ATX Learning Online Privacy Notice

Effective Date: April 14, 2015

ATX Learning and its group companies, (collectively, “ATX Group”, or “we”) are committed to safeguarding your privacy. In this Online Privacy Notice (“Notice”) we explain to you what information we may collect, use, share, and store about you, and the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below at ‘Contact Us’.
We participate in and comply with the U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as supervised by the U.S. Department of Commerce regarding the collection, use, and retention.

About ATX Learning Group

ATX Learning Group forms partnerships with organizations across the US to optimize talent attraction and retention. We work with clients to help them achieve their talent strategies and business goals, and we help potential candidates fulfil their career aspirations.

Our services include:

• Staffing and recruiting services for technical, and professional through ATX Learning, as well as managed health services via ATX Health.
• Staffing and recruiting services for operations, business, and consultancy positions.
• An online job board and resource for job seekers with disabilities and employers looking to hire in the U.S. via EDUz.org.
• Permanent and contingent workforce management solutions, talent advisory services, and Recruitment Process Outsourcing through ATX Learning.

When this Notice Applies

“Personal information” consists of information which may directly or indirectly identify you.
This Notice applies to our collection, use, and disclosure of your personal information:
(i) through our website(s) and related applications and content that link or refer to this Notice (including the all ATX Learning properties); and ATX Learning computer or mobile software applications (“apps”) and content made available to you) (collectively the “Sites”);
(ii) in connection with any of our events or sales, marketing, advertising and recruitment activities, or in the course of providing other ATX Learning Group services to you (collectively with the Sites, the “ATX Learning Services”); and
(iii) when receiving services from you.
This Privacy Notice does not apply to the practices of third parties that ATX Learning Group does not own or control.

What is in this Notice?

Click on one of the links below to jump to a specific section:
Collection of Personal Information
Use of Personal Information
Cookies and Online Tracking
Sharing Your Personal Information within ATX Learning
Sharing Your Personal Information with Third Parties
International Data Transfers
Your Privacy Rights
Your Choices
Security of Your Personal Information
Data Retention
Children’s Privacy
Links to Other Sites and Public Forums
Contacting Us
Changes to this Notice
Additional Notices

Collection of Personal Information

ATX Learning Group collects and maintains personal information from the following categories of individuals:

• Visitors: individuals who visit or use our site(s) or any other ATX Learning services, so that we can provide them with the site(s) or ATX Learning services they require;

• Job seekers: individuals that apply for job opportunities with ATX Learning Group to fill our internal positions or as part of our staffing and recruiting services or ATX Learning Group’s customers through our search, workforce management, or talent advisory services (in each case, whether such applications are made online or offline);

• Customers, vendors, service providers, and other suppliers: employees, representatives and/or agents of our customers, service providers, vendors, and other suppliers with whom we have a business relationship and/or manage on behalf of our customers.

• Referees and others who advise on the suitability of job seekers for particular positions.

If you submit any personal information relating to other people to us or to our service providers in connection with the ATX Learning Services, you confirm that you have the authority to do so and to permit us to use the information in accordance with this Notice.

The types of information we collect include the following:

• Information submitted to us: ATX Learning Group collects personal information that individuals provide to us through ATX Learning Services, such as when they visit one of our Sites, post on our forums or blogs, sign up for an ATX Learning account to access certain ATX Learning Services (like an ATX Learning Group job board or our Communities Site), or if they subscribe to our marketing, register for an ATX Learning Group event or webinar, or otherwise contact us. We may also collect personal information from individuals’ offline, for example when individuals provide information to us by telephone or in person at events or at one of our recruitment offices.

