Privacy Notice

Effective: Jan-2-2021

 

This Privacy Notice describes the privacy practices of Ulti, Inc. (“Ulti”, “we”, “us” or “our”), including how we collect, use, share and otherwise process Personal Data, and explains the rights and choices available to individuals with respect to their information.

 

Ulti may provide additional privacy notices to individuals at the time we collect their data. This type of an “in-time” notice will govern how we may process the information you provide at that time.

 

Please note this Privacy Notice applies to Ulti’s processing of web site users’ and job applicants’ personal data, but does not apply to Ulti’s processing of employee or contractor personal data.

 

BY PROVIDING YOUR PERSONAL DATA TO ULTI OR OTHERWISE USING OUR WEBSITE, YOU AGREE TO THE TERMS OF THE PRIVACY NOTICE AND OUR WEBSITE TERMS AND CONDITIONS.

THE INFORMATION WE COLLECT AND USE

When we use the term “Personal Data,” we mean any information that can be used to identify you, directly or indirectly, as an individual person.

 

We collect Personal Data about the following types of individuals: job applicants, volunteers, guest bloggers, job holder interviewees, client administrators, and other individuals who interact directly with Ulti or its business partners, including users of our website.

 

We collect and use Personal Data in the following ways:

 

DATA PROVIDED BY YOU

We collect and use Personal Data that you provide to us in the following ways:

  • Communications.  If you communicate with us through the website or by email, mail, phone, text, chat, or any other paper or electronic form, we may collect your contact information, such as your name, address, email address and phone number, the content of the communication, and the metadata associated with the communication.  We use this information to investigate and respond to your inquiries and to communicate with you. At your request, we may use information you provide to contact you with information regarding UltiCareer, postings you made to UltiCareer, and opportunities to provide feedback.  If you wish to stop receiving email messages from us, please see the “Privacy Preferences” section below.
  • Newsletters.  If you sign up for a newsletter, we collect your contact information and communication preferences.  We use this information to manage our communications with you.  If you wish to stop receiving email messages from us, please see the “Privacy Preferences” section below.
  • Registration.  If you register in our database we collect your contact information, demographic information, such as country, age range, gender, postal code, communication preferences and job position.  If you wish to stop receiving email messages from us, please see the “Privacy Preferences” section below.
  • Comment Submissions. If you submit publicly-accessible comments on the website, we collect your name, email and the information you supply in the comment.  This information allows us to communicate with you about your comment and to display your comment online.  Please be aware that any stories, comments or other information that you submit on a public forum will be publicly accessible. If you wish to delete your comment, please contact us using the information in the “Contact Us” section below.
  • Employment Applications. If you submit an application for employment, we collect your contact and demographic information, education, work history, employment needs, CV or resume, interests, and any other information you choose to provide.  We use this information to evaluate your eligibility and candidacy for employment, to communicate with you before, during and after the relevant application process and to facilitate the application process and any pre-contractual steps needed prior to employment.
  • Events.  If you register for any Ulti event, such as a training, lecture, seminar, workshop or open house event, we collect your contact and demographic information, including job position.  We require these details in order to register you in the program, administer the event, contact you about your experience and to inform you about future events that may be of interest to you.
  • Business Partners. If you are a business partner or service provider, or otherwise providing services to Ulti, we may collect your contact information, professional credentials, educational and professional history, institutional affiliations, background checks, performance reviews, and information needed for the purposes of compensation. 

The above list is intended to provide full visibility into potential uses.  As such, it may reference functionality not presently available on our website, as specific functionality may be added or removed over time.

DATA WE OBTAIN FROM THIRD PARTY SOURCES

We collect Personal Data from the following third party sources.

  • Business Partners and Service Providers: We may collect information about individuals from our business partners and service providers, market research providers, industry and interest groups and associations, and recruiters. The information may include contact information, demographic information, educational and professional history, institutional affiliations, background checks and performance reviews. We use this information to administer and coordinate events and programs, conduct market research and to identify potential employment candidates.
  • Publicly Available Sources: We collect information about individuals from publicly available sources, such as public comments on UltiCareer and its operations on social media platforms (for example, Facebook, Twitter, and Instagram) or publicly available research. This information enables us to conduct market research about the company and industry trends, analyse public interactions with Ulti, identify experts and improve our programs, events, and other offerings.

