareSource or its service providers except on a need-to-know basis. If You do create a username and password, You are responsible for maintaining the strict confidentiality of Your account password, and You shall be responsible for any access to or use of the Sites or Services by You or any person or entity using Your password, whether or not such access or use has been authorized by or on behalf of You, and whether or not such person or entity is Your employee or agent. You agree to (a) immediately notify HealthcareSource of any unauthorized use of Your password or account or any other breach of security, (b) take any reasonable steps within Your control to prevent any further unauthorized use or breach, (c) ensure that You exit from Your account at the end of each session, and (d) ensure that any individual leaving Your organization no longer maintains any access to Your account. It is Your sole responsibility to protect Your password, control access to and use of Your account. We will not be responsible or liable for any loss or damage arising from Your failure to comply with this provision.
We will have no liability for disclosure of Your information due to errors or unauthorized acts of third parties during or after transmission.
In the unlikely event that we believe that the security of Your Personal Information in our possession or control may have been compromised, we may seek to notify You of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and will do so using the contact information You have provided to us and that we have stored for You as Your Personal Information. It is Your responsibility to ensure Your contact information remains up-to-date. To the extent that the contact information we have for You includes an e-mail address, we may notify You by e-mail of any potential compromise of Your Personal Information. By visiting the Sites and using the Services, You consent to our use of e-mail as a means of such notification.
Please know that it has become increasingly common for unauthorized individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the e-mail address from which such an e-mail appears to have been sent, and the domain name of the website requesting such information, appears to be the domain name of a legitimate, trusted company, while in reality, such sensitive information is received by an unauthorized individual to be used for purposes of identity theft. This illegal activity is known as “phishing.”
Please know that we will never ask You to provide us with Your password for any reason, and will not ask You to provide any sensitive information (including Personal Information) via e-mail. If You receive an e-mail or other correspondence requesting that You provide any sensitive information (including Your password) via e-mail or to a website that does not seem to be affiliated with HealthcareSource, or that otherwise seems suspicious to You, please do not provide such information, and report such request to us at email@example.com.
Consent to Worldwide Transfer and Processing of Personal Information
Third Party “Linked-To” Websites
Do Not Track
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.
Use By Minors Prohibited
The Sites and Services are not geared towards children, and use of all of the Sites and all of the Services is limited to legally-competent adults aged 18 and older, unless a parent or guardian explicitly authorizes such use and we consent to such use. HealthcareSource does not knowingly solicit, collect or maintain any information from children under the age of 13. If You believe that Your child under 18 has gained access to the Sites or Services without Your authorization and without our permission, please contact us at firstname.lastname@example.org. If You are under 13 years of age, then please do not use or access the Sites or Services at any time or in any manner. Should a child whom we know to be under 13 send Personal Information to us, we will use that information only to respond directly to that child (or a parent or guardian) to inform the child that we must have consent from a parent or guardian before receiving the child’s Personal Information, and we will then take the appropriate steps to delete such information, potentially including (at our discretion) immediately terminating the Account used by the child and deleting all Data associated with the Account, potentially without advance notice to the account holder.
Questions or Comments
If You have any questions or comments regarding our privacy practices, You may contact us at email@example.com. You may also send any comments, questions or concerns by mail to:
HealthcareSource HR, Inc.
100 Sylvan Road, Suite 100
Woburn, MA 01801
Updated May 23, 2019