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TRANSPARENTBUSINESS GROUP PRIVACY POLICY
TransparentBusiness Group Privacy Policy (“Privacy Policy”) is effective as of March 29, 2021. Please note that this Privacy Policy will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
This Privacy Policy tells you everything you need to know about how TransparentBusiness Inc., Yandiki Inc., Sheworks Inc., Unicorns Inc., and/or its affiliates, subsidiaries and newly acquired companies (indistinctively “TransparentBusiness” or “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”) and which rights you have in relation to the processing of your personal data.
However, if you are a California resident, please see our specific California-Residents Privacy Policy (“California Privacy Policy”) in this link. If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act (“CCPA”).
It is of great importance to TransparentBusiness, your right to privacy, and the protection of your personal data. We want you to trust that your personal data is secure, and it is in good hands when you deal with TransparentBusiness.
TransparentBusiness protects your personal data in accordance with applicable laws and our Privacy Policy. In addition, TransparentBusiness maintains the best technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access, or accidental or unlawful destruction of or damage thereto.
The personal data collected comes from, but is not limited to, our employees, potential employees, clients, suppliers, business contacts, partners, ambassadors, shareholders, and website users (the “individuals). If the data we collect is not listed in this Privacy Policy, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used. However, all individuals shall be deemed to have accepted this Privacy Policy by using or entering any of the TransparentBusiness websites.
The personal data we collect includes the categories of personal data referred to in this Privacy Policy or in other statements you have received.
If we learn that any information, we collect has been provided by a child under the age of 13, we will promptly delete that information.
Below is also a chart describing the categories of personal data we collect:
GENERAL CATEGORIES | |
Category of personal information | Types of personal information captured by category |
Personal details, contact details, and identifiers. | Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth. |
Commercial information. | History and records of the services and softwares you have obtained from TransparentBusiness. |
Marketing and research information |
|
Sensitive data and biometric information. | TransparentBusiness may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication. |
Audiovisual materials. | Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions). |
Position and professional or employment-related information. | Professional or employment-related information, such as description of current position, job title, employer, location, and TransparentBusiness contact(s). |
System and application access data and Internet and electronic network activity information. | Where you are provided with access to TransparentBusiness’ systems, TransparentBusiness may collect information required to access such TransparentBusiness systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using TransparentBusiness systems. |
Cookies and geolocation data | As described below, we also may collect geolocation data in some circumstances. Please see our Cookies Policy for more details regarding our use of cookies. |
In addition, for recruitment/employment and vendor selection purposes, TransparentBusiness may process the personal information set out in the below table.
RECRUITMENT/EMPLOYMENT/VENDOR SELECTION CATEGORIES | |
Category of personal information | Types of personal information captured by category |
Additional personal details, contact details and identifiers. | In addition to the personal details listed above, TransparentBusiness may collect additional personal details such as, but not limited to, national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history. |
Education information and professional or employment-related information. | TransparentBusiness may collect information about your education and professional or employment-related information, such as your employment history. |
Sensitive data for recruitment purposes. | TransparentBusiness may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. TransparentBusiness collects this information for specific purposes, such as health/medical information to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination. |
Documentation required under immigration laws. | TransparentBusiness may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy). |
Financial information for payroll/benefits purposes | Your banking, tax (when applicable), and other relevant financial details we need for payroll/benefits purposes. |
Talent management information. | Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance, and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies. |
Requested recruitment information | Information requested to provide during the recruitment process, to the extent allowed by applicable law. |
Recruitment information you submit | Information that you submit in résumés/CVs, letters, writing samples, or other written materials (including photographs). |
Information generated by us during recruitment | Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law. |
Recruitment information received from third parties | Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable. |
Audiovisual information processed during recruitment | Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured during recruitment events or video recruitment interviews. |
Recommendations | Recommendations related information provided on your behalf by others. |
Employment history and background checks | Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings. |
Diversity related information | Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the TransparentBusiness workforce, subject to legal limits. |
Assessment information | Information generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them. |
We also may derive inferences about you based on the information described above and collect other information about you as described in this Privacy Policy.
If you provide us with personal information of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this Privacy Policy and that the person has given you his/her consent for sharing the information with TransparentBusiness.
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to be contacted, register as a user or become a partner) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, and vendors. Except where certain information is required by law or by TransparentBusiness policies (including management of an employment relationship with TransparentBusiness), your decision to provide any personal data to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Privacy Policy, and you may not be able to use certain tools and systems which require the use of such personal data.
