Privacy Policy

Updated 01/22/2021

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 may 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.careerjsm.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 may also decide to send you a notice in other ways in 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 changed or notice of the change has been given, you will be deemed to have accepted such changes.

1 Information We Collect

We collect the following types of information:

(a) Account information: When you use our Offerings you need to create an account with us. In order to create an account, you will need to provide us with login credentials (which include your username and password), your name, email address, institution you attend or are enrolled at, degree, concentration, start date at institution, and graduation date from institution.

(b) General usage data: When you use our Offerings we may collect technical properties of hardware and software utilized in conjunction with our Offerings. For example, we may 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 may 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..

(c) Third party information: If necessary to fulfill our identified purposes, we may combine the information you submit to us with information obtained from other sources or third party offerings. For example, we may 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, may 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 GetAJob service provider.

(d) Quality assurance and customer service: Your customer service emails to us and our service providers, if any, may 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.

(e) Cookies: In addition, when you visit our Website, we collect certain information about your activity on our Website, as described below under the heading “Our use of Cookies and Log Files”.

Some of this information would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. 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.

2 Our Use of Information We Collect

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, trouble shooting, 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 fulfill 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 may 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 may 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 may remove personal identifiers from your information and maintain and use it in a de-identified form that may 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 may 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 may update your communication preferences anytime by writing us at support@careerjsm.com, or within your account under account settings.

3 To whom we Disclose your Personal Information

In accordance with this Policy, we may share your personal information:

(a) within Company and/or with our service providers like a cloud service provider for data storage;

(i) for non-EU & non-Australian Thrive Users (thrivemycareer.com.au) personal data is encrypted and stored at rest in Canada;

(ii) for EU Users personal data is encrypted and stored at rest in the EU as per our GDPR Policy;

(iii) for Australian Thrive Users (thrivemycareer.com.au) personal data is encrypted and stored at rest in Australia as per our GDPR Policy;

(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 may 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 may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

4 Your Decisions About Your Personal Information

At any time you can contact us at 201-100 Front St E, Toronto, ON M5A 1E1 Canada Attn: Thrive Career Wellness Inc. to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information (which can also be done by you directly by editing your account information online). You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us.

If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. 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.

Generally, you may withdraw at any time your consent for us to use and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to use your personal information as may be required to provide you with our Offerings, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent to use and disclose this information, we may no longer be able to provide you with our Offerings.

5 Our Use of Cookies, Log Files, Web Beacons, and Embedded Scripts

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 may 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 may 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 may use third-party web analytics services to help us analyze how visitors use the Website. We may 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 may allow some 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 may 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.

In some instances, we may also combine information we receive about you from third parties with information we collect through the Website.

6 Security

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 may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may 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.

7 Links to Other Sites

We provide links on our Website to third party sites we think you will enjoy. These sites operate independently of us and may have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is subject to that third party’s privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

8 Children’s Online Privacy Protection

The Website and Offerings are not intended for use by children under 18 years of age. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.

9 California Residents – Your California Privacy Rights

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request by email to support@careerjsm.com or write to us at 201-100 Front St E, Toronto, ON M5A 1E1 Canada Canada Attn: Thrive Career Wellness Inc. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

10 Questions or 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://thrivemycareer.freshdesk.com or by delivery in person, by courier or by the 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 may 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).