DATA WE COLLECT AUTOMATICALLY

We use certain technologies on the website to collect information about the device or browser you use to navigate our website.

The technologies we use may include the following:

  • Web Logs: Like most websites, we automatically gather certain information about our website traffic and store it in log files.  This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.  We may use log data to analyse trends on our website, manage and administer the content, security and availability of our website, improve the content, overall performance and user experience on the website, and for fraud protection and to protect our rights and the rights and safety of individuals.
  • Cookies, Analytics and Other Data Collection Tools: Ulti and its service providers use cookies, web beacons and similar technologies to collect and store data about your preferences and interactions with our website.  This data helps us recognize your browser or device. We may also receive the information on an aggregate basis about broad demographics. The data helps us measure and analyse the demographics and interests of our visitors, determine how users are interacting with our website and develop solutions to make the website more useful. Most browsers allow you to control cookie tracking, typically under the sections “Help” or “Internet Options”, or you can visit AboutCookies.org for more information. If you disable or delete certain cookies in your settings, some pages of our website may not fully function, and you may not be able to access certain information on the website.  Please see our Cookie Notice at the end of this page for more information on cookies. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

OTHER USES OF PERSONAL DATA

In addition to the uses described above, we may use your Personal Data for the following purposes:

  • Maintaining, improving and delivering the website;
  • Communicating with you to provide technical or administrative support;
  • Developing new resources and services;
  • Conducting, managing and growing our business;
  • Defining and managing appropriate interest group activities, or programs;
  • Paying for services that contractors and other individuals may provide to us;
  • Preventing, investigating and providing notice of fraud, unlawful or criminal activity, unauthorized access to or use of Personal Data, the website or our data systems, and to meet legal, regulatory, judicial and company policy obligations;
  • Investigating and resolving disputes and security issues and enforcing our Terms And Conditions; and
  • For any other lawful, legitimate business purposes.

HOW WE SHARE AND DISCLOSE PERSONAL DATA

We share Personal Data in the following ways:

  • Service Providers: We share Personal Data with third-party service providers who perform services on our behalf, such as data storage and analytics providers, recruiters, background check providers, event coordinators, market research providers, technology providers (including technology support providers, email communications providers and web developers).
  • Research: We may disclose Personal Data to third-party market research firms for those organizations to perform market research on our behalf, as permitted by law.
  • Regulatory or Legal Requirements, Safety and Terms Enforcement: We may disclose Personal Data to governmental regulatory authorities as required by law. We may also disclose Personal Data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or us, to protect against fraud or credit risk, or to enforce our legal rights or contractual commitments that you have made.
  • Business Transfers: We may disclose Personal Data as part of a corporate business transaction, such as a merger, acquisition, joint venture, financing, or sale of company assets and may transfer Personal Data to a third party as one of the business assets in such a transaction. We may also disclose Personal Data in the event of insolvency, bankruptcy, or receivership.

PRIVACY PREFERENCES

If you have opted in to our email communications (or where permitted by law, if you have provided us or we have obtained your contact information for the purposes of marketing communications), you may choose to opt-out of receiving further commercial messages from us by following the unsubscribe instructions in the email you received. Please note that you may continue to receive certain transactional or administrative email communications from us.

 

If you have provided consent for our processing of your Personal data, you may withdraw such consent at any time and request the erasure of your data by contacting us at contactus@ulticareer.com.

 

A withdrawal of your consent does not affect the lawfulness of our use of the data prior to the withdrawal. Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent if we have a legal requirement to do so.  For example, we may retain certain information if we need to do so to comply with independent legal obligations.

 

You may contact us to update Personal Data we have about you by contacting us at contactus@ulticareer.com.