TransparentBusiness uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which TransparentBusiness uses your personal data and (ii) an overview of the legal basis for each such purpose.
Purpose | Legal basis |
Managing our contractual and/or employment relationship with you. | Necessary for the performance of a contract to which you are a party. |
Facilitating communication with you (including in case of emergencies, and to provide you with requested information). | Justified based on our legitimate interests for ensuring proper communication and emergency handling within the organization. |
Operating and managing our business operations. | Justified based on our legitimate interests for ensuring the proper functioning of our business operations. |
Complying with legal requirements. | Necessary for the compliance with a legal obligation to which we are subject. |
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use). | Justified based on our legitimate interests of avoiding non-compliance and protecting our reputation. |
Social listening (Identifying and assessing what is being said about TransparentBusiness and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements, or other interactions on social media channels. | Justified based on of our legitimate interest of protecting our assets and our brand on social media. |
Improving the security and functioning of our website, networks, and information. | Justified based on our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure. |
Undertaking data analytics, i.e., applying analytics to business operations and data to describe, predict and improve business performance within TransparentBusiness and/or to provide a better user experience. | Justified based on our legitimate interests for ensuring the proper functioning of our business operations. |
Marketing our products and services to you | Justified based on our legitimate interests for ensuring that we can conduct and increase our business. |
Specific Recruitment/Employment/Vendor selection Purposes | Legal basis |
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available. | Justified based on TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Manage your application. | Justified based on TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Facilitate communication with you. | Justified based on TransparentBusiness’ legitimate interests of ensuring proper communication within the organization and with you. |
Perform administrative functions (e.g., reimburse you for interview-related expenses). | Justified based on TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Perform data analytics, including analysis of our applicant pool to better understand who is applying to positions at TransparentBusiness and how to attract and keep top talent. | Justified based on TransparentBusiness’ legitimate interests of ensuring that it continually improves its recruitment processes. |
In some cases, record your online interview for review by additional recruiters and hiring managers. | Justified based on TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
If you apply for a position in TransparentBusiness, we may enter you into a database to receive future mailings about TransparentBusiness positions and events. You may also receive personalized job recommendations. | Justified based on TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Transfer your contact information, education data, employment data, application information and the CV, all as supplied by you to us to our HR team in order to notify you about new positions that may be of interest to you. | Justified based on TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Administration of employee benefits | Justified based on TransparentBusiness’ legitimate interests of ensuring that our employees receive the applicable benefits. |
Perform any legally required reporting and respond to legal process. | Compliance with a legal obligation. |
Legitimate interest means that TransparentBusiness has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy internal reviews and (iv) the rights you have in relation to the processing activity.
We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to one of our privacy policies, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.
We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
We may transfer personal data to our service providers and professional advisors, public and governmental authorities, TransparentBusiness companies/affiliates or third parties in connection with TransparentBusiness’ operation of its business, including any (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and TransparentBusiness’ internal policies. TransparentBusiness may also transfer your personal data to any of its global affiliates/partners in furtherance of any visits to our TransparentBusiness locations.
For example, we may disclose personal information to third parties for other business purposes as follows:
Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.
We do not generally seek to collect sensitive data (as defined in the second below) (also known as special categories within the EEA). In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
We maintain organizational, physical, and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal data and the processing we undertake.
As a global organization with offices and operations throughout the world, personal data we collect may be transferred or be accessible internationally throughout TransparentBusiness’ global business and between its entities and affiliates.
Any such transfers throughout TransparentBusiness’ global business take place in accordance with applicable data privacy laws.
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), TransparentBusiness’ actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TransparentBusiness’ affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to TransparentBusiness first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against TransparentBusiness with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).
In addition to the information set out above, this section describes how we use personal data when you visit TransparentBusiness’ website:
TransparentBusiness collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up as a user, register as an investor or as an ambassador or provide contact information); and (2) indirectly (for example, through our website’s technology).
We may collect and process the following personal data:
Our websites may include:
We use personal data for the purposes described in section 2.2 above, as well as to provide you with information you request, process user accounts, create investor and partners profiles.
We also analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it, make it more effective and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.
In addition to the information set out above, this section describes how we use personal data for marketing purposes:
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from TransparentBusiness, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from TransparentBusiness may include additional data privacy information, as required by applicable laws.
Like most companies, TransparentBusiness uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by TransparentBusiness professionals based on their personal interactions with you.
