Date : 2022-10-20
Privacy Policy
Thrive Career Wellness Inc. (“Company”, “we”, “our” or “us”) values our customers, including you (“you” or “your”) and we respect your privacy and personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws). This privacy policy (this “Policy”) applies to your use of our websites, software, and/or services (“Offerings”) and describes the kinds of personal information we collect about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information. You shall require us to change, amend, or delete the personal information that you have provided to us at any time.
If this Policy changes in the future, we will post an updated version on our website at www.thrivemycareer.com/privacy (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we shall also decide to send you a notice in other ways at our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Offerings after the Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You:
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect shall include the following:
Logged out users
Logged in users
Logged in admins and customers
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected:
We automatically collect certain information when you visit thrivecareerwellness.com, thrivemycareer.com, thrivemycareer.ca, thrivemycareer.us thrivemycareer.de, thrivemycareer.com.au, careerjsm.com, careerjsm.ca, careerjsm.de, careerjsm.com.au, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but shall include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:
General Usage Data. When you use our Offerings we shall collect technical properties of hardware and software utilized in conjunction with our Offerings. For example, we shall collect the type and model of computer and/or web browser you are using, referring or exit web pages, and the operating system version you are using. When you use our Offerings we shall also collect information about how long you use our Product in each session, features you use in our Offerings, how long you use our Offerings overall, what types of jobs you are seeking, where the jobs are located, whether you apply to jobs, the number of jobs you to apply to, who you apply to for jobs, what sector or industry the employer is in, where the job postings are located that you apply to, whether you were successful in obtaining an interview and the job, and how long did your job search take for you to find a job.
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data shall include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data shall include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we shall use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information by disabling your Location setting on your device. However, if you choose to opt out, you shall not be able to use certain aspects of the Services.
Third Party Information. If necessary to fulfil our identified purposes, we shall combine the information you submit to us with information obtained from other sources or third party offerings. For example, we shall receive personal information about you from third parties involved in providing you with the products, services, software, and websites you are utilizing, such as from your email, calendar, and online file storage provider to facilitate the integration of those products, services, software, and websites with our Offerings. We treat all such personal information in accordance with this Policy and the terms and conditions between us and such third parties, if any, shall also apply. However, the third party's own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is a Thrive Career Wellness service provider.
Quality assurance and customer service. Your customer service emails to us and our service providers, if any, shall be logged and/or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training, and analytics to identify trends and make improvements to our Offerings and customer service.
Cookies. In addition, when you visit our Website, we collect certain information about your activity on our Website, as described below under the heading “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES”.
If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.
We use the personal information we collect about you in order to:
(a) to understand and meet your needs and preferences, and to provide you with our Offerings, for example:
(i) for purposes related to the billing, activation, provision, maintenance, support, troubleshooting, resolving of disputes, deactivation, upgrade, or update of Offerings;
(ii) to ensure Offerings are technically functioning as intended and to help identify and troubleshoot issues;
(iii) to fulfil or enforce any agreements or notices we provide and are associated with a particular Product (“Notices”);
(iv) to manage or respond to your inquiries;
(b) to develop new and enhance existing Offerings including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or notices of upgrades or updates of Offerings;
(c) to manage and develop our business and operations, for example;
(i) to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect our property;
(ii) to allow for business continuity and disaster recovery operations;
(iii) to enforce our legal rights;
(iv) for statistical purposes;
(d) to meet legal and regulatory requirements and to respond to emergency situations, for example:
(i) to respond to court orders, warrants or other lawful requests or legal processes;
(ii) to provide emergency assistance in situations that shall threaten the life or physical safety of you or others; or
(iii) for any other purposes for which you have consented, such as those that shall be set out in Notices, and other purposes as permitted or required by any applicable law.
Notwithstanding anything to the contrary contained in this Policy, we shall remove personal identifiers from your information and maintain and use it in a de-identified form that shall be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which shall include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information.
We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.
You shall update your communication preferences anytime by writing us at support@thrivemycareer.com, or within your account under account settings.