 

CHILDREN’S PRIVACY

The website is not intended for, or directed to, children under the age of 13. We do not knowingly receive Personal Data from children under the age of 13. If you are under the age of under the age of 13, do not provide us with any Personal Data either directly, through any website forms, or by any other means.  If you become aware that your child has provided us with Personal Data, please contact us at  contactus@ulticareer.com.

 

SECURITY OF PERSONAL DATA

We strive to put in place measures to protect the Personal Data that we process in connection with the Services.  However, we cannot 100% guarantee the security of Personal Data that we process in connection with our business, or that your Personal Data will not be unlawfully accessed by third parties. You can also take additional measures to protect yourself and your information, such as keeping log-in credentials and passwords confidential.

 

REGION-SPECIFIC DISCLOSURES

If you are located in the European Economic Area (“EEA”) or Switzerland, these following additional disclosures apply to the processing of your Personal Data.

  • Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your personal data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your personal data, and we will do so, if we are relying on a legitimate interest to process your personal data - unless we demonstrate compelling legitimate grounds for the processing.
  • Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
  • Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, and your are a resident of the European Union, you can report it to the relevant Information Commissioner’s Office (“ICO”) responsible for your country of residence.

To submit a request, please contact us using the information in the “Contact Us” section below. We will respond to your request within a reasonable timeframe.

Residents of the European Union have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority, https://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm).

  • Legal Basis for Processing: In this section, we identify the lawful grounds we rely on for processing Personal Data.

Consent

If Ulti relies on consent for the processing of Personal Data, we will provide transparent notice of the purposes for which we seek such consent at the time we collect your Personal Data.

If Ulti wishes to process any special categories of Personal Data as set out in Article 9(1) of the EU’s General Data Protection Regulation, Ulti may obtain your explicit consent for such processing.

For information on how to withdraw consent, please see the “Privacy Preferences and Retention” section of the Privacy Notice.

Contractual Necessity

Ulti processes Personal Data to fulfil our contracts with our business partners and service providers, such as for rendering payment or communicating with health care professionals or consultants.

Legal Obligation

Ulti may process Personal Data as specifically required by applicable legal obligations, such as laws and regulations.

Public Interest

Ulti may process Personal Data for scientific or historical research purposes, or statistical purposes in the public interest, as authorized by applicable law.

If Ulti wishes to process any special categories of Personal Data as set out in Article 9(1) of the EU’s General Data Protection Regulation, it may do so when necessary for scientific research purposes.

Legitimate Interests

Ulti may process Personal Data subject to its own legitimate interests, such as to develop, administer and support our research; to operate, evaluate and improve our business; to facilitate and manage interest group engagement programs; to promote scholarly research; to support our recruitment activities; or to facilitate a sale of assets or merger or acquisition.

It may be also necessary for Ulti to process Personal Data to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the Terms And Conditions that govern the services we provide.

Compatible purposes

Ulti may also process Personal Data for purposes that are compatible with those described above. 

  • Data Retention. We retain Personal Data for as long as necessary to carry out the purposes of processing described in this Privacy Notice, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.  The criteria used to determine the period for which Personal Data about you will be stored varies depending on the legal basis under which we process such personal data:

Consent

For the period of time necessary to fulfil the underlying agreement with you, subject to your right, under certain circumstances, to have certain personal data about you erased (see Data Subject Rights section above).

Contractual Necessity

For the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the limitation period for legal claims that could arise from the contractual relationship.

Legal Obligation

For the duration of any legal required retention period, or as needed to preserve evidence for known, threatened or suspected legal claims, actions or other proceedings.

Public Interest

For the period of time necessary to fulfil the purposes of the business process in the public interest.

Legitimate Interests

For a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.

