PRIVACY NOTICE
Last updated: April 2021

This Privacy Notice (“Privacy Notice”) outlines how SAK Talent Advisory & Recruitment, d/b/a Occhio Search & Recruitment (“Occhio,” “we,” “our,” or “us”), uses the Personal Information (defined below) that we process in connection with your use of our website, software, services, content, and materials that link to or reference this Privacy Notice (collectively, our “Service”). Occhio serves individuals seeking employment opportunities and employers seeking potential candidates for employment (each, our “Client”).

1. INTRODUCTION. 
We strive to respect privacy and we recognize the need for appropriate protection and management of any Personal Information that is shared with us as part of using our Service. As used in this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable person. You may choose whether or not to provide or disclose Personal Information in connection with your use of our Service. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Service, but may be unable to access or use certain features, options, programs, products, and services. Our Service may contain links to third-party websites, products, services, and advertisements that are not owned or controlled by Occhio. We are not responsible for the privacy practices or the content of those third party websites, products, services, and advertisements, and you visit them at your own risk. Further, we are not responsible for the privacy practices of our Clients.

2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT.
We, our Clients, and our third party service providers may collect or receive the below categories of Personal Information when you use our Service:

  • Your name
  • Physical address
  • Email address
  • Phone number
  • Educational history
  • Job history

Communications you send to us (including and all information submitted through your resume).
Occhio may collect the categories of Personal Information above and/or additional categories of Personal Information that are necessary for you to access the Service.

3. WHEN PERSONAL INFORMATION IS COLLECTED.
Our Service may invite you to submit Personal Information in the following ways:

  • Contact Information.
    In various areas of our Service, we provide you the opportunity to submit contact information such as your name, email, address, and phone number. We process this Personal Information only as necessary to provide our Service, to further our legitimate interests in protecting our Service and content, and in accordance with our relationship with our Clients. When you submit this Personal Information, you may also be given the opportunity to subscribe to newsletters or consent to receive marketing materials and other communications from us. If you no longer wish to receive these emails, the opt-out process is described in Section 7 of this Privacy Notice. Occhio may also use this Personal Information in an anonymized form to improve our Service and for other lawful purposes.
  • User Submissions.
    Our Service allows users to upload Personal Information, and related information, in connection with submitting their resume to our Clients for consideration of employment. If you submit Personal Information in connection with your resume, you may disclose certain Personal Information to us and our Clients as a product of your submission. Occhio uses commercially reasonable efforts to ensure the appropriate administrative, physical, and technical safeguards are in place as it relates to the Personal Information you provide through our Service as part of any submission.
  • Personal Information You Disclose Relating to Others.
    Our Service may allow you to disclose Personal Information relating to another person (for example, an employment reference). If you disclose any Personal Information relating to other people in connection with our Service, you represent to us that you have the right and authority to (i) submit that information to us, and (ii) to permit us and our third party service providers to manage, process, use, and disclose that information in accordance with this Privacy Notice.
  • Third Party Providers.
    Please note that we use certain third party service providers on our Service to enhance your experience or deliver certain features, functionality, products, and services to you. These third party service providers may collect Personal Information about you when they are performing services on our behalf and/or when you are using certain functions on our Service that are operated by these third parties. Any information, including Personal Information, collected by such third party service providers will be subject to those third parties’ privacy notices or privacy policies, rather than this Privacy Notice. For more information related to our third party service providers, please see Section 6(a) of this Privacy Notice.

4. INFORMATION COLLECTED AUTOMATICALLY.
Certain information on our Service is collected automatically by means of various software tools, as described below. We have a legitimate interest in using such information to assist in systems administration, information security, abuse prevention, to understand the usage of our Service, to analyze the effectiveness of our Service, and to improve our Service. Alone or in combination with other information, some or all of the automatically collected information may constitute Personal Information under certain laws pertaining to data privacy depending on where you live.

Some of our third party service providers may also use cookies or other methods to gather information regarding your use of our Service. These third party service providers may use these cookies or other tracking methods for their own purposes by relating information about your use of our Service with any Personal Information about you that they may have. The use of this information, including any Personal Information they may have about you, by these third party service providers is subject to those third parties’ privacy notices or privacy policies, rather than this Privacy Notice.

