Privacy Policy

North America Privacy Policy

Last Updated: January 2023

KeyFitConnect LLC (“Company,” “we,” “our,” or “us”) takes your privacy seriously. We want you to know how we collect, use, disclose, and protect your Personal Information and about the rights of all consumers in North America which includes, the United States and Canada, and the specific rights according to enacted Privacy Legislation:

This Privacy Policy addresses the following topics:

· The Scope of this Privacy Policy

· The Company’s Collection, Use and Disclosure of Personal Information

· Your Privacy Rights

· How to Exercise Your Rights

· Requests by Authorized Agents

· How We Will Verify Your Requests

· The Company’s Non-Discrimination Policy

· For California Residents, Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes

· For California Residents, Your “Do Not Track” Browser Setting

· Links to External tools and Resources

· Minors Under 13 Years of Age

· For More Information

· Changes to This North American Privacy Policy

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at info@keyfitconnect.com for assistance.

The Scope of this Privacy Policy

What Is Personal Information?

Personal data is information that whether alone, or combined, allows you to be identified directly, or indirectly. Common personal data identifiers are attributes like your name, online identifier, or ID number. However, a combination of one or more elements specific to your physical, physiological, genetic, psychological, economic, cultural, or social identity will also be classed as your personal data/personal information, given their potential to identify you when combined.

Some personal data types are considered more sensitive than others and the definition of sensitive data varies by local law. Across several major privacy laws, sensitive data examples include health and financial data, ethnic and racial origins, political opinions, genetic and biometric data, an individual’s sex life or sexual orientation, religious/philosophical beliefs, trade union membership, precise geolocation and/or government identifiers.

Personal Information We Collect

Depending on systems, platforms used and programs you interact with, we will process some or all of the following information:

· First and last name

· Preferred name

· Platform password

· Email address

· Alternative email address

· Contact phone number

· Street address

· City/nearest city of residence

· Country

· Your career transition objectives, for example industries of interest, areas you require support e.g. resume guidance

· Cookie data collected via cookies essential for the operation of the platform, consistent with our Cookie Notice

· Cookie data collected via any non-strictly necessary cookies you explicitly consent to via the cookie banner on the platform, consistent with our Cookie Notice

· Your interaction with the site, including usage of the career management tools

· Name of your employer/former employer organization

· Learning and Development courses taken, scheduled or interacted with

· Your assessment results

· User IP address and your Service Provider IP address

· CV/Resume data, which may include contact details, social media URL, employment history, education history, professional memberships qualifications, knowledge, skills, abilities, languages, licenses held, depending on the information in your CV/Resume

· Recording of any interview practice you decide to record which will not be used for any purpose other than supporting you with interview techniques.

How We Use The Information We Collect

We do not, and will not, sell your personal data. We will never use the information you provide us for cross-contextual advertising. We will use the personal data you provide us with to deliver, evaluate and, where necessary, enhance the services you are eligible for, as permitted under the privacy laws applicable to you.

All processing will be carried out based on adequate legal grounds, including:

1. Consent from you i.e., when you tick a box to give permission based on your understanding of the nature of the processing.

2. Legitimate business purpose, for example, to enhance, modify, personalize, or otherwise improve our services.

When we use personal data, we ensure it is minimized to what is necessary to achieve the intended result. As you use Company some services, we will use some or all of your data, or a portion of your data to:

A. Create and manage accounts where you can edit your profile and adjust the optional information you have disclosed with us at any time.

B. Provide you with access to the relevant Career Management or Career Transition tools, based on your program eligibility.

C. Enable you to create, enhance, update or modify your CV/Resume.

D. Assist you in your job search and present you with potential job matches, by means of artificial intelligence technology.

E. Allow you to gain interview practice and provide you with feedback on your interview techniques, should you choose to disclose your practice recording with your career consultant.

F. Support you in your personal development by providing access to personality/ behavioral/ career management assessments. If you have been assigned a career consultant, you can choose whether you disclose the results of your assessment with your consultant who may help you determine potential career or development opportunities.

G. Contact you with helpful platform notifications and reminders, to the extent you agree to receive such notifications via the communication settings made available to you in your profile.

