Privacy Policy

Introduction

Computing Concepts Inc ("CCI", or "we") are committed to safeguarding your privacy. “Personal Information” consists of information that may directly or indirectly identify you. This Privacy Notice ("Notice") is designed to assist you in understanding how we collect, use, disclose, share, and safeguard your information, and to explain the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below.

Accessibility

We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us as described above.

About Computing Concepts Inc

Our services include:

Managed Delivery: Managed, project-based and out-sourced delivery services for IT, software engineering initiatives including packaging, development, upgrades and maintenance
Workforce Management: Permanent and contingent workforce solutions, including recruitment process outsourcing (RPO), managed service provider (MSP) solutions, and technology implementation.
Staffing, Recruiting and Search: Temporary staffing, temp-to-perm and direct placement/search of talent, including candidate recruitment, career counseling and guidance to candidates and job seekers as well as knowledge research by working with clients, candidates and job seekers to conduct research in the market regarding talent and workforce needs and dynamics.

When this Notice Applies

This Notice applies to Personal Information we collect online and offline:

through our website(s), email and related applications and content that link or refer to this Notice (including the CCI websites listed here: www.computingconceptsinc.com and CCI computer or mobile software applications (“apps”) and content made available to you) (collectively, the “Sites”);
over the phone; and
in person.

In some cases, we may provide additional data privacy notices specific to certain services, practices, or regions. Those terms are to be read in conjunction with this Notice. This Notice also applies when we are receiving services you are providing to us. This Notice does not apply to the practices of third parties that CCI does not own or control.

What Are Our Sources of Personal Information?

Our Sources of Personal Information May Include:

Information you submit to us: Where we request information from you, we will inform you prior to collection whether the provision of the Personal Information may be provided on a voluntary basis, and the consequences of not providing the information, which may include being unable to properly provide you with Services.
Information we collect automatically: We automatically collect certain technical information from you when you visit our Site(s) (for example your IP address, browser and operating system details and actions you take on the Site(s)).
Information we obtain from third parties: We may receive or acquire information about you from third parties such as:
Third party websites and services like job boards and professional network sites (for example LinkedIn) and social media platforms and websites where you post information;
Clients (for example for our search services a client may provide current or prospective candidates for us to consider for a job they have asked us to fill); Business intelligence sources, including data aggregators and list providers;
Your referrals (for example a referral who refers you to us for a potential job opportunity);
Clients (for example for our search services a client may provide current or prospective candidates for us to consider for a job they have asked us to fill); and
Any Personal Information you provide to a third party will be subject to that third party’s privacy notice and our use of the Personal Information we obtain from such third parties will be subject to this Privacy Notice.

What Types of Personal Information Do We Collect?

Contact Information like your email address, telephone number, postal address and contact information of any referrals, references or emergency contacts you provide.
Professional and Work Eligibility Information: including your resume or C.V., employment history, education history, certifications, professional license information (for example bar registration number), languages proficiencies, security clearance information, work authorization (for example citizenship information and proof of government-issued identification), professional association memberships, volunteer activities, occupational health and safety information where required, client information where relevant (for example we may collect information from candidates and consultants we place through our staffing business regarding clients the candidate has performed services for) and work-related skills, practice details and skills assessment information including personality characteristics / traits which you choose to provide on a voluntary basis.
Career Planning Information: including your career interests, desired compensation and benefits, desired work location and willingness to relocate, family information as it relates to your career goals or plans, and hobbies and interests.
Demographic Information: including your race, gender, national origin, disability status and veteran status, where we are required to or permitted to do so by law and in support of equal opportunity monitoring or affirmative action programs.
Photos and Visual Images: including photos that you provide to us or that you make publicly available on the internet (for example LinkedIn or company/firm websites); your image on video if you elect to do a video interview, and your image from a security camera if you visit one of our locations.
Device Information: including your IP address, browser type and version, time zone setting, browser plug-in types and versions, location information on a city-regional basis and operating system and platform information when you are visiting our Site(s).
Other Information You Provide: including any other Personal Information you may elect to provide to us, including any paper materials you submit to us.