Thrive Career Wellness Inc. collects and stores personal data about its users to customize career services provided. This includes automated decision-making to promote content tailored to the preferences and interests indicated by the user, their browsing job search history, and resume data. This includes automated decision-making to provide the following services:
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we shall rely on the following legal bases to process your personal information:
Consent. We shall process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Legal Obligations. We shall process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We shall process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We shall process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we shall be legally permitted under applicable law to process your information without your consent, including, for example:
We shall need to share your personal information in the following situations:
(a) within Company and/or with our service providers like a cloud service provider for data storage;
(b) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
(c) if we have your consent;
(d) and any and all information about your access and use of the Offerings with your institution if your institution paid for your access and use of the Offerings;
(e) as necessary to complete any transactions while using our Offerings;
(f) to respond to a subpoena, order, legal process, or government request;
(g) to protect, establish or exercise our legal rights or defend against legal claims;
(h) to investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;
(i) as otherwise required by law; or
(j) if we are to be sold, merged, or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information shall be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you shall contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
(k) to help you find employment opportunities, potential employers will have access to resume content in an anonymized format;
We shall use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. When you visit the Website, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website), web beacons (also known as clear GIFs and pixel tags, which shall be used to transmit information back to the Website), and embedded scripts (programming code that is designed to collect information about your interactions with the Website, such as the links you click on, and which is active only when you are accessing the Website).
The information we collect in this manner shall include details about the computer, mobile phone, or other device used to access the Website (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.
We shall use third-party web analytics services to help us analyze how visitors use the Website. We shall permit these third parties to operate directly on the Website, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.
When you visit our Website, we shall allow third parties (such as advertising networks and data analytics companies) to collect information about your online activities over time and across different websites. Your browser settings shall allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
We shall also combine information we receive about you from third parties with information we collect through the Website.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
Thrive Career Wellness Inc. retains personal data associated with your account for the lifetime of your account. Your account will become deactivated once your access to a Thrive Career Wellness Inc. product has ended. Following 30 days of deactivation an archive is created of your account which is used for historical, billing, and statistical purposes. The archive also allows us to provide users with their account data upon request, and restore their account if needed. If you would like to delete your personal information, you can request to have your personal information deleted at any time. It shall take several additional days for your personal data to be fully removed from recipients, depending on those recipients practices, over which Thrive Career Wellness Inc. shall have limited or no control.
We aim to provide you with a safe experience. We have in place certain physical, technological, and organizational safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.
We limit access to your personal information within the Company to individuals with a need to know.
Your personal information shall be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area which shall be outside the region in which you are situated and shall have different privacy or data protection legislation, and shall therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, by using our Offerings, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of us.
Thrive Career Wellness Inc. is based in Canada. As such we must access certain data in Canada to provide the Services - for example: To resolve support tickets we often require personal data such as email and name.
Thrive Career Wellness Inc. processes personal data in Australia, EU, Canada, and the United States. By using Thrive Career Wellness Inc. Services, you authorize Thrive Career Wellness Inc. to transfer, store, and use your information in Canada and any other country where we operate. We limit the amount of data processed outside of the users own region whenever possible.
Any enterprise agreements and policies that specify data residency will supersede this clause. If you have further questions about where your data is being stored please contact us.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we shall have collected from children under age 18, please contact us at Privacy@thrivemycareer.com.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These shall include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you shall also have the right to object to the processing of your personal information. We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which shall be expressed and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at privacy@thrivemycareer.com. You will then be removed from the marketing lists. However, we shall still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
If you have questions or comments about your privacy rights, you shall email us at privacy@thrivemycareer.com.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data shall not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information. What categories of personal information do we collect?
We shall also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
Please reach out to your account manager to submit any privacy inquiries, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we shall deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We shall disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We shall use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.
Thrive Career Wellness Inc has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Thrive Career Wellness Inc will not sell personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that shall be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights. Verification process
Upon receiving your request, we will need to verify your identity to determine if you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we shall ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we shall contact you through a communication method (e.g., phone or email) that you have previously provided to us. We shall also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we shall request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
You shall object to the processing of your personal information.
You shall request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We shall deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You shall request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us. Please reach out to your account manager to submit any privacy inquiries, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
13. DO WE MAKE UPDATES TO THIS NOTICE?
We shall update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we shall notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you shall email us at privacy@thrivemycareer.com.
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you shall have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to privacy@thrivemycareer.com.
16. Questions and Comments
If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by clicking Contact Us or visiting https://support.thrivemycareer.com/or by delivery in person, by courier or by mail, to us at 201-100 Front St E, Toronto, ON M5A 1E1 Canada Canada attn.: Thrive Career Wellness Inc., or by calling us at 905-928-7061. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we shall refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
