Notice at Collection and Privacy Notice for California Residents
Last updated: January 17, 2024
This Notice at Collection and Privacy Notice for California Residents (“Notice”) supplements the information in the general Privacy Policy posted on our website at horizontaltalent.com and applies solely to “consumers” as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”). This Notice is limited to our activities when we are acting as a business, as defined by the CCPA.
In simply accessing our website, the following applies. If you register to use our Services, please continue reading below to learn more about the personal information we collect, and how we use and disclose such information.
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Categories of personal information about consumers to be collected. * ** *No sensitive personal information about consumers is to be collected. ** None of the information described is sold. |
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The business purposes for which the above categories of personal information are collected and used. |
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The criteria used by Horizontal Talent to determine the period of time such personal information will be retained. |
Horizontal Talent will retain the personal information it collects and uses so long as it has a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is the longer. |
Horizontal Talent has “shared” the following categories of personal information to various marketing and advertising vendors for the purposes of serving you with targeted advertisements, either on behalf of us or third parties.
- Identifiers: IP address, online identifier
- Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, information on a consumer’s interaction with the Horizontal Talent platform.
This information was shared with the applicable third parties through the use of automatic tracking technologies deployed on our website. To opt out of sharing of such information, please update your preferences by clicking the cookie button displayed on each page.
To learn more about our online and offline practices in connection with the collection, processing, and disclosure of personal information relating to California consumers, including those who register to use our Services, continue to read below.
Information We Collect and Disclose
As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information certain regulated information or public information.
In the past 12 months, Horizontal Talent has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.
- IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants
- If you are submitting this information as a user of our Services, other users of our Horizontal Talent Platform (e.g., candidate profile information being made available to employer users)
| Categories of PI Collected | Examples | Categories of Third Parties to Whom Disclosed |
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Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account username and password, or other similar identifiers. |
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Commercial information |
Records of products purchased, obtained, or considered by your organization, or other purchase histories, customer services inquiries, requests, and communications. |
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Internet or other similar network activity |
Browsing history, search history, information on a consumer’s interaction with a website, information on a consumer’s interaction with the Horizontal Talent platform. |
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Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
A name, signature, address, telephone number, or employment information. Some personal information included in this category may overlap with other categories. |
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Sensory data |
Voicemail or similar audio recordings. |
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Characteristics of protected classifications under California or federal law |
Gender, race/ethnicity. |
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Professional or employment-related information
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The details typically found on a resume, such as job history, certifications and education, other relevant credentials or extra-curricular activities. |
From time to time, Horizontal Talent may be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process. We may also disclose your personal information to third parties in connection with the sale of our business or assets, or any merger or similar corporate matter, when your personal information is part of the assets involved in such transaction.
Applicable Retention Periods
For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this Notice. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.
Categories of Sources of Personal Information
Horizontal Talent collects these categories of personal information from the following categories of sources:
- Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, using our Services, engaging in transactions with us, signing up to receive promotional or information communications from us, communicating with us about our services, or otherwise directly providing the information to us.
- Indirect and technology-based collection: We also collect certain information from you automatically when you visit, use, or navigate our website. Horizontal Talent collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in our website privacy policy.
- Collection via social media: We may collect personal information about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number, if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.
- Third-party collection: From time-to-time, we may obtain marketing or lead lists from third party vendors. We use these, for example, to send you marketing communications.
Business or Commercial Purposes for Collecting and Disclosing Personal Information
We collect and disclose the personal information described above for the following business or commercial purposes (as well as any other purposes as set forth in our Privacy Policy):
- Providing and optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner, including within the Horizontal Talent platform.
- Providing you with our products and services, including access to our Horizontal Talent platform, as well as any reasonable customer support services.
- Fulfilling transactions with you or your organization, processing payments, and managing the transaction process.
- Communicating with you and responding to your inquiries about our Services, including to provide you with promotional and informational communications regarding our products and services, informing you about new services, updating you about changes to our website, and investigating any concerns you have about our services or your transactions.
- Developing, updating, and improving our products/services, customer service, customer experience, and marketing efforts, and otherwise improving our knowledge and insights regarding customers.
- Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the website or purchase and use of our Services.
- Enforcing our agreements with customers and complying with our legal or regulatory obligations.
- Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
Sensitive Personal Information
Horizontal Talent does not use or disclose “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, Horizontal Talent treats any such information as “personal information” consistent with applicable provisions of the CCPA.
Sale or Sharing of Personal Information
In the past 12 months, Horizontal Talent has not sold any categories of personal information, as those terms are defined by the CCPA.
In the past 12 months, Horizontal Talent has “shared” the following categories of personal information to various marketing and advertising vendors for the purposes of serving you with targeted advertisements, either on behalf of us or third parties.
- Identifiers: IP address, online identifier
- Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, information on a consumer’s interaction with the Horizontal Talent platform.
Because the information we collect from you and share with third parties is done so via the use of automatic tracking technologies deployed on our website, you can request to opt-out of the sharing of your personal information by updating your preferences within the provided cookie banner.
Horizontal Talent does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.
Your Rights Under the CCPA
Subject to exceptions, the CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.
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Right to Know. You have the right to request that we provide you certain information about our collection and use of your personal information during the past twelve (12) months (or longer, as permitted by the CCPA). Specifically, you may request that we disclose (in whole or part):
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- The business and commercial purposes for collecting (or selling or sharing, if applicable) your personal information;
- The categories of third parties to whom we disclose (or sell or share, if applicable) your personal information;
- The specific pieces of personal information we collected about you;
- If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party; and
- If applicable, the categories of personal information that we sold, and for each category, the categories of third parties whom such information was sold.
As noted above, you have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.
- Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
- Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
- Right to Opt-Out of Sharing. You have the right to request that we opt you out of the sharing of your personal information for the purposes of cross-context behavioral advertising.
Consumers in California also have the right to opt-out of the sale of personal information, (as defined in the CCPA). California consumers also have the right to limit the use or disclosure of sensitive personal information by the business if such information is used or disclosed for certain purposes, as required by the CCPA. Because Horizontal Talent does not engage in any of the foregoing activities, these rights are not available.
Exercising Your Right to Know, Request Deletion, or Correct Inaccurate Information
To exercise the rights described above, you or someone authorized to act on your behalf must submit a verifiable consumer request to us by sending an e-mail to: verify@horizontal.com with the subject line: “CCPA Request” or calling us at (888) 242-6907. Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.
You may only make a verifiable consumer request to know twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.
The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know specific pieces of information collected about you, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.
Exercising Your Right to Opt-Out of Sharing
You can request to opt-out of the sharing of your personal information by updating your preferences within the cookie banner or calling us at (888) 242-6907. The CCPA requires us to comply with a consumer request to opt out of sharing as soon as feasibly possible, but no later than fifteen (15) business days from the date the request is received. No verification is required; however, we may deny a request to opt-out of sharing if we have a good-faith, reasonable, and documented belief that the request is fraudulent. In the event we deny a request for this reason, we will inform the consumer that we are not complying with the request and provide an explanation of why we believe the request is fraudulent.
Requests may be made using an authorized agent, if the consumer provides the agent with written permission signed by the consumer to act on the consumer’s behalf. We may deny a request if the applicable agent does not submit proof that it has been authorized by the consumer to act on the consumer’s behalf.
Once a consumer makes an opt out request, we will honor such request for at least twelve (12) months before asking the consumer to reauthorize personal information sales or sharing.
Additionally, if a consumer initiates a transaction or attempts to use a product or service that requires the sharing of the consumer’s personal information, we may inform the consumer that the transaction, product or service requires the sale or sharing of the consumer’s personal information and provide the consumer instructions on how to opt in to sharing.
Our Commitment Not to Discriminate
Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to this Notice
We reserve the right to amend this Notice at our discretion and at any time. If there are changes to this Notice, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this page periodically for updates.
Data Disclosures for Direct Marketing Purposes
California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.
Contact Information
If you have any questions or comments about this Notice, please contact us using the following information.
Phone: (888) 242-6907
Email: talent@horizontal.com
Horizontal Talent
Attn: Rachel Enstrom
1660 Hwy 100 South, Suite 200
St. Louis Park, MN 55416
United States