Who Do We Collect Personal Information From?

Visitors: if you are visiting or using our Site(s) or office locations or any of our Services, so that we can provide you with the Site(s) or Services you require;
Job seekers and Candidates: if you apply for or we contact you about job opportunities with CCI to fill our internal positions or if you apply to or we contact you about job opportunities through our staffing and recruiting services or search, workforce management, or talent advisory services;
Customers, vendors, service providers, and other suppliers: if you are an employee, representative and/or agent of our customers, service providers, vendors, and other suppliers or individuals with whom we have a business relationship and/or manage on behalf of our customers (for example through our outsourcing, MSP and consulting services); and
Referees and others who advise on the suitability of job seekers: if you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you confirm that you have the authority to do so and to permit us to use the information in accordance with this Notice.

Why Do We Collect Your Personal Information?

We collect and use your Personal Information for our business and commercial purposes, which include:

Recruiting and Hiring for current and future job opportunities with us or with our customers, including determining your eligibility and suitability for such opportunities.
Providing our Services, including our staffing and recruiting services as well as our various IT consulting, advisory, transformation and workforce management services.
Receiving Services, including receiving services from various vendors, suppliers, service providers and contractors.
Operating and Improving our Site(s), for example we use your device and information you provide to establish and maintain an account for you on our Site(s) and to improve the navigation and usage of our Site(s).
Business Sales Development, for example using your contact information to call or email you as a talent candidate, customer or prospect as part of providing our Services.
Marketing and Promotions, including sending you promotional communications such as newsletters, surveys, articles of interest, press releases and job fair or other event announcements and personalizing and delivering content about our Services to you, including through advertisements on our Site(s) and other websites.
Improving Our Services through business analytics, internal audits, troubleshooting, quality control, internal user acceptance testing and use of machine learning to improve our search and match capabilities in matching job seekers to suitable jobs efficiently and effectively.
Meeting Substantial Public Interest, such as equal opportunity monitoring and programs that promote diversity and inclusion.
Aggregation and Anonymization, including the process of using Personal Information to create aggregated or anonymized data sets for the purpose of internal business analysis or thought leadership with the end product of such data sets not being Personal Information since it is not identifiable to an individual.
Security and Fraud Prevention to ensure the security of our Site(s) and Services, to protect against fraud, and to comply with legal requirements.
Compliance with Laws, Legal Action and Professional Advice, including compliance with all laws and regulations and addressing legal action or taking professional advice, for example from attorneys or tax professionals.

Who Do We Disclose Your Personal Information To?

CCI does not sell your Personal Information. CCI may disclose certain categories of Personal Information about you for the business purposes mentioned in this Notice to the following categories of third parties:

Potential employers or potential customers – We may disclose your contact information, professional and work eligibility information, career planning information, demographic information, and other information you ask us to disclose to a customer for the purpose of providing our Services for opportunities we believe are of interest to you. Customers of CCI will process such Personal Information in accordance with their own policies and procedures.
Vendors, contractors, and other service providers – We use vendors, contractors, and other service providers to assist us in providing our Services, and it may be necessary for us to provide access to some of the categories of your Personal Information (for example, IT vendors who support our systems, assessment services, and marketing services vendors, attorneys and accountants as well as premises and other security management vendors, including video security at our office locations). These companies will have access to your Personal Information as necessary to perform their functions, but they may only use that information for the purpose of providing the services and are obligated to protect the Personal Information.
Disclosing Within CCI – We may disclose your Personal Information to CCI affiliates, which are companies that have ownership in CCI, are owned by CCI, or are under common control with CCI for example to match you to job opportunities and to utilize shared service functions within CCI.
Business transfers – Circumstances may arise where, whether for strategic or other business reasons, CCI decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of Personal Information to prospective or actual purchasers, or the receipt of it from sellers. It is CCI’s practice to seek and provide appropriate protection for Personal Information in these types of transactions.
Vital interests and legal rights – We may collect and possibly disclose your Personal Information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of CCI’s terms of use, its policies or this Notice.
Compliance with laws – We may disclose your Personal Information where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process, or government requests, including in response to public authorities to meet national security or law enforcement requirements. We also may disclose your Personal Information when we choose to establish or exercise our legal rights or defend against legal claims.
With your consent – We may disclose your Personal Information for other purposes with your consent.