We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this data to better assess your experience with TransparentBusiness and to perform the other activities described throughout our privacy policy.
In addition to the third parties mentioned in section 2.3. above, we may share your personal data with marketing agencies and service providers.
You can exercise your right to prevent marketing communications to you by not checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you.
You can exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by communicating to the link indicated in section “6. CONTACT” below. In such cases, we will retain minimum personal data to note that you opted out to avoid contacting you again.
In addition to the information set out above, this section describes how we use personal data in connection with content creation/production purposes.
Some TransparentBusiness entities are in the business of content production. We may process your personal data for these TV, film, marketing, advertising or other related content creation, production, and distribution activities.
The personal data that we process for production purposes include images and footage of you and may include your location at the time of filming.
If you are a member of public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.
If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.
We may also collect and process special categories of data a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.
Please send an email to [email protected] if:
LAST UPDATED: [4.20.21]
TRANSPARENTBUSINESS GROUP COOKIES POLICY
TransparentBusiness Group Cookies Policy (“Cookies Policy”) is effective as of March 29, 2021. Please note that this Cookies Policy will regularly be updated to reflect any changes in the way we handle your cookies or any changes in applicable laws.
TransparentBusiness Group Privacy Policy (“Privacy Policy”) tells you everything you need to know about how TransparentBusiness Inc., Yandiki Inc., Sheworks Inc., Unicorns Inc., and/or its affiliates, subsidiaries and newly acquired companies (indistinctively “TransparentBusiness” or “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”). This Cookies Policy together with our Privacy Policy tells you everything you need to know about how TransparentBusiness use cookies and other similar technology on its websites.
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a site and allow a site to recognize your device. Cookies managed by TransparentBusiness only are called “first party cookies” whereas cookies from third parties are called “third party cookies” as explained below.
We can place cookies and other similar technology on your device, including mobile device, in accordance with your preferences set on your web browser. Depending on your web browser settings, the following information may be collected through cookies or similar technology: your unique device identifier, mobile device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).
Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests. In addition, cookies can help us to analyze the use of our websites and online content (analytics cookies) and they can also facilitate/track the interaction on our websites and online content with social media (e.g. links to social media sites, like buttons, etc.).
Yes, we may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile, and for the other purposes described below, to the extent allowed pursuant to applicable law in certain jurisdictions.
In other cases, we can relate cookie information (including information from cookies placed via our advertisements on third party sites) with an identifiable individual. For example:
Some cookies, web beacons and other tracking and storage technologies that we use are from third party companies (third party cookies), such as, for example, Facebook, Google Analytics, Microsoft, Marketo Munchkin Tracking, Twitter, Knotch, YouTube, Instagram, Yoptima and Linkedin Analytics to provide us with web analytics and intelligence about our sites which may also be used to provide measurement services and target ads. These companies use programming code to collect information about your interaction with our sites, such as the pages you visit, the links you click on and how long you are on our sites. This code is only active while you are on an TransparentBusiness website. For more information on how these companies collect and use information on our behalf, please refer to each third-party company privacy policy.
We may also use web beacons (including conversion pixels) or other technologies for similar purposes as above and we may include these on our sites, in marketing e-mail messages or our newsletter, affiliated websites, to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor website activity. The information provided below about cookies also applies to web beacons and similar technologies. Conversion pixels are small codes located on a particular web page which are triggered when someone visits a page resulting in an increase in the conversion count.
You can adjust your cookie settings through your web browser settings. If you want to remove existing cookies from your device, you can do this using your browser options. Please bear in mind that deleting and blocking cookies may have an impact on your user experience. Information about the procedure to follow to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, not all features of the Sites may operate as intended.
You can adjust your cookie preferences by adjusting your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. The Help function within your browser should explain how to do this. Alternatively, you may visit www.allaboutcookies.org to obtain detailed information on how to prevent cookies from being set on your browser.
You may avoid web beacons by configuring your email reader program to disable the functionality that enables remote images to load and by refraining from clicking on any links in email messages.
The cookies used on TransparentBusiness sites have been categorized as per the table below. However, it is important to note that not all cookies may be used in all jurisdictions or websites. A list of the categories of cookies used on this website is set out below.
