Last Updated: January 6, 2021

This Privacy Policy (“Privacy Policy“) describes how APC Workforce Solutions, LLC d/b/a Workforce Logiq and its wholly owned subsidiaries (together, “Workforce Logiq” or “we” or “us” or “our”) use and disclose the Personal Information we collect from or about you when you:

• Use the Workforce Logiq website (com), Engage Talent website (www.engagetalent.com), our Self-Sourcing Platform, web-based portals, or other websites, blogs, podcasts, pages, or online services that link to this Privacy Policy (the “Sites”);
• Communicate with us electronically, such as via email or through an online chat function; and
• Interact with us offline, including in person, at an event, or via phone.

Before submitting Personal Information to us or using our Sites, please review this Privacy Policy carefully.

Certain Workforce Logiq services or subsidiaries may use different privacy policies to provide notice to you about how your Personal Information is used and disclosed in the context of your use of particular services or relationship that subsidiary. To the extent that Workforce Logiq services or subsidiaries post or reference different privacy policies, the privacy policy posted by each subsidiary, not this Privacy Policy, will apply to your Personal Information collected in the context of those services or by that subsidiary.

Your Agreements with Workforce Logiq

If you are a customer of Workforce Logiq, you may have entered into a contract, engagement letter or other agreement with Workforce Logiq that governs the relationship between you and Workforce Logiq and the services we provide to you (your “Agreement”). If any provision in your Agreement with Workforce Logiq conflicts with any provision in this Privacy Policy, the provision in your Agreement will control to the extent of such conflict.

Note about Customer and Supplier Data: We may receive Personal Information contained in the files, documents, data, and other materials we receive in connection with your Agreement (“Customer and Supplier Data”). We use and disclose this Customer and Supplier Data as described in your Agreement.

Note about Google Integration: If you are a customer of Workforce Logiq’s subsidiary, Engage Talent, you have the option to integrate our platform with your Google email account (“Gmail”). Notwithstanding anything else in this Privacy Policy, our use of your integrated Google data will be subject to the following restrictions: (i) we will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows you to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets; (ii) we will not use Gmail data for serving advertisements; and (iii) we will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.

How We Collect and Use Your Personal Information

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.

We may collect Personal Information:

• Directly from you;
• Automatically through our use of cookies and other data collection technologies on our Sites;
• From publically available sources, such as company websites, blogs, news articles, press releases, and corporate records or reports; and
• From other third-party sources, such as social media platforms (if you, for example, connect with us using your social media account), background check providers, data brokers, and third parties to whom you direct us to collect your Personal information. We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy but we are not responsible or liable for the accuracy of the information provided by third parties or for the third-party policies or practices.

The categories of Personal Information that we collect from you depend on your interactions and engagement with us. For example, we collect:

• Direct Identifiers, such as your name, address, email address, phone number, IP address, online identifiers, payment card or financial account numbers and related information required to process payments, and other similar identifiers. We collect this information to verify your identity and information, communicate with you (including by email, text, or through other methods based on the contact information we have), process your payments, and provide you with access to your Workforce Logiq, Engage Talent, or other account (“Account”).
• Commercial Information, such as the products and services purchased from us. We collect this information to maintain customer and supplier records, identify trends in our relationships, and conduct business analytics.
• Internet Activity Information, such as your browsing history, search history, and information regarding your interactions with pages you visit on the Sites. We collect this information to understand your use of the Sites and your Account.
• Professional and Employment-Related Information, such as information about your current employment, professional degrees, licenses and certifications, education background, publications and quotations, and other information you may include in your CV or cover letter. We collect this information to evaluate your applications, verify your identity, perform regulatory compliance checks, and other related processes.

• Profile Information, such as information about your preferences and characteristics. We collect this information in order to understand your preferences and to tailor our services and communications to you. In some cases, we collect this information in order to create a profile about you.

In addition to the purposes for collection described above, we also collect each category of information for the purpose of maintaining our relationship with you and performing services, which include:

• Onboarding you as a customer or supplier, maintaining or servicing your Account, processing and fulfilling your requests, and other activities that are part of our service offerings.
• Taking steps to improve our services, including to run analytics, improve the artificial intelligence tools and algorithms we use, assess the quality of our services, and for other related internal business purposes.
• Confirming your balances and managing other aspects of your financial transactions.
• Sending you messages promoting our products and services, including webinar information, newsletters, special reports and other marketing communications. You may opt-out of receiving certain promotional e-mail messages from us as described in the “Opt-out” section below.
• Administering and improving our Sites, including to measure the effectiveness of the Sites, help diagnose problems with our server, see where Site traffic is coming from, and to identify our Site users.
• Ensuring the security and integrity of the Personal Information we process and to prevent and address fraud, breach of policies or terms, and threats or harm.
• Complying with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims.