Please note that if you post any Personal Information in a public area of our Site(s), the information that you share will be visible to others and can be read, used, or collected by others. CCI is not responsible for the way others may use Personal Information you post to public areas of the Site(s).

Your Privacy Rights

We respect your privacy rights related to the Personal Information we collect, use and disclose about you and we will comply with applicable data protection laws and regulations in the handling of your Personal Information. The availability of these rights and the ways in which you can exercise them are set out below.

California Consumer Rights

For California residents, you are given rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (“CCPA”) to request that CCI disclose the following about the Personal Information we collect, use and disclose about you:

The right to know what Personal Information we collected about you, including the:
categories of Personal Information;
categories of sources where we obtained Personal Information about you;
the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable);
the categories of third parties to whom we disclose Personal Information; and
the specific pieces of Personal Information we collected about you.
The right to delete Personal Information we collected from you, subject to certain exceptions (for example, we may refuse your deletion request if we are permitted by law to keep the information);
The right to correct inaccurate Personal Information that we maintain about you;
The right to opt out of the sale or sharing; and
If we use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA, the right to limit our use or disclosure.

Additionally, you have the right to be free of discrimination for exercising your consumer privacy rights. If we deny your privacy rights request, we will explain why.

We do not sell Personal Information, and we do not knowingly collect or sell the Personal Information of minors under 16 years of age.

We do not offer any financial incentives in exchange for your Personal Information.

We also do not collect Sensitive Personal Information from you.

Virginia Consumer Data Protection Act

The Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia residents with the right to: Confirm whether or not we are processing your Personal Information and to access such Personal Information;
Correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information;
Delete your Personal Information you have provided or we have obtained about you;
Obtain a copy of your Personal Information;

You also have the right to opt out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. However, we do not sell your Personal Information to third parties as defined by the VCDPA. We also do not engage in profiling in further of decisions that produce legal or similarly significant effects concerning you. If you want to opt out of the processing of your Personal Information for purposes of targeted advertising, we only process your Personal Information for purposes of targeted advertising through our use of cookies should you visit our Sites and you can manage your cookies on our website.

In all jurisdictions, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. This will not affect any processing of your Personal Information done before you withdrew your consent.

Nevada Privacy Rights

Nevada law allows Nevada residents to opt out of the sale of certain types of Personal Information. We do not sell your Personal Information as defined under Nevada law. However, if you are a Nevada resident, you may still submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. To submit your opt out request, you can follow the instructions set forth below for “How to Exercise Your Privacy Rights”.

How to Exercise Your Privacy Rights

If you would like to exercise any of your privacy rights, please contact us to submit your request. If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. For all requests, after submitting the request, we will require additional information to reasonably verify your identity depending on the nature of your request, including for those acting as a representative for a California resident your authority to act on behalf of the California resident.

We will abide by all applicable legal requirements for deadlines for responding to your request and will collect the minimum Personal Information necessary to verify your identity.

Your Right to Opt-Out from Marketing Communications

Where it is in accordance with your marketing preferences and applicable data protection laws, we may periodically send you updates via e-mail about promotional opportunities or services we think may interest you, such as jobs in our database that match your selection criteria, newsletters, white papers, surveys and event information.

You can opt-out of receiving marketing emails from us by clicking the unsubscribe link contained in such emails. If you continue to have issues in unsubscribing from marketing emails from us, you may subject the form mentioned above or call the toll-free number and request to opt-out.