Category | Description |
Strictly Necessary cookies | These cookies are essential in order to enable you to move around the site and use its features, such as accessing secure areas of the site. Without these cookies, services you have asked for cannot be provided. |
First party analytics cookies | These cookies allow us to employ data analytics so we can measure and improve the performance of our site and provide more relevant content to you. These cookies don’t collect information that identifies a visitor down to an individual level that is available to us. These cookies are not passing personally identifiable information to any external third party other than in limited cases when we engage a service provider to act on our behalf but who is then unable to use the data for their own purposes. |
Performance and Analytics cookies | Performance cookies are generally third-party cookies from vendors we work with or who work on our behalf that collect information about your visit and use of the TransparentBusiness website, for instance which pages you visit the most often, and if you get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how the website works. Third party vendors may have access to this data and may use it to improve their overall services and offerings. While using cookies, TransparentBusiness generate analytics regarding your use of our services, to improve the services, and make our services easier to use, and more relevant, for you. |
Functionality cookies | These cookies allow a site to remember choices you make (such as your username, language, or the region you are in) and provide more enhanced, personal features. These cookies cannot track your browsing activity on other websites. They do not gather any information about you that could be used for advertising or remembering where you’ve been on the Internet outside our site. |
Advertising and social media cookies | Advertising and social media cookies (including web beacons and other tracking and storage technologies) are used to (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of the advertising campaign; (4) retargeting to TransparentBusiness websites/information and (5) understand people’s behavior after they view an advertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site and quite often they will be linked to site functionality provided by the other organization. This may impact the content and messages you see on other websites you visit. |
Please send an email to [email protected] if you have any question regarding this Cookies Policy.
LAST UPDATED: [4.20.21]
TRANSPARENTBUSINESS GROUP CALIFORNIA PRIVACY POLICY
TransparentBusiness Group California Privacy Policy (“California Privacy Policy”) is effective as of March 23rd, 2021. Please note that this California Privacy Policy will regularly be updated to reflect any changes in the way we handle your personal information or any changes in applicable laws.
This California Privacy Policy applies to California residents whose personal information is bien processed by TransparentBusiness Inc., Yandiki Inc., Sheworks Inc., Unicorns Inc., and/or its affiliates, subsidiaries and newly acquired companies (indistinctively “TransparentBusiness” or “we”). This California Privacy Policy, which is pursuant to the California Consumer Privacy Act (“CCPA”), tells you everything you need to know about how we protect the personal information we process and control relating to a California resident (“your personal information”; “your information”) and which rights you have in relation to the processing of your personal information.
If you are not a California resident, this California Privacy Policy does not apply to you. In that case, please refer to the TransparentBusiness Group Privacy Policy.
It is of great importance to TransparentBusiness, your right to privacy, and the protection of your personal data. We want you to trust that your personal data is secure when you deal with TransparentBusiness, your personal data is in good hands.
TransparentBusiness protects your personal data in accordance with applicable laws and our Privacy Policy. In addition, TransparentBusiness maintains the best technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access, or accidental or unlawful destruction of or damage thereto.
The personal data collected comes from, but is not limited to, our employees, potential employees, clients, suppliers, business contacts, partners, ambassadors, shareholders, and website users (the “individuals). If the data we collect is not listed in this Privacy Policy, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used. However, all individuals shall be deemed to have accepted this Privacy Policy by using or entering any of the TransparentBusiness websites.
The personal information we collect includes the categories of personal information referred to in this California Privacy Policy or in other statements you have received.
Below is also a chart describing the categories of personal information we collect in the context of the processing activities described in this California Privacy Policy.
GENERAL CATEGORIES | |
Category of personal information | Types of personal information captured by category |
Personal details, contact details, and identifiers. | Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth. |
Commercial information. | History and records of the services and softwares you have obtained from TransparentBusiness. |
Marketing and research information |
|
Sensitive information and biometric information. | TransparentBusiness may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication. |
Audiovisual materials. | Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions). |
Position and professional or employment-related information. | Professional or employment-related information, such as description of current position, job title, employer, location, and TransparentBusiness contact(s). |
System and application access information and Internet and electronic network activity information. | Where you are provided with access to TransparentBusiness’ systems, TransparentBusiness may collect information required to access such TransparentBusiness systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using TransparentBusiness systems. |
Cookies and geolocation information | As described below, we also may collect geolocation information in some circumstances. Please see our Cookies Policy for more details regarding our use of cookies. |
In addition, for recruitment/employment and vendor selection purposes, TransparentBusiness may process the personal information set out in the below table.