Note to Job Applicants: When creating a profile and submitting your application, we will collect the following categories of Personal Information about you: Direct Identifiers, Internet Activity Information, Professional and Employment-Related Information, and other information or preferences you may include in your resume and cover letter. We use your Personal Information to evaluate your candidacy for the job opening(s) you apply to and other job openings at Workforce Logiq that we think may interest you based on your preferences. We may also evaluate your Personal Information using internal and third party business analytics tools and algorithms to discover ways to improve our business, identify trends in our job applicants and workforce, and enhance our service offerings.

How We Disclose Your Personal Information

We may share your Personal Information in the following circumstances:

• Service Providers: We may share your Personal Information with companies or individuals that we contract with in order to receive services (our “Service Providers”). These services may include, among other things, providing products or services to you on our behalf, creating or maintaining our databases, payment processing, researching and analyzing the people who request information from us, preparing distribution communications or responding to inquiries. We do not allow our Service Providers to use or disclose your Personal Information for any purpose other than for providing services to us.

• Affiliates and Subsidiaries: We may share your Personal Information with companies that we own or control, or that own or control us, or that are under common ownership or control with us.

• Third Parties: We may share your Personal Information with companies or individuals outside of Workforce Logiq who may use your Personal Information for their own purposes (a “Third Party”). For example:
  • We may share your Personal Information with Third Parties to which you have applied for employment. Depending on the circumstances, we may also share your Personal Information with companies and business who have recruiting needs and we think your application and profile is a good fit for those recruiting needs.
  • From time to time, we may be required to provide Personal Information to a Third Party in response to a court order, subpoena, government investigation, or as otherwise required by law.
  • We may share your Personal Information with Third Parties, such as law enforcement agencies, when we, in good faith, believe: (i) you or others are acting unlawfully, (ii) when we believe it is necessary or appropriate to satisfy any law, regulation or other governmental request, (iii) to operate our business and Sites properly, or (iv) to protect or defend our rights or the rights or well-being of our users, even without a subpoena, warrant or court order.

• A Reorganization Event: We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a “Reorganization Event”), transfer, sell or assign your Personal Information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.

Cookies and Other Technologies

We use data collection technologies, such as cookies, web beacons, and pixels on our Sites. “Cookies” are small text files placed on your hard drive when you visit a website. They store information that is sent back to our servers or those of third parties. A list of our cookies is available here, which may change from time to time. In generally, we use these cookies and other data collection technologies to recognize Site visitors, improve the Sites, integrate with third party social media platforms, and serve interest-based and targeted ads. We also may use cookies and other data collection technologies to observe your behaviors and browsing activities over time, across multiple devices, websites or other platforms.

You may adjust your browser settings to block cookies or warn you when a cookie is dropped. If you choose to restrict cookies, some functionality and features of the Sites may be unavailable. To opt out of specific service providers’ cookie technologies, you may visit the following:

• To opt out of Google cookie technologies, visit here
• To opt out of AddThis cookie technologies, visit here
• For instructions on how to control Facebook’s cookie technologies, visit here

Do Not Track Signals: Your web browser may have settings that allow you to transmit at “Do Not Track” signal when you visit various websites or use online services. Like many websites, the Sites are not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you may wish to visit http://www.allaboutdnt.com/.

Social Features

Certain functionalities on the Sites permit interactions that you initiate between the Sites and third-party services, such as social networks (“Social Features”). Examples of Social Features include features enabling you to send content such as contacts and comments between the Site and a third-party service; “liking” or “sharing” our content; and features that otherwise connect the Sites to a third-party service (e.g., to pull or push information to or from the Sites). If you use Social Features, and potentially other third-party services, information you post or provide access to may be publicly displayed by the third-party service you use. Also, both Workforce Logiq and the third party may have access to certain information about you and your use of the Sites and the third-party service.