H. Respond to your enquiries and requests for assistance.

I. Provide you with upskilling and reskilling learning and development content, by means of artificial intelligence technology.

J. Optimize your user experience and to better tailor our offer to you, we may use Cookies and similar technology, where permitted under law and consistent with our Cookie Notice.

We will also process your personal data for other legitimate business purposes which may include:

A. Performing data analytics, such as analyzing platform usage across our users, determining the effectiveness of our engagement strategy, determining the effectiveness of our products and services.

B. Operating, evaluating, and improving our business (including developing, enhancing, analyzing, and improving our services)

C. Enhancing, modify, personalizing, or otherwise improving our services for the benefit of our customers.

D. Auditing our interactions, transitions, accounting, and other internal compliance functions.

E. Protecting against, identifying, and seeking to prevent fraud, deceptive practices, and other unlawful activity, claims and other liabilities.

F. Complying with and enforcing applicable legal requirements, exercise or defense of legal claims, relevant industry standards, contractual obligations, and our policies.

G. To enhance security of our network and information systems

H. Creating aggregated data (client reporting etc.)

Whenever we process data for our business purposes, we will ensure that we keep your rights in high regard and take account of these rights. You have the right to object to such processing; please see the section How to Exercise Your Privacy Rights for information on how to do this.

Artificial Intelligence (AI) / Machine Learning (ML)

Job Search

Some Job Search functionality provided on Company platforms apply AI and ML technology to identify, extract and structure information coming from the text of the CV/resume you upload and use to create your job search profile. A limited set of CVs/Resumes are used to train and evaluate the AI parsing algorithms annually, to ensure a service offering that is accurate and free from bias.

The search and match component uses the structured data from the job profile you have created to perform queries, create search queries, and rank results. The search and match component is not AI powered and is not trained on user behavior or other signals for machine ‘self-learning’. The search and match component is a transparent normalized search engine that does not learn from user interactions or other user data. The only ML algorithms used in the search and match offering are for the purpose of effective parsing and making the search facility more robust and relevant for users.

No automated decisions are made via Job Search functions that produce any legal or similarly significant effects on you. The job search functions are just one of the numerous ways you can approach the job market to search for opportunities.

How We Protect Personal Data

We maintain technical and organizational measures designed to protect the personal data we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Such measures are designed to provide a reasonable and appropriate level of security taking account, on one hand, the technical state of the art and, on the other hand, the sensitivity of the personal data and the evaluation of potential risks.

To provide reasonable and appropriate security and confidentiality of personal data, we apply to the following non-exhaustive list of measures:

· Encryption of data at rest and in transit using industry standard encryption algorithms with appropriate key lengths.

· Strong user authentication and role-based access controls.

· Network monitoring solutions with events logging.

· Hardened network infrastructure.

· Measures for ensuring physical security of locations at which personal data are processed.

· Business continuity and disaster recovery plans with periodic testing.

· Incident management policy and processes.

· Periodic vulnerability and penetration testing.

· Certification/assurance of processes and products.

· Periodic employee privacy and security training and awareness program.

· Third party privacy and security assessments.

· Robust data processing and confidentiality agreements.

· Organizational measures for ensuring data minimization, purpose limitation, retention, data quality and accountability.

How We May Disclose Your Personal Information

We do not disclose personal data that we collect about you, except as described in this privacy notice or in separate notices provided in connection with particular activities. We will not “share” (i.e., disclose to a third party for cross-context behavioral advertising) your personal information.

We may disclose a portion of your personal data with vendors who perform services on our behalf based on our instructions to make the services available to you. We strive to minimize this disclosure to what is necessary to perform the specific services instructed. We conduct vendor due diligence to assess their privacy and security measures for protecting your data. We also enter data processing agreements with vendors, with appropriate requirements stipulating the technical and organizational measure we require them to comply with when handling your personal data.

We also may disclose a portion of your personal data to our subsidiaries and affiliated KeyFitConnect LLC companies for administrative, legal or compliance purposes; where this is the case, we will ensure that there are appropriate safeguards for the protection of your data.

