(as of July 27, 2020)
- Intoo, LLC, with offices at 10880 Wilshire Boulevard, Suite 1101, Los Angeles, CA 90024 (referred to as, Intoo, “we”, “us”, “our”) provides the www.yournextstep.com website along with other Intoo websites (collectively, the “Site”). The Site includes a variety of services, online and mobile applications, downloadable software, products and features, including, but not limited to, CareerArc Outplacement, Your Next Step, Candidate Care, and all available on various mediums or devices now known or hereafter developed (collectively, the “Services”).
Information We Collect
- We receive and collect information that identifies you or that can be used to contact you, online or offline (“Personal Information”) (such as name, address, telephone number, email address, contact information, demographic information, work history, academic history, etc.) from: (i) you, on a strictly voluntary basis, by specifically requesting it from you (1) when you register on the Site, (2) when you complete or edit your profile, (3) when you use or register for the Services, (4) when you respond to surveys or questionnaires, (5) when you enter or sign up for promotions or contests; or (6) when you choose to upload resumes, cover letters, writing samples and other documents to the Site, which contain personal information about you, or personal information about third parties, such as references or contacts, that you provide to us if you have such third party’s consent to do so, and (ii) our business partners, including, but not limited to, our social networking partners (e.g., Facebook, Twitter, LinkedIn) who have your permission to disclose your Personal Information to us.
- We may also ask you for other information from time to time, which you may choose to provide or not to provide at your sole discretion, such as information regarding your views on career related topics and other selected issues, your opinion regarding various features of our Site or Services, the types of jobs or candidates you are interested in, etc..
- When you create an account on our Site or through use of our Services, you will provide information that could be Personal Information, such as your name, username, password, phone number, postal address, and email address. You acknowledge that this information may be personal to you, and by creating an account on our Site or through use of the Services, and providing Personal Information to us, you allow others, including us, to identify you, and therefore, you may not be anonymous.
- We also collect information including technical data about how our Site and Services are used. This includes information such as a User’s Internet Protocol (IP) address, browser type, operating system, a User’s interactions and/or activities within the Site and the Services, frequency with which our Services and its features are used by a User, the pages or features of our Services which a User has browsed, the time spent on those pages, and other statistics. It also includes certain information that your device may send when you use our Services, like a device identifier, user settings, and the operating system of your device.
- We may aggregate and anonymize your information so that we can use it to understand our User base and Site and Services usage patterns, but only on a collective, aggregated basis and in a manner which does not reveal any Personal Information about any individual User.
How We Use Personal Information Collected
- to allow you to create an account and profile;
- to enable you to provide feedback, to contact us and for us to respond to you;
- to provide information about you and your potential interest in job postings to employer customers or networking opportunities with other Users of our Site and Services;
- to provide products and services to employer customers to complete the recruitment and hiring process, such as accessing our application or resume database;
- to communicate with you with regard to your use of the Site and the Services, or to advise you of Site or Service changes or other events or occurrences which may affect your access to or use of the Site or Services;
- to provide employers or business partners who are members of our Network (as defined below) with information and statistics on Users of the Site or Services;
- to administer market research including questionnaires, polling activities and other similar events and activities that you choose to participate in;
- to administer sweepstakes, contests, surveys, and other similar events and activities that you choose to participate in;
- to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
- to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our Terms of Service, which may include sharing information with other companies, lawyers, courts or other government entities; and
- for other purposes specifically communicated to you when we collect the information.