Cookies and Online Tracking

CCI websites use cookies, tracking pixels, web beacons and similar technologies (collectively “cookies”) to help personalize your online experience and for analytics purposes. For more information about cookies, the types of cookies we use, how we use them and how to change your cookie settings, please see our Cookie Notice.

California Residents – Additional Privacy Information

Categories of Information Collected and Disclosed

For more information about each category of Personal Information, purpose of use and third parties which we disclose Personal Information, please see the What Types of Personal Information Do We Collect, Why Do We Collect Your Personal Information and Who Do We Disclose Your Personal Information To sections of our Privacy Notice.

Sale and Sharing of Personal Information

This section will explain to you the instances in which we sell or share your Personal Information, as each is defined by the CCPA. We sell or share your Personal Information for cross-context behavioral advertising, which includes our use of third-party analytics services and online advertising services. These are descried in detail in our Cookie Notice and may result in the disclosure of your online identifiers (e.g., cookie data, IP address, device identifier and usage information).

You have the right to opt out of the sale or sharing of your Personal Information by managing your cookie settings and opting out of all targeted advertising cookies or by enabling Global Privacy Control settings within your browser.

Other CCPA Rights

We do not offer any financial incentives in exchange for your Personal Information. Please see Your Privacy Rights [add internal link to this section] section of this Notice for the rights you have as a California Resident and how to exercise them. Please see information under Data Retention [add internal link to section] section of our Privacy Notice for information regarding how long we retain your Personal Information.

California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclosure your Personal Information to third parties for their own direct marketing purposes.

Security of Your Personal Information

CCI is committed to protecting the Personal Information you share with us. CCI uses appropriate physical, technical, organizational and administrative security measures to help protect your Personal Information from unauthorized or unlawful access, use, or disclosure, and from accidental loss, destruction, or damage.

Data Retention

We retain Personal Information we collect from you where we have an ongoing business need to do so (for example, to provide you with the Service you have requested to maintain you in our talent pool to be potentially contacted about other employment opportunities or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

International Data Transfers

We may transfer Personal Information within CCI, its clients and third parties located in the United States and in other countries that may be outside your country of residence for storage and processing in order to provide the Services. These countries may not necessarily have data protection laws as comprehensive as those in your country or residence. In addition, we will have taken appropriate safeguards to protect your Personal Information in accordance with this Notice and applicable law wherever it is processed. These safeguards include conducting appropriate vetting of third party business partners and implementing data protection language in our contracts with any business partners with whom we are disclosing your Personal Information.

Children's Policy

This site is not intended for use by children under the age of 13. CCI does not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13, we will delete that data from our systems.

Links to Other Sites and Public Forums

Our Sites may contain links to other sites for your convenience and information. If you access those links, you will leave our Sites. CCI does not control those sites or their privacy practices, which may differ from CCI's practices. CCI is not responsible for the privacy practices or the content of other websites outside of CCI. The Personal Information you choose to provide or that is collected by these third parties is not covered by this Notice. We encourage you to review the policies of such third parties before submitting your Personal Information.

CCI may make message boards, news groups, and/or public forums available to users on its Sites. Any information that you disclose in these areas becomes public information that may be accessed by third parties; therefore, you should use caution before deciding to disclose any Personal Information in these forums.

If you have any questions, please contact:

COMPUTING CONCEPTS INC.

185 East Union Avenue

East Rutherford, NJ 07073

t: 201.508.2112

f: 201.935.9653

Changes to this Notice and Effective Date of Notice

If we change this Notice, we will post the revised Notice on our Sites, with an updated revision date. Any new Notice will automatically be effective when it is published on the website. You should therefore return here regularly to view our most up-to-date Notice. If we make material changes to our Notice, we may also notify you by other means, such as sending an email or posting a notice on our home page. The Effective Date of this Privacy Notice is January 1, 2023.