RECRUITMENT/EMPLOYMENT/VENDOR SELECTION CATEGORIES | |
Category of personal information | Types of personal information captured by category |
Additional personal details, contact details and identifiers. | In addition to the personal details listed above, TransparentBusiness may collect additional personal details such as, but not limited to, national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history. |
Education information and professional or employment-related information. | TransparentBusiness may collect information about your education and professional or employment-related information, such as your employment history. |
Sensitive information for recruitment purposes. | TransparentBusiness may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. TransparentBusiness collects this information for specific purposes, such as health/medical information to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination. |
Documentation required under immigration laws. | TransparentBusiness may collect information on citizenship, passport information, and details of residency or work permit (a physical copy and/or an electronic copy). |
Financial information for payroll/benefits purposes | Your banking, tax (when applicable), and other relevant financial details we need for payroll/benefits purposes. |
Talent management information. | Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance, and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies. |
Requested recruitment information | Information requested to provide during the recruitment process, to the extent allowed by applicable law. |
Recruitment information you submit | Information that you submit in résumés/CVs, letters, writing samples, or other written materials (including photographs). |
Information generated by us during recruitment | Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law. |
Recruitment information received from third parties | Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable. |
Audiovisual information processed during recruitment | Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured during recruitment events or video recruitment interviews. |
Recommendations | Recommendations related information provided on your behalf by others. |
Employment history and background checks | Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings. |
Diversity related information | Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the TransparentBusiness workforce, subject to legal limits. |
Assessment information | Information generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them. |
We also may derive inferences about you based on the information described above and collect other information about you as described in this California Privacy Policy.
If you provide us with personal information of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this California Privacy Policy and that the person has given you his/her consent for sharing the information with TransparentBusiness.
The above-mentioned categories of personal information have been obtained either directly from you (for example, when you provide information to be contacted, register as a user or become a partner) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, and vendors. Except where certain information is required by law or by TransparentBusiness policies (including management of an employment relationship with TransparentBusiness), your decision to provide any personal information to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this California Privacy Policy, and you may not be able to use certain tools and systems which require the use of such personal information.
TransparentBusiness uses your personal information only where required for specific purposes. Please view the table below for (i) a list of the purposes for which TransparentBusiness uses your personal information and (ii) an overview of the legal basis for each such purpose.
Purpose | Legal basis |
Managing our contractual and/or employment relationship with you. | Necessary for 1) the performance of a contract or similar arrangement to which you are a party or 2) managing your employment relationship with TransparentBusiness. |
Facilitating communication with you (including in case of emergencies, and to provide you with requested information). | Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization. |
Operating and managing our business operations. | Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations. |
Complying with legal requirements. | Necessary for the compliance with a legal obligation to which we are subject. |
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use). | Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation. |
Research in general and market research. | Justified on our legitimate interest to gain market insights and insights in business and society in general or, where required, the consent of the relevant subjects. |
Social listening (Identifying and assessing what is being said about TransparentBusiness and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.) | Justified on the basis of our legitimate interest of protecting our assets and our brand on social media |
Ethnographic videography – this is video recording of the activity of individuals in their natural environment, in order to experience, interpret and understand behavior. This may be part of a campaign or project. | Justified on the consent of the relevant subjects. |
Improving the security and functioning of our website, networks and information. | Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure. |
Undertaking information analytics, i.e. applying analytics to business operations and information to describe, predict and improve business performance within TransparentBusiness and/or to provide a better user experience. | Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations. |
Marketing our products and services to you | Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business. |
Specific Recruitment/Employment/Vendor Selection Purposes | Legal basis |
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Manage your application. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Facilitate communication with you. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring proper communication within the organization and with you. |
Perform administrative functions (e.g. reimburse you for interview-related expenses). | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Perform information analytics, including analysis of our applicant pool in order to better understand who is applying to positions at TransparentBusiness and how to attract and keep top talent. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it continually improves its recruitment processes. |
In some cases, record your online interview for review by additional recruiters and hiring managers. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
If you apply for a position in TransparentBusiness, we may enter you into a information base to receive future mailings about TransparentBusiness positions and events. You may also receive personalized job recommendations. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Transfer your contact information, education information, employment information, application information and the CV, all as supplied by you to our HR team in order to notify you about new positions that may be of interest to you. | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that it recruits the appropriate employees. |
Administration of employee benefits | Justified on the basis of TransparentBusiness’ legitimate interests of ensuring that our employees receive the applicable benefits. |
Perform any legally-required reporting and respond to legal process. | Compliance with a legal obligation. |
Legitimate interest means that TransparentBusiness has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular internal privacy reviews and (iv) the rights you have in relation to the processing activity.