Marketing Opt-Out

You may unsubscribe from receiving promotional emails from us by following the instructions provided in those email communications, or by emailing us at dataprivacy@workforcelogiq.com. Please note that even if you opt out of receiving promotional communications from us, we may continue to send you non-promotional emails, such as communications regarding our ongoing relationship with you.

Your California Privacy Rights

We provide certain California residents the privacy rights listed below in accordance with the California Consumer Privacy Act (CCPA).

• The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information.

Generally:

• Within the preceding 12 months, Workforce Logiq has collected the categories of Personal Information detailed in “How We Collect and Use Your Personal Information”.
• Workforce Logiq has “sold” (within the meaning of the CCPA) the following categories of Personal Information in the preceding 12 months: contact information, professional and employment information and profile information. We only “sell” Personal Information in connection with the offerings of our Engage Talent business, so that our business partners may use your Personal Information for their recruiting and workforce management needs. We do not sell the Personal Information of minors under 13 without the consent from the minor’s parent or guardian. We do not sell the Personal Information of minors between 13 and 16 years old without the minor’s own consent.
• Workforce Logiq has disclosed the following categories of Personal Information in the preceding 12 months: contact information, professional and employment information, and profile information.

• The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.

• The right to opt out of the sale of your Personal Information. You have the right to opt out of the sale of your Personal Information. You can submit your request to opt out of the sale of your Personal Information by completing our “Do not Sell my Personal Information” form.

• The right to equal service. If you choose to exercise any of these rights, Workforce Logiq will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of Workforce Logiq’s Sites or services.

You may exercise your right to know and your right to deletion two-times a year free of charge. To exercise your right to know or your right to deletion, contact us at 1-877-809-3318 or complete our “California Consumer Request” form.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your request. If you do not have an Account with us, we may request additional information about you. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Shine the Light: This Privacy Policy describes how we may share your information, including for marketing purposes. California residents are entitled to request and obtain from Workforce Logiq once per calendar year information about when we share your Personal Information with third parties for those third parties’ own direct marketing purposes. To request this information, please contact us at dataprivacy@workforcelogiq.com and indicate “California Shine the Light” in the subject line.

International Data Transfers

If you are located outside of the United States and provide us with your Personal Information or use the Sites from outside of the United States, your information will be transferred to, stored and processed in the United States and other countries where Workforce Logiq or its vendors operate. While we take steps to comply with the data protection laws applicable to us, such laws may differ from the data protection laws in your country. By using the Sites or providing us with your Personal Information, you understand that your Personal Information will be collected from and processed in the United States and other countries where Workforce Logiq or its vendors operate. As such, your Personal Information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

U.S.-EU Privacy Shield Framework

Workforce Logiq participates in the U.S.-EU Privacy Shield Framework and is committed to processing all Personal Information received in reliance on Privacy Shield in accordance with the Privacy Shield Principles. In this section, “Personal Information” is defined in accordance with the U.S.-EU Privacy Shield Framework.

Under the Privacy Shield Principles, individuals have the right to opt out of (i) disclosures of their Personal Information to third parties; or (ii) uses of their Personal Information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual. In certain situations, Workforce Logiq may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

We may transfer data to third parties, including business partners, affiliates, and service providers. In accordance with the Privacy Shield Principles, Workforce Logiq is liable for any processing of Personal Information by such third parties that is inconsistent with the Privacy Shield Principles unless Workforce Logiq was not responsible for the event giving rise to any alleged damage.

We are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Please contact us with any questions or concerns relating to our Privacy Shield certification. If we are unable to resolve your questions or concerns, you have the right to contact our independent recourse mechanism, the American Arbitration Association (“AAA”) a U.S.-based alternative dispute resolution provider, free of charge. Visit the ICDR/AAA Privacy Shield Program website http://go.adr.org/privacyshield.html for additional information about how to file a complaint. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means.

The following Workforce Logiq entities are certified under the Privacy Shield: APC Workforce Solutions II, LLC; APC Workforce Solutions III, LLC; Engage Talent, LLC; Job Market Maker, LLC; Quick Acquisition, LLC; and ZeroChaos, LLC.

Visit the Privacy Shield website at https://www.privacyshield.gov/ to learn more about the Privacy Shield program and to view our certification page. If there is a conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern with regard to the Personal Information transferred pursuant to the Privacy Shield.

In addition to Privacy Shield, Workforce Logiq also may transfer Personal Information in accordance with standard contractual clauses approved by the European Commission, which impose data protection obligations on the parties to the transfer.