The types of personal information we may collect include:

• contact information (such as name, postal address, email address, and telephone number);

• username and password when you register on our Sites;

• professional information, such as your job title, department, or job role;

• information you provide about others you would like us to contact (for example referrals or references) or information regarding your emergency contacts;

• resumé or C.V. information, such as employment and education history, language proficiencies, security clearance information, and other work-related skills, awards, and honors, membership in clubs and organizations, personal interests and activities, and information regarding your career interests and other qualifications for or desires regarding future employment opportunities, including information regarding desired compensation and benefits; and

• citizenship and work authorization status.
Where we request information from you, we will let you know prior to collection whether the provision of the personal information we are requesting is required either by employers as a term of their employment or by law, or whether the information may be provided on a voluntary basis, and the consequences of not providing the information.

• Information we collect automatically: We automatically collect certain technical information from visitors to our site(s), such as the Internet protocol (IP) address of their device, their login information, device type and unique identification numbers, browser type and version, time zone setting, browser plug-in types and versions, operating system and platforms. We may also automatically collect certain information about their visits to our site(s), such as download errors experienced and length of visits to certain pages. When you download, install, or use ATX Learning Group apps, we and our service providers may track and collect certain device-related information (such as your type and device unique ID) and certain app usage data (such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device ID.

• Information we obtain from other sources or third parties: We may receive or acquire information about our visitors, job seekers, customers, and suppliers from third-party partners (such as background check providers) or other third-party sources (such as information from publicly available sites (like Monster.com, CareerBuilder.com, or LinkedIn), or a job seeker’s third-party reference.

• You may also choose to provide us with access to certain personal information stored by third parties, like social media sites. For example, if you register for an account to access some of our sites (like the Communities site), you can choose to import your LinkedIn basic profile data (such as your name, experience, location, photo, and contact information). By authorizing the ATX Learning Group to have access to this information, in collecting, storing, and using this information, in accordance with this Privacy Notice, ATX Learning Group will only pursue the legitimate interests set out below under Use of Personal Information.

• We collect publicly available information from job boards or professional social media websites where career data is made available by individuals and can be viewed by recruiters.

Sensitive Personal Information:

In connection with the various services we provide, or if you are applying for a job opportunity with us or one of our customers, you may be asked for types of personal information that are viewed by some countries as sensitive personal information. Sensitive personal information includes, for example, government-issued identification numbers (such as national insurance numbers), information relating to a person’s race or ethnic origin, political opinions or religious or philosophical beliefs, physical or mental health or condition, sexual orientation, trade union membership, genetic data and any related legal actions, or the processing of biometric data for the purposes of uniquely identifying an individual. It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws (collectively “Sensitive Personal Information”).

• Although we aim to minimize the amount of Sensitive Personal Information we process, we may process such information in certain circumstances, such as where we are required to or permitted to do so by law (e.g. information about your racial/ethnic origin, gender, and disabilities for equal opportunity monitoring or affirmative action programs), or where it is necessary to provide you with a service, or if we need to perform a criminal background check, drug/alcohol test or fitness-for-duty testing. If required by applicable data protection laws, we will obtain your express consent to our collection and use of your sensitive personal information.

Use of Personal Information

The personal information ATX Learning Group collects will be used only as described in this Notice and/or in the way we specify at the time of collection. For the most part, we collect and use personal information to effectively provide and improve the ATX Learning Services (such as our Sites and related staffing and recruiting services, or search, workforce management or talent advisory services) and to comply with applicable laws and government regulations (such as, to comply with mandatory employment, tax, and insurance requirements).

More specifically, we may use your personal information for the following purposes:

• Providing and administering the ATX Learning Services and for internal operations (for example, troubleshooting, data analysis, statistical, and survey purposes);
• Protecting the ATX Learning Services (for example, fraud monitoring, and prevention);
• Responding to your communications;
• Complying with applicable laws and government regulations;
• To fulfil your needs if you are a job seeker;
• To match job seeker to job positions;
• To match job positions to job seekers;
• Gauging the number of users and usage of the Site(s), so we can plan Site bandwidth and capacity accordingly;
• Recognizing you when you return as a repeat visitor to our Site(s) or other online ATX Learning Services;
• Providing information on goods and services you have requested;
• Sending you e-mails and other promotional communications about ATX Learning Group marketing, advertising, and promotions in accordance with your marketing preferences. You can opt-out of our marketing at any time (see “Your Choices” below);
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, services and offerings, enhancing, improving or modifying our Sites, products and services, and operating and expanding our business activities; and
• Notifying you about changes to our Site(s) or other ATX Learning Services.