  • Usage Data Collection.
    As part of our Service, we collect anonymous usage data. This is non-Personal Information that includes, but is not limited to, internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages, minutes spent completing assessments, minutes spent per learning module, and any other information your browser may send to us (collectively, “Usage Data”). This Usage Data may be used to monitor and analyze use of our Service, for technical administration, to enhance functionality and user-friendliness, and to tailor our Service to your and our other visitors’ needs. Our Clients may also have access to certain Usage Data. We do not treat Usage Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the purposes provided in this Privacy Notice.
  • Cookies.
    We use cookies, which are small pieces of data stored in text files, to make interactions with our Service easy, efficient, and meaningful. When you visit our Service, our servers may send a cookie to your computer or other device. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to an email, submitting your resume, filling out a web form, or through another means, you remain anonymous to us. We may use cookies that are session-based or persistent. Session cookies exist only during one session – meaning, they are downloaded to your web browser when you visit our Service, but then they disappear from your computer/device when you close your browser software or turn off your computer/device. Persistent cookies, on the other hand, are used for multiple visits to our Service and remain on your computer/device after you close your browser or turn off your computer/device.

    Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:

    • Cookie settings in Internet Explorer
    • Cookie settings in Firefox
    • Cookie settings in Chrome
    • Cookie settings in Safari web and iOS.

    Cookies may be set by us when you are visiting or using our Service (these are “first party cookies”) or by third parties, like our third party service providers and/or third party advertisers, (these are “third party cookies”). If you are primarily concerned about third party cookies generated by advertisers, you may be able to turn these off by going to the Your Online Choices or by visiting the Network Advertising Initiative’s Opt-out page, where you may be able to control third party online advertising. Please note that there are more networks listed on those sites than we may use as part of our Service. If you would like to find out more about cookies and their use on the internet, you may find the following links useful:
    Microsoft Cookies guide
    All About Cookies

    Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate through parts of our Service, but you may not be able to successfully use all of the features of our Service.

  • Do Not Track Signals.
    Occhio does not track users of our Service across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to a web browser’s “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time and across third party websites or online products/services.
  • Analytics Service.
    We may use certain third party analytics services to improve the functionality, features, or delivery of our Service. We may also use these analytics services to record mouse clicks, mouse movements, scrolling activity, as well as any text that you type into our Service. For example, we use Google Analytics on our Service to track user trends and usage. For more information on Google Analytics’ processing of Personal Information as it relates to our Service, please see http://www.google.com/policies/privacy/Clients/. By using a browser plugin provided by Google, you can opt out of Google Analytics.

5. THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION. 
If you submit or we collect Personal Information through our Service, then such Personal Information may be used to:

  • Provide, analyze, administer, and improve our Service and related services
  • Contact you in connection with our Service and in connection with certain other services
  • Send you recommendations, updates, and other materials that you have requested
  • Obtain additional information about you from third parties
  • Provide customer service
  • Investigate and address fraud
  • Contact you through email
  • Fulfill our responsibilities to our Clients
  • Protect our rights, our property, or the rights of third parties including our Clients; and ensure the technical functionality and security of our Service.

6. HOW WE DISCLOSE PERSONAL INFORMATION. 
We do not sell, lease, rent or otherwise disclose the Personal Information collected from our Service to third parties unless otherwise stated in this Privacy Notice or unless you otherwise consent to us doing so. The following sets forth when and where we disclose Personal Information collected through our Service:

  • Third Party Service Providers.
    We transfer Personal Information to our third party service providers to perform tasks on our behalf and to assist us in providing our Service. For example, we may share your Personal Information with third party service providers who assist us in performing core functions (such as hosting, data storage, and security) related to our operation of our Service and/or by making certain interactive tools available to you as a user of our Service. We may use third party service providers, such as applicant tracking systems and video interview services, to provide our Service to you. We also use third party service providers for technical support, application development, tracking and reporting functions, quality assurance, and other services. We may share Personal Information from or about you with these third party service providers so that we can deliver the highest quality user experience. We use commercially reasonable efforts to only engage with third party service providers that post a publicly available privacy notice or privacy policy.
  • De-Identified and Aggregated Information.
    To better serve you and improve our Service, Occhio may conduct research utilizing certain anonymized Personal Information in statistical form. This research may be compiled and analyzed on an aggregate basis, and we may share this de-identified or aggregated information with our affiliates and third parties with whom we do business. This de-identified or aggregate information does not identify a user personally. Occhio may also disclose de-identified or aggregated information in order to describe our Service to current and prospective third parties with whom we conduct business and to other third parties for other lawful purposes.
  • Advertisers.
    From time-to-time, we engage third parties to provide advertising services to assist us in advertising our brand and our Service. Those advertising services may target advertisements on third party websites based on cookies or other information indicating previous interaction with our Service.
  • Our Clients.
    Our Clients utilize our Service to connect with those seeking employment. Where a Client has engaged us, we may share Personal Information collected in connection with your use of our Service, including your expression of interest in a position with our Client, in accordance with a separate agreement. We do not control our Client’s use of Personal Information we collect, and their use of the Personal Information will be in accordance with their own privacy notices or privacy policies.
  • In the Event of Merger, Sale, or Change of Control.
    We may transfer or assign this Privacy Notice and any Personal Information to a related or third party entity as part of a merger, acquisition, sale, or other change of control of our business, assets, or stock, including in connection with any bankruptcy or similar proceedings.
  • Other Disclosures.
    We may disclose Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) detect, prevent, or otherwise address fraud or security issues; or (iii) protect against harm to the rights, property or safety of Occhio, our users, or the public.