Who We Share Your Personal Information With
- If you are a job seeker and choose to publish your profile, upload or create a resume or any other document containing Personal Information (e.g., education and work history) so that employers can find you in our database or to participate in the CareerArc Outplacement network, Your Next Step network, Candidate Care network or any of our other networks (collectively, “Networks”), your personal profile information, cover letter, resume and/or other User Content containing your Personal Information will be accessible to employers who have access to those databases. In addition, these employers will have access to individual statistics about how you interact with their content on the Site, such as which of their job postings you view. If you are a User of our Your Next Step service (or its functional equivalent) and choose to use a career coach, then your Personal Information will be available to that career coach, including information exchanged between you and the career coach using chat, telephone or email. Please note that for User Content that is either uploaded to or created through use of our Services, such User Content must not contain sensitive data relating to your (i) racial or ethnic origin (ii) political beliefs (iii) philosophical or religious beliefs (iv) membership of a trade union or political party (v) physical or mental health or genetic makeup (vi) addictions, (vii) sexual life, (viii) criminal offences or proceedings and associated penalties or fines (if applicable), (ix) Social Security Number or state or national identification number, or (x) credit card or bank account numbers. If you provide us with details of a professional reference, it is your responsibility to ensure that the person is aware that you have forwarded his/her details and has consented in writing for you to do so.
- With your prior permission, we may use your email address and other contact information to send you articles, profiles, industry news and other career related information, as well as to notify you of special promotions or additional products and services offered by us or our business partners and advertisers that may be of interest to you. With your prior permission, we may also share your Personal Information with our business partners and other third parties to enable them to contact you regarding special promotions, products, and services they offer which may be of interest to you. You have the ability to opt-out of these types of communications at any time (see “Opt-in/Opt-out Policy” below).
- We may use third-party advertising companies to serve ads when you visit the Site or use the Services. These companies may use information (not including your name, street address, email or telephone number) about your visits to the Sites and other web sites, or use of the Services, in order to provide advertisements about goods and services of interest to you.
- We employ other companies and individuals to perform functions on our behalf who require access to your Personal Information. Examples may include hosting our web servers, analyzing data, providing marketing assistance, cloud storage providers, customer relationship management systems, communication systems (e.g., email, SMS text messages), and processors providing customer service. These other companies are required to maintain the confidentiality of your information and are prohibited from using your Personal Information except to provide services to us.
- From time to time, we may also disclose Personal Information to fulfill certain legal and regulatory requirements or if we believe, in good faith, that such disclosure is legally required or necessary to protect others’ rights or to prevent or mitigate harm, or to investigate or report on activity which we believe to be unlawful.
- We may also disclose and transfer such information to a third party who acquires all or a substantial portion of our business, whether such acquisition is by merger, restructuring, consolidation or purchase of all or a substantial portion of our assets related to the Services. In addition, if Intoo becomes the subject of a bankruptcy proceeding, whether voluntary or involuntary, Intoo or its trustee in bankruptcy may sell, license or otherwise dispose of such information in a transaction approved by the bankruptcy court.
- All Users should be aware that when they voluntarily display or distribute Personal Information (such as their email address) to others (whether in chat rooms, message boards or discussion forums, by posting jobs, responding to employers message or otherwise), that information can be collected and used by others. This may result in unsolicited messages from third parties, for which we are not responsible.
- Finally, if you provide any information to parties who operate Third Party Websites that are linked to or from the Site or Services, or if you input your information on a co-branded registration page such as that of Intoo and a partner company in connection with a partnership, sponsorship or contest, different rules may apply to the collection, use or disclosure of your Personal Information by such other party or in connection with such partnership, sponsorship or contest. We are not responsible for any such party’s use of your Personal Information. We encourage you to review these Third Party Websites’ privacy policies or terms of service before revealing any sensitive or Personal Information.
Updating Account Information
- When you complete your account profile to register on the Site or to use the Services, you are allowed to change or correct your Personal Information at any time. To do so, simply log in to your account, go to your profile, and you will find options for editing the information you have submitted.
Important Tips for Job Seekers to Use When Dealing With Prospective Employers
- Never give out your social security number to a prospective employer via email or before you are contracted to work for them.
- Never provide credit card or bank numbers or monetary transactions of any sort to individuals or employers, especially individuals or employers seeking initial investments or deposits, or promising reimbursements.
- Be cautious when dealing with contacts outside of your own country.
- Do not provide any non-work related personal information (i.e. eye color, marital status, etc.) over the phone or online.