Cookies and Online Tracking

ATX Learning Group websites use “cookies” and similar technologies (like web bugs) to help personalize your online experience and for analytics purposes.
For more information on the types of cookies which are used on the ATX Learning Group websites, please see contact us.

Sharing Your Personal Information within ATX Learning

ATX Learning Group may disclose your personal information to any affiliate within ATX Learning Group for use in accordance with this Privacy Notice. This includes our subsidiaries, affiliates, and our ultimate holding company.

This sharing of personal information with ATX Learning Group affiliates may include combining the personal information gathered by certain ATX Learning Group Sites with information independently gathered on other ATX Learning Group Sites as well as information gathered offline into one or more database(s) useable by ATX Learning Group, including all of its affiliates. Again, this combined information will only ever be used for the purposes disclosed within this Privacy Notice.

Sharing Your Personal Information with Third Parties

ATX Learning Group may share and disclose personal information about you with the following types of third parties and in the following circumstances:

• Potential employers or potential customers – We may share your personal information if you are a job seeker with a customer for the purpose of providing the ATX Learning Services (such as staffing and recruiting services, or search, workforce management, or talent advisory services).

In connection with the above, we may need to disclose certain data about your previous employment (such as your C.V. and corresponding information or to the extent permitted by law, the results of any criminal background checks or other specific employee data such SSN/National ID) with that customer or other service providers or agents acting on our behalf to facilitate and enable the potential placement or employment. To the extent you are employed by a customer of ATX Learning Group through our search, workforce management, or talent advisory services, the ATX Learning Group customer will process such personal information in accordance with its own policies and procedures.

• Compliance with laws – We may disclose personal information to a third party where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process, or government requests, including in response to public authorities to meet national security or law enforcement requirements.

• Vendors, consultants, and other service providers – We use third party vendors, consultants, and other service providers to assist us in providing the ATX Learning Services, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/C.V. data, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training, occupational health and safety screening, and drug and background screening. In providing these services on behalf of ATX Learning Group, it may be necessary for us to provide these third parties with access to your personal information.

• Business transfers – Circumstances may arise where, whether for strategic or other business reasons, ATX Learning Group decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers. It is ATX Learning Group’s practice to seek appropriate protection for information in these types of transactions.

• Vital interests and legal rights – We may collect and possibly share personal information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of ATX Learning Group’s terms of use, or as otherwise required by law, including without limitation to meet national security or law enforcement requirements. We also may disclose your personal information to third parties when we choose to establish or exercise our legal rights or defend against legal claims.

• With your consent – We may disclose your personal information for other purposes with your consent.
Your personal information is never sold, rented, or leased to any external company, unless you have granted us permission to do so.

International Data Transfers

As a global company, we may transfer personal information to ATX Learning Group companies, and third parties located in the United States and in other countries that may be outside your country of residence for storage and processing in order to provide the ATX Learning Services. These countries may not necessarily have data protection laws as comprehensive as those in your country or residence. In addition, we will have taken appropriate safeguards to protect your personal information in accordance with this Notice and applicable law wherever it is processed. Further details of these safeguards can be provided upon request.

Your Privacy Rights

What Are Privacy Rights?
Privacy rights enable an individual to make specific requests to an organization regarding the processing of their personal data. These rights are implemented by data protection laws that differ from place to place.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time but this will not affect any processing of your personal information done before you withdrew your consent, nor will it affect processing of your personal information done on a legal basis other than consent.