7. YOUR CHOICES.
If you have questions regarding the Personal Information collected via our Service, you may submit an inquiry via our contact page at www.occhiosearch.com and we will use commercially reasonable efforts to respond in a timely manner in accordance with applicable law. You may choose not to receive future promotional or advertising emails from us or our Client by selecting an unsubscribe link at the bottom of each email that you receive, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to our contact page above. Please note that even if you opt out of receiving the foregoing emails, you cannot opt out of receiving transactional emails related to our Service.

8. INTERNATIONAL USERS.
Please note that our Service is directed towards users who reside in the United States. By using our Service, you consent to the collection, storage, processing, and transfer of Personal Information in and to the United States, or other countries and territories, pursuant to the laws of the United States. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this Privacy Notice.

9. RETENTION OF PERSONAL INFORMATION.
We reserve the right to retain any Personal Information as long as the Personal Information is needed to: (i) fulfill the purposes that are described in this Privacy Notice, and (ii) comply with applicable law.

10. DATA SECURITY. 
The security of Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee the absolute security of Personal Information or our Service.

11. CHILDREN’S PRIVACY. 
We do not target children and do not knowingly collect any Personal Information from children under the age of thirteen (13). When a user discloses Personal Information on our Service, the user is representing to us that he or she is at least thirteen (13) years of age. If we become aware of Personal Information in our systems of children under thirteen (13) years of age, we will take commercially reasonable steps to delete such information promptly.

12. FEEDBACK.
This Privacy Notice does not apply to any unsolicited free-form information you provide to Occhio through our Service or through any other means. Please review our User Terms of Service for more information on our handling and treatment of feedback.

13. YOUR CALIFORNIA PRIVACY RIGHTS.
This section applies to our collection and use of “Personal Information”, as defined under California law, if you are a resident of California.

Categories of Personal Information Collected, Used, and Disclosed
In accordance with California law, we collected the following categories of Personal Information within the preceding 12 months:

  • Identifiers such as your name, alias, email address, mailing address, IP address, and online identifiers
  • Certain categories of Personal Information described in subdivision (e) of California Civil Code Section 1798.80
  • Internet or other electronic network activity information,including information on your usage of our Service
  • Information used to create a profile about a consumer reflecting the consumer’s preferences or behavior
  • Professional or employment-related information
  • Geolocation data
  • Commercial information, including records of products or services purchased or other purchasing histories

We do not sell Personal Information. We may disclose each of these categories of Personal Information with our service providers, but only to the extent necessary for them to facilitate our business purposes (including any purpose specified in Section 5, above).

Your California Privacy Rights
If you are a resident of California, you have the following rights:
Right to Know. You may have the right to request information on the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request information on the categories of Personal Information that were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.

Right to Delete. You may have a right to request us to delete Personal Information that we collected from you.
If you would like to exercise your rights listed above, please contact us at sarah@occhiosearch.com.When doing so, please tell us which right you are exercising and provide us with contact information to direct our response.

We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.

You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

14. CHANGES TO THIS PRIVACY NOTICE.
As our organization changes over time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on our Service. We may e-mail periodic reminders of our notices and terms and conditions, but you should check our Service frequently to see the current Privacy Notice that is in effect and any changes that may have been made to it. Any changes are effective upon the date last updated. This Privacy Notice may be supplemented by additional policies, procedures, disclaimers, guidelines, rules, terms, and conditions of specific application that our Client may disclose from time-to-time related to its legal relationship with you.

15. CONTACTING US.
Any comments, concerns, complaints, or questions regarding this Privacy Notice may be addressed to our contact page at www.occhiosearch.com.