- When you complete your profile to register on the Site or to use the Services, you may be presented with a series of choices regarding whether you want to receive certain types of communications directly from us or on behalf of our business partners and advertisers. If you do not wish to receive any or all of such communications, then do not click or check the appropriate box to opt-in, do not input the requested Personal Information (e.g., your phone number for SMS text alerts), or simply do not agree to register with our the Site or use our Services. We reserve the right to send you communications regarding the Site or the Services, or to advise you of Site or Services changes or other events or occurrences which may affect your access to or use of the Site or Services (such as service announcements, administrative notices and the like) without offering you the opportunity to opt out of them. If after opting-in to our Networks or receiving communications from us or our business partners, you wish to opt-out of participation in the Network or from receiving future communications, you may do so at any time by electing to unsubscribe from further communications.
Cookies & Other Tracking Technologies
The types of cookies and similar technologies used by us and our partners in connection with the Site and Services can be classified into one of five categories, namely 'essential cookies', 'functionality cookies', 'analytics cookies', 'advertising cookies', and ' social media cookies'. Cookies do a lot of different tasks to ensure you enjoy your visit to our Site, for example, they are used to remember your preferences on sites you visit and to help you navigate between pages more efficiently. We have set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.
Type of cookie What it does Cookies necessary for essential purposes These cookies are essential to provide you with the Site and Services and any services available through this and to use some of its features, such as access to secure areas. Without these cookies services you have asked for, like transactional pages and secure login accounts, would not be possible. Functionality Cookies Functionality cookies record information about choices you've made and allow us to tailor the Site and Services to you. These cookies mean that when you continue to use or come back to the Site, we can provide you with our Services as you have asked for them to be provided.
These cookies allow us to:
- Save your location preference if you have set your location on your homepage, if applicable, in order to receive localized content specific to your location; and
- Remember settings you have applied.
Analytics Cookies We use analytics cookies to analyze how the Site and Services are accessed, used, or is performing in order to provide you with a better user experience, to allow our employer customers to see how you interact with their content on the Site and through use of our Services, and to maintain, operate and continually improve the Site and Services.
We also use Google Analytics, which is a web analytics tool that helps us understand how Users engage with the Site and Services. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how Users use our Site and Services. This information is used to compile reports and to help us improve our Site and Services. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, see here. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
Analytics cookies allow us to:
- Better understand our Site visitors and use of the Services so that we can improve how we present our content;
- Test different design ideas for particular pages, such as our homepage;
- Collect information about Site visitors such as where they are located and what browsers they are using;
- Determine the number of unique users of the Site;
- Improve the Site by measuring any errors that occur; and
- Conduct research and diagnostics to improve product offerings.
Advertising and Targeting Cookies We allow third party companies, including advertising companies, to place cookies on our Site.
These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet.
Cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you've last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.
Social Media Cookies On some pages of our Site, third parties that provide applications through our Site will set their own cookies in order to track the success of their applications or customize applications for you. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of our Site will also contain embedded content, such as video content from YouTube, and these sites will set their own cookies.
These cookies are used when you share an article using a social media sharing button on our Site (e.g., Facebook, Twitter, or Google Plus) as the social network that has created the button will record that you have done this. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via cookies.
- You can adjust and block cookies using your browser settings. Find out how to manage cookies on these popular browsers:
- As you browse the Site, online ad networks we work with may place anonymous cookies on your computer, and use similar technologies, in order to understand your interests based on your (anonymous) online activities, and to tailor more relevant ads to you. If you do not wish to receive such tailored advertising, you may use the opt-out tool of the Network Advertising Initiative found here: http://www.networkadvertising.org/choices, or the opt-out tool of the Digital Advertising Alliance (DAA) found here: http://www.aboutads.info/choices. Opting out of tailored advertising will not prevent you from seeing ads altogether, and we cannot guarantee that these opt-out tools will always be effective; the opt-out tools are simply designed to ensure your ads will not be delivered through targeting methods from these online ad networks. We and our online ad networks provide opt-out mechanisms through the tools linked above and do not currently respond to browser “Do Not Track” signals.
- When you visit the Site, the server housing the pages automatically generates a “session log.” We use session logs to help us determine how people travel through the Site. In this way, we can structure our pages so that the information most frequently visited is easier to find. By tracking page visits, we can also determine if the information we’re providing is being used.
