High5 and its group companies, (collectively, “High5”, or “we”) are committed to safeguarding your privacy. In this Online Privacy Notice (“Notice”) we explain to you what information we may collect, use, share, and store about you, and the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below at ‘Contacting Us’.
We participate in and comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as supervised by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area (“EEA”) member countries and Switzerland to the United States, respectively. You can find out more about our Privacy Shield commitments below.
Talented people around the world work hard to find good work. Yet opportunity remains concentrated, held captive. With High5, employers liberate work opportunities — full-time, contract, contract-to-hire, freelance, onsite or remote — on the world’s first and only global total talent experience platform. Qualified talent and recruiters find work. Employers gain immediate access to trusted talent. Finally, working people, recruiters, and employers get the superior experience they’ve long deserved. And, unlike niche talent marketplaces, with High5, you can get it all done — any job, skill, work type, and in any geography. High5 is work, liberated.
When this Notice Applies
“Personal information” consists of information which may directly or indirectly identify you. This Notice applies to our collection, use, and disclosure of your personal information:
- through our website(s) and related applications and content that link or refer to this Notice; and High5 computer or mobile software applications (“apps”) and content made available to you) (collectively the “Sites”);
- in connection with any of our events or sales, marketing, advertising and recruitment activities, or in the course of providing other High5 services to you; and
- when receiving services from you.
This Privacy Notice does not apply to the practices of third parties that High5 does not own or control.
Collection of Personal Information
High5 collects and maintains personal information from the following categories of individuals:
- Visitors: individuals who visit or use our site(s) or any other High5 services, so that we can provide them with the site(s) or High5 services they require;
- Job seekers: individuals that apply for job opportunities with High5 to fill our internal positions or as part of our staffing and recruiting services or High5’s customers through our search, workforce management, or talent advisory services (in each case, whether such applications are made online or offline);
- Customers, vendors, service providers, and other suppliers: employees, representatives and/or agents of our customers, service providers, vendors, and other suppliers with whom we have a business relationship and/or manage on behalf of our customers.
- Referees and others who advise on the suitability of job seekers for particular positions. If you submit any personal information relating to other people to us or to our service providers in connection with High5, you confirm that you have the authority to do so and to permit us to use the information in accordance with this Notice.
The types of information we collect include the following:
Information submitted to us: High5 collects personal information that individuals provide to us, such as when they visit one of our Sites, post on our forums or blogs, sign up for a High5 account to access certain services, like an High5 job board, or if they subscribe to our marketing, register for an High5 event or webinar, or otherwise contact us. We may also collect personal information from individuals’ offline, for example when individuals provide information to us by telephone or in person at events or at one of our recruitment offices.
The types of personal information we may collect include:
- contact information (such as name, postal address, email address, and telephone number);
- username and password when you register on our Sites;
- professional information, such as your job title, department, or job role;
- information you provide about others you would like us to contact (for example referrals or references) or information regarding your emergency contacts;
- resumé or C.V. information, such as employment and education history, language proficiencies, security clearance information, and other work-related skills, awards, and honors, membership in clubs and organizations, personal interests and activities, and information regarding your career interests and other qualifications for or desires regarding future employment opportunities, including information regarding desired compensation and benefits; and
- citizenship and work authorization status. Where we request information from you, we will let you know prior to collection whether the provision of the personal information we are requesting is required either by employers as a term of their employment or by law, or whether the information may be provided on a voluntary basis, and the consequences of not providing the information.
Information we collect automatically: We automatically collect certain technical information from visitors to our site(s), such as the Internet protocol (IP) address of their device, their login information, device type and unique identification numbers, browser type and version, time zone setting, browser plug-in types and versions, operating system and platforms. We may also automatically collect certain information about their visits to our site(s), such as download errors experienced and length of visits to certain pages. When you download, install, or use High5 apps, we and our service providers may track and collect certain device-related information (such as your type and device unique ID) and certain app usage data (such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device ID.
- Information we obtain from other sources or third parties: We may receive or acquire information about our visitors, job seekers, customers, and suppliers from third-party partners (such as background check providers) or other third-party sources (such as information from publicly available sites (like Monster.com, CareerBuilder.com, or LinkedIn), or a job seeker’s third-party reference.
- You may also choose to provide us with access to certain personal information stored by third parties, like social media sites. For example, if you register for an account to access some of our sites, you can choose to import your LinkedIn basic profile data (such as your name, experience, location, photo, and contact information). By authorizing High5 to have access to this information, in collecting, storing, and using this information, in accordance with this Privacy Notice, High5 will only pursue the legitimate interests set out below under Use of Personal Information.
- We collect publicly available information from job boards or professional social media websites where career data is made available by individuals and can be viewed by recruiters.
Sensitive Personal Information: In connection with the various services we provide, or if you are applying for a job opportunity with us or one of our customers, you may be asked for types of personal information that are viewed by some countries as sensitive personal information. Sensitive personal information includes, for example, government-issued identification numbers (such as national insurance numbers), information relating to a person’s race or ethnic origin, political opinions or religious or philosophical beliefs, physical or mental health or condition, sexual orientation, trade union membership, genetic data and any related legal actions, or the processing of biometric data for the purposes of uniquely identifying an individual. It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws (collectively “Sensitive Personal Information”).