 

  • International Data TransfersInformation collected through our website or otherwise sent to us electronically is maintained in the United States and India. The countries to which we transfer Personal Data may not have the same data protection laws as the country in which you initially provided the information. By submitting Personal Data to Ulti, you agree that Ulti may maintain the information in the U.S. and share the Personal Data as described in this Privacy Notice.
  • If we transfer Personal Data across borders, we will consider a variety of requirements that may apply to such transfers. Specifically, we may transfer Personal Data from the EEA or Switzerland to:
      • Countries that the European Commission has deemed to adequately safeguard Personal Data, and
      • Third countries where the European Commission has not issued an adequacy decision and subject to appropriate or suitable safeguards, including:
        • Pursuant to the recipient’s compliance with standard contractual clauses, Data Processing Agreements (DPAs), EU-US Privacy Shield, or Binding Corporate Rules,

OR

        • Pursuant to the consent of the individual to whom the Personal Data pertains,
  • To perform a contract with you or to perform a contract that we enter in your interest, and
  • As otherwise permitted by applicable EEA requirements.

You may request information relating to the applicable safeguards by contacting us using the information in the “Contact Us” section below.

 

LINKS TO OTHER WEBSITES

As a convenience to our visitors, the website may contain links to some external sites and digital services operated by third parties that we believe may offer information of interest to our website visitors.  This Privacy Notice does not apply to these websites.

 

Our website also includes features like buttons and widgets hosted by other companies (for example, the Facebook “share” button).  Some of these features collect Personal Data or other information such as your IP address and your actions on our website.  This Privacy Notice does not apply to the practices of these third parties. We encourage you to review the privacy notices of those third parties to learn about their Personal Data and privacy practices.

 

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Company other than Personal Data collected through the Site. This Privacy Policy shall not apply to any unsolicited information you provide to Company through any other means (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and Company shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

 

UPDATES TO THE PRIVACY NOTICE

This Privacy Notice is subject to occasional revisions. We will notify you of changes by posting the new policy on the website and updating the effective date of the policy. Ulti encourages visitors to check this page frequently for any changes to this Privacy Notice. Continued use of the website following such changes will indicate your acknowledgement of, and agreement to be bound by the changes.

 

CONTACT US

If you have questions, comments or requests about this Privacy Notice or your Personal Data, you may contact us at:

Ulti, Inc.

103 Village Pond Road
Guilford, CT 06437

203-974-3296

contactus@ulticareer.com 

 

 

 

Cookie Notice

Effective: Apr-16-2020

 

CONSENT

By using the UltiCareer website (located at www.UltiCareer.com) and any other website (including mobile-optimized websites) owned or controlled by Ulti and which link to this Cookie Notice (collectively, the “Website”), you consent to the use of cookies in accordance with this Cookie Notice.

 

COOKIES

Cookies are small amounts of data which your web browser stores on your device at the request of certain websites. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains so when you visit the website, your browser may receive cookies from several sources.

 

Cookies are useful because they allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

 

There are two primary types of cookies that are used, session cookies and persistent cookies. Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site). Each cookie typically falls into one of several categories.

 

TYPES OF COOKIES ULTI USES

We describe the categories of cookies Ulti and its service providers use below.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, Website pages you have asked for cannot be provided.

Performance Cookies

We make use of analytics cookies to analyze how our visitors use our Website and to monitor Website performance, including those by Google Analytics. This allows us to provide a high-quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

Website Functionality Cookies

We make use of cookies to provide you with certain functionality. For example, to enable user comments on our articles, or to recognize the platform from which you access the site, and to provide enhanced and more personal features. These cookies are not used to track your browsing on other sites.

 

DISABLING COOKIES

If you do not agree to the use of cookies that are not strictly necessary, most browsers allow you to control cookie tracking, typically under the sections “Help” or “Internet Options”, or you can visit AboutCookies.org for more information. Please note that some of the Website services may not function properly if cookies are disabled. You may also opt out of third-party cookies where available by using the links provided in this Cookie Notice.

 

THIRD PARTY WEBSITES

Please note that this Cookie Notice does not apply to, and we are not responsible for, the cookie practices of third-party websites that may be linked to this Website.

 

CHANGES TO THE COOKIE NOTICE

We may update this Cookie Notice and we would encourage you to review the notice from time to time to stay informed of how we are using cookies.

 

 

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