In addition, we may disclose personal data about you on the following basis:

1. If we are required to do so by law or legal process.

2. To law enforcement authorities or other government officials based on a lawful disclosure request.

3. When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; and,

4. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Links To External Tools and Resources

We may provide links to external third-party websites operated by organizations not affiliated with KeyFitConnect LLC. We do not disclose your personal information to organizations operating such linked third-party websites and we do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each website that you visit. This privacy notice applies solely to information collected by KeyFitConnect LLC and its subsidiaries and affiliates through the services provided or performed.

Whose Personal Information Is Covered By This Policy?

This Privacy Policy applies to North American residents Personal Information of Consumers that we collect both online and offline, including through Consumers’ (a) visits to our websites, and (b) use of our applications or services that reference this Privacy Policy (collectively, the “Services”).

· California residents who are employees or other agents of a business engaged in a transaction with Company in their capacities as employees or agents of that business.

What Personal Information Does This Privacy Policy Cover?

This Privacy Policy applies to North American residents Personal Information, California Employee data, of Consumers that we collect both online and offline, including through Consumers’ (a) visits to our websites, and (b) use of our applications or services that reference this Privacy Policy (collectively, the “Services”).

Whose Personal Information Is Not Covered By This Privacy Policy?

All state residents, excluding California, who are Company’s employees, job applicants, directors, officers, or contract workers (collectively, “HR Individuals”), or the emergency contacts of HR Individuals or the dependents or spouses who receive Company benefits by virtue of their relationship to an HR Individual in their capacities as HR Individuals or emergency contacts, dependents, or spouses.

The Company’s Collection, Use and Disclosure of Personal Information

Categories Of Personal Information Collected

In the last 12 months, Company collected the following categories of Personal Information about Consumers:

· Identifiers, including: full name; address; email address; telephone number; IP address; and account username.

· Non-Public Education Information, including: education level and CV/resume information.

· Characteristics of Protected Classifications Under State, Federal and Country Law, including: gender and age.

· Professional or Employment-Related Information including: CV/resume information and employer information.

· Commercial Information, including: services obtained or considered.

· Sensory Information, including: video surveillance of branch locations.

· Internet Or Other Electronic Network Activity Information, including: pages visited on Company’s websites and links clicked; IP address; location information; browser and device data; and language preferences.

· Profile Information, including: results of self-assessment questionnaires and inferences drawn from the categories of Personal Information listed above to create a profile reflecting a Consumer’s preferences.

Purposes For Using Personal Information Collected

In the last 12 months, Company used the categories of Personal Information listed above for the following purposes:

Categories of Personal Information:

· Identifiers

· Non-Public Education Information

· Characteristics of Protected Classifications Under California or Federal Law

· Professional or Employment-Related Information

· Commercial Information

· Sensory Information

· Internet or Other Electronic Network Activity Information

· Profile Information

Purpose For Which Information Is Used:

· To Provide Our Services

Categories of Personal Information:

· Identifiers

· Commercial Information

· Sensory Information

· Profile Information

Purpose For Which Information Is Used:

· To Communicate With Current And Prospective Recipients Of Our Services About Our Services And Promotions

Categories of Personal Information:

· Identifiers

· Internet Or Other Electronic Network Activity Information

· Sensory Information

Purpose For Which Information Is Used:

· To Protect Against Malicious, Deceptive, Fraudulent, Or Illegal Activity

Categories of Personal Information:

· Identifiers

· Characteristics of Protected Classifications Under California or Federal Law

· Commercial Information

· Sensory Information

· Internet or Other Electronic Network Activity Information

Purpose For Which Information Is Used:

· To Audit Company’s Interactions, Transactions, And Legal Compliance

Categories of Personal Information:

· Commercial Information

· Internet or Other Electronic Network Activity Information

Purpose For Which Information Is Used:

· To Undertake Internal Research For Technological Development And Demonstration

Categories of Personal Information:

· Identifiers

· Internet or Other Electronic Network Activity Information

· Characteristics of Protected Classifications Under California or Federal Law

· Commercial Information

· Sensory Information

· Profile Information

Purpose For Which Information Is Used:

· To Undertake Activities To Verify Or Maintain The Quality Or Safety Of Our Services, And To Improve, Upgrade, Or Enhance Our Services

Categories of Personal Information:

· Commercial Information

· Sensory Information

Purpose For Which Information Is Used:

· For Service Training

Categories of Personal Information:

· Identifiers

· Payment Information

· Product or Service Usage Information

· Commercial Information

· Sensory Information

· Internet or Other Electronic Network Activity Information

· Profile Information

Purpose For Which Information Is Used:

· Short-term, Transient Use

Sources Of Personal Information Collected

In the last 12 months, Company collected the following categories of Personal Information about Consumers from the following sources:

· Directly From Consumers: (a) Identifiers; (b) Characteristics of Protected Classifications Under California or Federal Law; (c) Commercial Information; (d) Sensory Information; (e) Professional or Employment-Related Information; (f) Non-Public Education Information; (g) Profile Information.

· Data Collection Technologies (described above): Internet Or Other Electronic Network Activity Information.

Disclosure Of Personal Information To Third Parties

In the last 12 months, Company may have disclosed the following categories of Personal Information about Consumers to the following categories of third parties for a business, commercial or legal purpose:

Category of Personal Information:

· All Categories of Personal Information Collected

Category of Third Party: 

· Government agencies, law enforcement, and other parties as required by law, including in litigation.

Category of Personal Information:

· Internet or Other Electronic Network Activity Information

Category of Third Party:

· Service Providers, including providers of Data Collection Technologies, providers of data analytics services, and website providers.

· Third-party advertising networks

Right to Know

Consumers have the right to submit a verifiable request to know:

· The categories and specific pieces of Personal Information that Company has collected about them.

· The categories of sources from which Company collected the Personal Information.

· The categories of Personal Information that Company sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information.

· The business or commercial purposes for Company’s collection, disclosure, or sale of the Personal Information.

Right To Delete

· Consumers have the right to submit a verifiable request for deletion of their Personal Information that the Company has collected from the Consumer.

Right to Correct

· Consumers have the right to submit a verifiable request for correction of inaccurate Personal Information collected from or about them.

Right to Non-Discriminated

· The Company cannot deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the California Privacy Rights Act.

· However, if you refuse to provide your personal information to the Company or ask it to delete your personal information, and that personal information is necessary for the Company to provide you with goods or services, the Company may not be able to complete that transaction.

How to Exercise Your Rights

The Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request and validate the request itself. Consumers can exercise their rights in the following ways:

· Complete the “Online Request Form” to create a new Consumer Request.

· Contact by telephone: 206-973-7227 for assistance with the Online Request Form.

Requests by Authorized Agents

You may designate an authorized agent to exercise your right to know, your right to delete and right to correct by submitting to us a completed “Authorized Agent Designation” form. You can obtain the designation form by emailing a request to: info@keyfitconnect.com

If an authorized agent submits a request on your behalf, the authorized agent must submit with the request a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity.

How We Will Verify Your Requests

The processes that we follow to provide access to our “Secure Online Portal” and verify the identity of the person making a request to know, update or delete data about whom we have collected personal information are described below.

All consumer requests require multiple verifications to confirm both the email of the consumer making the requests and the “Secure Online Portal’ access requested.

For each new request via our “Online Request Form“, a consumer will receive an email requesting confirmation of their email address to enable access to our “Secure Online Portal”. Once the “Secure Online Portal” is accessed, we will require that you re-authenticate yourself by completing a “Request an Access Code” process and entering the code sent to enable access to the “Secure Online Portal” and two-way communication with the KeyFitConnect Team.

You are responsible for protecting the security of your credentials and codes for the “Secure Online Portal” so please do not share your access credentials or codes with anyone. If we suspect fraudulent or malicious activity on or from your account, we will not respond to any request until we have been able to confirm, through further verification procedures, that you made the request.

As an additional access point, a phone number is available for any assistance you may need in making your request via the “Online request Form” and “Secure Online Portal”

All Consumer Requests require verification of a consumer’s identity to confirm they are who they say they are and additional documentation if you are submitting requests on behalf of someone else.