How to Exercise Your Privacy Rights?
If you would like to exercise your privacy rights, please send us an email. The email will help us with the relevant information we need to evaluate and respond to your request. You will receive emails to the email address you provide through the web form acknowledging your request and updating you on the status of your request. All communications through this web portal are secure and encrypted. We encourage and appreciate your use of this process as it allows us to track requests in a centralized, secure and efficient system.
To protect your privacy and security, we may take steps to verify your identity, such as a password and user ID if there is an account associated with your request or identifying information such as your address or date of birth, before proceeding with your request.
If you experience any issues with the web form or you prefer to submit your requests to us outside of the preferred method of submission, please contact info@atxlearning.com. Please note that if you prefer to submit your request outside of the web form, we will still need to obtain the same relevant information from you in order to process your request, which may result in the process being less prompt. Regardless of how we receive your request, we will abide by all applicable legal requirements for deadlines for responding to your request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Your Choices

Marketing Communications: Where it is in accordance with your marketing preferences and applicable data protection laws, we may periodically send you updates via e-mail about promotional opportunities or services we think may interest you, such as jobs in our database that match your selection criteria, newsletters, white papers, surveys and event information.
You can opt-out of receiving marketing emails from us.
When we request personal information about you, our sites also give you the opportunity to decide which communications you receive.

Security of Your Personal Information

The ATX Learning Group is committed to protecting the personal information you share with us. The ATX Learning Group uses appropriate physical, technical, organizational and administrative security measures to help protect your personal information from unauthorized or unlawful access, use, or disclosure, and from accidental loss, destruction, or damage.
The ATX Learning Group supports online security using secure server technology because we want your data to be safe. We use state-of-the-art security arrangements and facilities on our sites and through the ATX Learning Services to maintain data security. Unfortunately, the transmission of information via the internet cannot be guaranteed to be 100% completely secure and we cannot guarantee the security of your personal information that is transferred over the internet.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Children’s Privacy

This site is not intended for use by children under the age of 13. ATX Learning Group does not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under the age of 13, we will delete that data from our systems.

Links to Other Sites and Public Forums

ATX Learning Group Sites may contain links to other sites for your convenience and information. If you access those links, you will leave the ATX Learning Group Site. ATX Learning Group does not control those sites or their privacy practices, which may differ from ATX Learning Group’s practices. ATX Learning Group is not responsible for the privacy practices or the content of other websites outside of ATX Learning Group. The personal information you choose to provide or that is collected by these third parties is not covered by this Notice. We encourage you to review the policies of such third parties before submitting your personal information.
ATX Learning Group may make message boards, news groups, and/or public forums available to users on its sites. Any information that you disclose in these areas becomes public information that may be accessed by third parties; therefore, you should use caution before deciding to disclose any personal information in these forums.

Contacting Us

If you have any questions about this Notice, please contact:

ATX Learning Group
9442 Capital of Texas Highway North, Plaza 1,
Suite 500
ATTN: Privacy Officer
info@atxlearning.com

Our Data Protection Officer

The Data Protection Officer is an independent advisor and supervisor of ATX Learning Group’s data protection compliance. The DPO’s advice is directed towards ATX Learning Group in the first instance. The DPO can be contacted at:

Attention: GDPR Data Protection Officer
c/o Legal Department
ATX Learning Group
9442 Capital of Texas Highway North, Plaza 1,
Suite 500,
Austin, Texas, 78759, United States of America @
info@atxlearning.com

Changes to this Notice

If we change this Notice, we will post the revised Notice on our sites, with an updated revision date. If we make significant changes to our Notice, we may also notify you by other means, such as sending an email or posting a notice on our home page. We will update the “Effective Date” at the top of this page to indicate the date from which any changes take effect.

Additional Notices

In addition, sometimes ATX Learning Group acts as a data processor, for example when processing personal information, it receives from one of its customers as part of its staffing and recruiting services, including IT staffing and consulting solutions, workforce management or talent advisory services. Any time that ATX Learning Group acts as a data processor, it will process personal information according to the contractual obligations it has with the applicable data controller. To the extent ATX Learning Group receives requests from individuals regarding the processing of their personal information by ATX Learning Group, it will refer them to and coordinate with the appropriate data controller.