For further information on the mechanism(s) used to transfer your Personal Information, please contact us at dataprivacy@workforcelogiq.com.

Disclosures to Individuals in the European Union

We are required to comply with the European Union (“EU”) General Data Protection Regulation and applicable local laws with regard to certain Personal Information we collect. For such Personal Information, the Workforce Logiq entity identified at the time of collection is the data controller of the Personal Information. In this section, “Personal Information” is defined in accordance with the General Data Protection Regulation.

We collect your Personal Information detailed in “How We Collect and Use Your Personal Information” pursuant to the following lawful bases:

In limited circumstances, we may collect Special Categories of Personal Information if they are included or inferred by your job application materials. We only process Special Categories of Personal Information if you have provided your explicit consent to us or a third party, the processing is necessary to meet a legal or regulatory obligation, the processing is in connection with the establishment, exercise or defense of our or our client’s legal claims or is otherwise expressly permitted by law. Special Categories of Personal Information includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life, and sexual orientation.

If we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide us with the information when requested, may not be able to perform the contract we have, or are trying to enter into, with you. We will inform you of any mandatory Personal Information we require from you and the consequences if you fail to provide it.

Automated Processing: Our artificial intelligence technologies use automated processing and profiling to improve and deliver our services. This processing allows, for example, recruiters to filter potential job applicants based on certain specified or perceived characteristics, such as skill set or salary expectation. We rely on our legitimate interests for this automated processing, to which you have a right to object. We are not making decisions with Personal Information that would create significant legal effects for you.

EU Privacy Rights: You may have the right to access Personal Information maintained about you and to impose certain limits on the use and disclosure of your Personal Information. Subject to certain conditions, you have the followings rights with regard to your Personal Information that we hold:

• The right to access to certain information about how we process your Personal Information, including the categories of Personal Information that we process, our purposes for processing, and with whom we’ve shared your Personal Information;
• The right to rectify inaccurate Personal Information concerning you and, in certain circumstances, the right to have incomplete Personal Information completed;
• The right to erasure (deletion) of your Personal Information in certain circumstances, including when the Personal Information is no longer necessary for the purposes for which we collected it;
• The right to restrict our processing of your Personal Information in certain circumstances, including when the processing is unlawful or you contest the accuracy of your Personal Information;
• Where processing is based on your consent, the right to withdraw consent. Please note that even after you have withdrawn your consent, we may be able to continue to process your Personal Information in some limited circumstances; and
• Where processing is based on your consent or on a contract, the right to data portability (the right to obtain a copy of the data concerning you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from us).
• In certain circumstances, the right to object to our processing (including our automated processing) of your Personal Information based on our legitimate interests.
• You always have the right to lodge a complaint with your local competent supervisory authority or any authority that applies to Workforce Logiq.

You can submit these requests by email to dataprivacy@workforcelogiq.com or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.

Security

We maintain appropriate technical and organizational safeguards designed to help protect Personal Information from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. For example, we limit access of your Personal Information to authorized parties and have systems in place designed to ensure that we can restore availability and access to Personal Information in the event of a physical or technical incident. Although we use reasonable efforts to safeguard Personal Information, we cannot guarantee the security of Personal Information obtained or stored electronically.

Data Retention

We will store your Personal Information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the Personal Information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process the Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize it.

Third Party Websites and Services

Our Sites, services and materials may contain references and/or links to third-party websites and services, including references and links to third parties that accept and process your payments. Except as described above regarding Service Providers, we have no control over what information third parties track or collect. Any access to and use of third-party websites and services is not governed by this Privacy Policy but instead is governed by the privacy policies of those third-parties. We are not responsible for the information practices of such third parties.

Children’s Privacy

Our Sites and services are not intended for and not targeted to children under 16 and we do not knowingly or intentionally collect information about children under 16. If we learn that we have received information children under 16, we will delete the information.

Questions about Our Privacy Policy

If you have questions about this Privacy Policy, please contact us at dataprivacy@workforcelogiq.com. You can also can contact us at 1-877-809-3318 or by mail at: Workforce Logiq, 420 S Orange Ave., Orlando, FL 32801, USA.

Changes to Our Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practices. When we post modifications to this Privacy Policy, we will revise the “Last Updated” date at the top of this web page. If the changes are material, we will try to notify you in advance of such changes taking place.

We encourage you to periodically review this page for the latest information on our privacy practices.