Under Privacy Legislation, a business is only required to respond to requests that are “Verifiable Consumer Requests”. A verifiable consumer request is defined as a request that is made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the Country of Origin or Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that the business can reasonably verify to be the consumer about whom the business has collected personal identifiable information.

· All Consumer Requests for Personal Information:

• Consumer will need to provide one of the following to verify their personal identity: Scanned Driver License, Birth Certificate or a Utility Bill. A Passport can be used but will require additional address verification documentation when making a request for themselves.
• Consumer will additionally need to provide a scanned Power-Of-Attorney if the consumer request is on behalf of someone else for any reason.

· All Consumer Update Requests To Personal Information also require:

•  Consumer will additionally need to provide proof of the changes requested.

We have implemented the following additional procedures when verifying the identity of Consumers making requests:

   1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process. We will not use that information for any purpose other than verification.

   2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity and process your request.

Annual User Rights Request Metrics

The CCPA/CPRA requires certain businesses to compile and disclose metrics on an annual basis regarding their compliance with the CCPA and consumer rights requests. The metrics must be posted by July 1 of each year. KeyFitConnect LLC. has elected to report the required metrics on a calendar year basis for the period of January 1, 2022 through December 31, 2022. During the previous calendar year, KeyFitConnect LLC. facilitated the following requests from California residents who submitted requests via our secure online portal:

California Consumer Requests

Total Requests to Know 0

The Company’s Non-Discrimination Policy

Consumers have the right not to be subject to discriminatory treatment by Company for exercising their privacy rights under applicable Privacy legislation, and Company will not discriminate on that basis. However, Company may charge a California Consumer a different price or rate or provide a different level or quality of goods or services if the difference is reasonably related to the value provided to the Consumer by the Consumer’s Personal Information. If Company does so, it will provide Consumers with any legally required notice.

For California Residents, Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes

Under applicable Privacy legislation, Consumers can request information from us about whether we have disclosed Personal Information to any third parties for the third parties' direct marketing purposes. We will not sell your Personal Information to, or disclose it with, third-party companies for their direct marketing purposes without your consent. Consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.

For California Residents, Your ‘Do Not Track’ Browser Setting

The Company’s websites collect personally identifiable information about your online activities over time and across third-party websites or online services. Through Company’s advertising networks, other parties may also collect personally identifiable information about an individual’s online activities over time and across different websites when an individual uses Company’s website. Company’s websites do not support the Do Not Track browser setting.

Links to External Tools and Resources

We may provide links to external third-party websites operated by organizations not affiliated with KeyFitConnect LLC. We do not disclose your personal information to organizations operating such linked third-party websites and we do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each website that you visit. This privacy notice applies solely to information collected by KeyFitConnect LLC. and its subsidiaries and affiliates through the services provided or performed.

Minors Under 13 Years of Age

We respect the privacy of children. Our Services are not designed to attract an audience younger than thirteen (13), and we do not knowingly collect Personal Information from children under thirteen (13). If you are under the age of thirteen (13), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected information from your child under the age of thirteen (13), and we will work to delete it.

For More Information

For questions or concerns about Company’s privacy policies and practices, please email: info@keyfitconnect.com

Changes to This North American Privacy Policy

From time to time, we may modify this North American Privacy Policy to accommodate new technology, industry practices, regulatory requirements, or for other purposes. If we make material changes to this North American Privacy Policy that would impact your continued use of our Services, we will make reasonable efforts to notify you of such changes (including through email, push message, and/or by posting a notice directly to your account), and may also ask you to affirmatively consent to the changes at the time of your next login to the Services. By continuing to use the services after such notice and/or consent, you agree to the terms of the North American Privacy Policy as modified. If you do not agree with our changes to the North American Privacy Policy, your sole and exclusive remedy will be to discontinue use of the Services and this website.

By using this website, you consent to the real-time collection, storage, use and disclosure of information on your device, or provided by you, (such as mouse movements and clicks) for KeyFitConnect LLC and/or its third-party providers.