We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to one of our privacy policies, doing so will be considered as providing your consent to process your personal information, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal information will not be your consent but any other applicable legal basis.
We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
We may transfer personal information to our service providers and professional advisors, public and governmental authorities, TransparentBusiness companies/affiliates or third parties in connection with TransparentBusiness’ operation of its business, including any (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal information will be given adequate protection as required by relevant information privacy laws and TransparentBusiness’ internal policies. TransparentBusiness may also transfer your personal information to any of its global affiliates/partners in furtherance of any visits to our TransparentBusiness locations.
For example, we may disclose personal information to third parties for other business purposes as follows:
Unless you are otherwise notified, any transfers of your personal information from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal information will take place in accordance with the appropriate international information transfer mechanisms and standards.
We do not generally seek to collect sensitive information (as defined in the second below) (also known as special categories within the EEA). In the limited cases where we do seek to collect such information, we will do this in accordance with information privacy law requirements and/or ask for your consent.
The term “sensitive information” refers to the various categories of personal information identified by information privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic information, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
We maintain organizational, physical, and technical security arrangements for all the personal information we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal information and the processing we undertake.
As a global organization with offices and operations throughout the world, personal information we collect may be transferred or be accessible internationally throughout TransparentBusiness’ global business and between its entities and affiliates.
Any such transfers throughout TransparentBusiness’ global business take place in accordance with the applicable information privacy laws.
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), TransparentBusiness’ actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TransparentBusiness’ affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party information providers).
We will retain your personal information only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal information are deleted after a reasonable time according to the following retention criteria:
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
In addition, you every California resident is entitled to the following rights:
If, despite our commitment and efforts to protect your personal information, you believe that your information privacy rights have been violated, we encourage and welcome individuals to come to TransparentBusiness first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against TransparentBusiness with a competent court (either in the country where you live, the country where you work or the country where you deem that information privacy law has been infringed).
In addition to the information set out above, this section describes how we use personal information when you visit TransparentBusiness’ website:
TransparentBusiness collects personal information at its websites in two ways: (1) directly (for example, when you provide personal information to sign up as a user, register as an investor or as an ambassador or provide contact information); and (2) indirectly (for example, through our website’s technology).
We may collect and process the following personal information:
Our websites may include:
We use personal information for the purposes described in section 2.2 above, as well as to provide you with information you request, process user accounts, create investor and partners profiles.
We also analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it, make it more effective and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.
In addition to the information set out above, this section describes how we use personal information for marketing purposes:
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from TransparentBusiness, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from TransparentBusiness may include additional information privacy information, as required by applicable laws.
Like most companies, TransparentBusiness uses customer relationship management (CRM) information base technology to manage and track our marketing efforts. Our CRM information base include personal information belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal information used for these purposes includes relevant business information, such as: contact information, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by TransparentBusiness professionals based on their personal interactions with you.
We may combine information from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this information to better assess your experience with TransparentBusiness and to perform the other activities described throughout our California Privacy Policy.
In addition to the third parties mentioned in section 2.3. above, we may share your personal information with marketing agencies and service providers.
You can exercise your right to prevent marketing communications to you by not checking certain boxes on the forms we use to collect your personal information, or by utilizing opt-out mechanisms in e-mails we send to you.
You can exercise the right to discontinue marketing communications to you, or to have your personal information removed from our customer relationship management (CRM) information bases at any time by communicating to the link indicated in section “6. CONTACT” below. In such cases, we will retain minimum personal information to note that you opted out to avoid contacting you again.
In addition to the information set out above, this section describes how we use personal information in connection with content creation/production purposes.
Some TransparentBusiness entities are in the business of content production. We may process your personal information for these TV, film, marketing, advertising or other related content creation, production, and distribution activities.
The personal information that we process for production purposes include images and footage of you and may include your location at the time of filming.
If you are a member of public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.
If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.
We may also collect and process special categories of information a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.
Please send an email to [email protected] if:
LAST UPDATED: [4.20.21]
Any historical returns, expected returns, or probability projections may not reflect actual future performance. These examples are extreme and rare examples of returns that have been realized. It should not be assumed that these types of results are common or that they should be expected. Investing in private companies offers the opportunity to earn a high return on your investment, but also carries significant risks, including lack of liquidity and potential loss of some or all of your investment. Past performance is no guarantee of future results. Please refer to Risks and Disclaimers to learn more about the risks associated with investing in private companies.