- Although we aim to minimize the amount of Sensitive Personal Information we process, we may process such information in certain circumstances, such as where we are required to or permitted to do so by law (e.g. information about your racial/ethnic origin, gender, and disabilities for equal opportunity monitoring or affirmative action programs), or where it is necessary to provide you with a service, or if we need to perform a criminal background check, drug/alcohol test or fitness-for-duty testing. If required by applicable data protection laws, we will obtain your express consent to our collection and use of your sensitive personal information.
Use of Personal Information
The personal information High5 collects will be used only as described in this Notice and/or in the way we specify at the time of collection. For the most part, we collect and use personal information to effectively provide to comply with applicable laws and government regulations (such as, to comply with mandatory employment, tax, and insurance requirements).
More specifically, we may use your personal information for the following purposes:
- Providing and administering High5’s services and for internal operations (for example, troubleshooting, data analysis, statistical, and survey purposes);
- Protecting High5 (for example, fraud monitoring, and prevention);
- Responding to your communications;
- Complying with applicable laws and government regulations;
- To fulfil your needs if you are a job seeker:
- Gauging the number of users and usage of the Site(s), so we can plan Site bandwidth and capacity accordingly;
- Recognizing you when you return as a repeat visitor to our Site(s);
- Providing information on goods and services you have requested;
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, services and offerings, enhancing, improving or modifying our Sites, products and services, and operating and expanding our business activities; and
- Notifying you about changes to our Site(s).
Personal information collected online through the High5 sites may also be supplemented with information you provide to us through other High5 services, as well as other online and offline sources (such as recruitment fairs, social media platforms (like LinkedIn), trade shows, or other events) and other data appending methods (such as spot tags, tracking, and cookies as referenced below).
We may also use the personal information we receive for the purposes of creating anonymized and aggregated statistics that do not reveal the specific identity of any person.
In most cases, High5 will process personal information for a variety of business purposes which are in our legitimate interests (for example, to operate its business and provide you with services you have requested), in order to enter into or perform a contract with you and/or for compliance with our legal obligations (as described above). However, in some cases, and always where required by applicable law, High5 will seek your consent to process your personal information (including any Sensitive Personal Information).
Cookies and Online Tracking
High5 websites use “cookies” and similar technologies (like web bugs) to help personalize your online experience and for analytics purposes.
- A cookie is a small data file placed on the hard drive of your computer when you visit certain websites. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited.
- A web bug is a graphic on a web page or email that gathers information about the computers used to view the web page or email. A web bug can collect your computer’s IP address and the time you viewed the website or email.
You can also refuse all cookies and web bugs by turning them off in your browser, although you may not be able to take full advantage of High5 websites if you do so. You do not need to have cookies turned on to use/navigate through many parts of High5 websites, except that access to certain High5 web pages require a login ID and password.
You can find information on popular browsers and how to adjust your cookie preferences at the following websites:
Microsoft Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Google Chrome: https://support.google.com/accounts/answer/61416
Apple Safari: Blocks cookies by default and accepts cookies only from your current domain. To change, click Safari, Preferences, Security, and choose your preference.
Sharing Your Personal Information within High5
High5 may disclose your personal information to any affiliate within the EEA High5 family of companies, for use in accordance with this Privacy Notice. This includes our subsidiaries, affiliates, and our ultimate holding company. This sharing of personal information with High5 affiliates may include combining the personal information gathered by certain High5 Sites with information independently gathered on other High5 Sites as well as information gathered offline into one or more database(s) useable by High5, including all of its affiliates. Again, this combined information will only ever be used for the purposes disclosed within this Privacy Notice.
Sharing Your Personal Information with Third Parties
High5 may share and disclose personal information about you with the following types of third parties and in the following circumstances:
- Potential employers or potential customers – We may share your personal information if you are a job seeker with a customer for the purpose of providing our staffing and recruiting services, or search, workforce management, or talent advisory services. In connection with the above, we may need to disclose certain data about your previous employment (such as your C.V. and corresponding information or to the extent permitted by law, the results of any criminal background checks or other specific employee data such SSN/National ID) with that customer or other service providers or agents acting on our behalf to facilitate and enable the potential placement or employment. To the extent you are employed by a customer of High5 through our search, workforce management, or talent advisory services, the High5 customer will process such personal information in accordance with its own policies and procedures.
- Compliance with laws – We may disclose personal information to a third party where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process, or government requests, including in response to public authorities to meet national security or law enforcement requirements.
- Vendors, consultants, and other service providers – We use third party vendors, consultants, and other service providers to assist us in providing our services, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/C.V. data, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training, occupational health and safety screening, and drug and background screening. In providing these services on behalf of High5, it may be necessary for us to provide these third parties with access to your personal information. In cases of onward transfer to third parties of data of individuals resident in the EEA or Switzerland received pursuant to the EU-U.S. Privacy Shield or the Swiss-U.S. Privacy Shield, High5 is potentially liable under the Privacy Shield Principles if our agents process your personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
- Business transfers – Circumstances may arise where, whether for strategic or other business reasons, High5 decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of personal information to prospective or actual purchasers, or the receipt of it from sellers. It is High5’s practice to seek appropriate protection for information in these types of transactions.