Children Under 13 Are Prohibited from using the Site and Services
- The Site and Services are not intended for children under the age of 13 and we do not knowingly collect or solicit Personal Information from children under the age of 13 or knowingly allow such persons to register on our Site or use our Services. If you are under 13, please do not attempt to use or register on our Site or use our Services or send any Personal Information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any Personal Information to our Site or through use of the Services. If we become aware that a child under the age of 13 has provided us with Personal Information, we will delete such Personal Information from our records where reasonably possible.
- While we use SSL encryption and user passwords to protect sensitive information online, we also protect user-information off-line. All of our Users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a member service representative) are granted access to sensitive or Personal Information. Furthermore, all employees are kept up-to-date on our security and privacy practices.
Your California Rights
- A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
- California customers may request further information about our compliance with this law by emailing email@example.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.
Questions or Concerns
10880 Wilshire Boulevard, Suite 1101
Los Angeles, CA 90024
Phone: (888) 879-9357
EU and UK Addendum
If you are a User located in the EU or UK, please read this additional information about how we process your Personal Information. This is in addition to what we have described above.
We are the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and applicable data protection laws.
Legal Basis for Processing your Personal Information
Personal Information Use Legal Basis for Processing Account data such as your name and contact details. To create your account for the Services in accordance with your request. We need this information to fulfil our contractual obligations with you to provide and support the Services. Information that you provide to us, such as your work and academic history and demographic information. This information may be provided to us through documents you upload or responses you give to our surveys. To allow you to prepare and search for job opportunities, and interact with our career coaches.
We also use this to send job postings to you in accordance with our contract with you.
We need this information to fulfil our contractual obligations with you to provide and support the Services.
It is in our legitimate business interests to provide you with a relevant service and to analyze how Users are interacting with our Site and Services so that we can improve our products and provide a better service
How Long We Retain Your Data For
- We retain your Personal Information for the period during which you maintain an account or registration for the Services, after which time your data is deleted or stored in an aggregated and anonymized format, unless otherwise required by applicable laws. All User Content submitted by you to the Services may be aggregated and anonymized after you terminate your account with us.
In accordance with the appropriate statutory limitation periods as provided by local law, we may retain your information for longer than stated above for as long as such Personal Information is needed for the following reasons:
- as required by law or court order;
- as needed to defend or pursue legal claims; and / or
- as required for legitimate business purposes.
Under the GDPR you have a number of rights with regard to your personal data (as defined in the GDPR). In certain circumstances, you have the right:
- to access your personal data: this means that you can request access to the data we hold on you at any time;
- to correct your personal data: if any personal data that we hold about you is incomplete or inaccurate, you are able to require us to correct it;
- to delete your personal data: if you would like us to stop processing your personal data, in certain circumstances you have the right to ask us to delete it from our systems, for instance where you believe there is no reason for us to continue processing it;
- to restrict the processing of your personal data: in certain circumstances, you have the right to restrict our processing of your personal data, for example if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the personal data is correct;
- to data portability: where we process your personal data on the basis of your consent or on the basis that it is necessary for the performance of a contract, you will have the right to transfer the data that we hold on you for your own purposes in a structured, machine readable format;
- to object certain data processing: where we are processing your personal data for our own legitimate interests, or for the legitimate interests of a third party, you have the right to object to the way we use your data; and
- to regulate any automated decision-making and profiling of personal data: you have a right not to be subject to automated decision-making in any way that adversely affects your legal rights.
- Where we are relying solely on your consent to use your data, you also have the right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use.
- These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to retain.
To exercise any of the rights in this section, please contact our representative in the EU, DataRep, via email at firstname.lastname@example.org or by mailing your request to either of the following addresses:
- Germany: DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
- Italy: DataRep, BPM 335368, Via Roma 12, 10073, Turin, Italy
- United Kingdom: DataRep, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom
Questions or Concerns
10880 Wilshire Boulevard, Suite 1101
Los Angeles, CA 90024
Phone: (888) 879-9357
- You also have the right to lodge a complaint with the relevant data protection authority in the country in which you live or work.