- With your consent – We may disclose your personal information for other purposes with your consent. Your personal information is never sold, rented, or leased to any external company, unless you have granted us permission to do so.
Legal Basis for Processing Personal Information (EEA users only)
If you are a user from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and to communicate with you as necessary to provide our services to you and for our legitimate commercial interest; for instance, when responding to your queries, improving our services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
You may choose to provide your personal information to High5 for a particular position for which you are not successful. In such a situation, as you have indicated that you are looking for opportunities beyond your current role, High5 may retain your personal information in order to present you with other opportunities for which your experience may be suitable. If you have concerns about High5 retaining this data for these purposes, please discuss them with your contact at High5.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the Contacting Us heading below.
International Data Transfers
As a global company, we may transfer personal information to High5 companies and third parties located in the United States and in other countries that may be outside your country of residence for storage and processing in order to provide our services. These countries may not necessarily have data protection laws as comprehensive as those in your country or residence. In addition, we will have taken appropriate safeguards to protect your personal information in accordance with this Notice and applicable law wherever it is processed. These safeguards include implementing the European Commission Standard Contractual Clauses for transfers of personal information between High5 companies and our self-certification to the Privacy Shield Frameworks which are explained in further detail below. Further details of these safeguards can be provided upon request.
EU-U.S. and Swiss-U.S. Privacy Shield Framework
For personal information we receive from the EEA and Switzerland, High5 and its US controlled subsidiary companies have certified their compliance to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the EEA and Switzerland.
We have certified that we adhere to the Privacy Shield Framework Principles of: Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability when processing personal information from the EEA in the U.S.
If there is a conflict between the policies in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To access the Privacy Shield List and to find details of our certification, please visit: https://www.privacyshield.gov. High5 is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regards to our compliance with the Privacy Shield. Residents of the EEA or Switzerland who believe that their information has not been processed in compliance with the Privacy Shield Principles may raise their complaints in a number of ways:
You can contact us directly using the contact details provided below and we will respond to your complaint within 45 days of receipt.
285 Davidson Avenue Suite 406
Somerset, NJ 08873-4153
ATTN: Privacy Officer
We have also committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus (“BBB”). The BBB is a non-profit alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Further, for residents of the EEA, the European data protection authorities (DPA) and for residents of Switzerland, the Swiss Federal Data Protection and Information Commissioner, may refer your complaint to the US Department of Commerce or the Federal Trade Commission for further investigation.
Please note that if your complaint is not resolved through the above methods, under limited circumstances, a binding arbitration process option may be available before a Privacy Shield Panel. To find out more about the Privacy Shield‘s binding arbitration scheme please see www.privacyshield.gov/article?id=My-Rights-under-Privacy-Shield
Your Privacy Rights
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws in certain circumstances, which include the following rights:
- to request access to a copy of your personal information,
- to request rectification or erasure of data held about you;
- to restrict the processing of your personal information; and
- to data portability.
In certain circumstances, you may also have the right to object to the processing of your personal information. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
To protect your privacy and security, we may take steps to verify your identity, such as a password and user ID, before granting access to data. If you are resident in the EEA or Switzerland, we will process any access request you make in accordance with our commitments under the EU-U.S. Privacy Shield or the Swiss-U.S. Privacy Shield.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Marketing Communications: Where it is in accordance with your marketing preferences and applicable data protection laws, we may periodically send you updates via e-mail about promotional opportunities or services we think may interest you, such as jobs in our database that match your selection criteria, newsletters, white papers, surveys and event information. You can opt-out of receiving marketing emails from us. When we request personal information about you, our sites also give you the opportunity to decide which communications you receive.
Security of Your Personal Information
High5 is committed to protecting the personal information you share with us. High5 uses appropriate physical, technical, organizational and administrative security measures to help protect your personal information from unauthorized or unlawful access, use, or disclosure, and from accidental loss, destruction, or damage.
High5 supports online security using secure server technology because we want your data to be safe. We use state-of-the-art security arrangements and facilities on our sites to maintain data security. Unfortunately, the transmission of information via the internet cannot be guaranteed to be 100% completely secure and we cannot guarantee the security of your personal information that is transferred over the internet.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
This site is not intended for use by children under the age of 13. High5 does not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under the age of 13, we will delete that data from our systems.
Links to Other Sites and Public Forums
High5 Sites may contain links to other sites for your convenience and information. If you access those links, you will leave the High5 Site. High5 does not control those sites or their privacy practices, which may differ from High5’s practices. High5 is not responsible for the privacy practices or the content of other websites outside of High5. The personal information you choose to provide or that is collected by these third parties is not covered by this Notice. We encourage you to review the policies of such third parties before submitting your personal information. High5 may make message boards, news groups, and/or public forums available to users on its sites. Any information that you disclose in these areas becomes public information that may be accessed by third parties; therefore, you should use caution before deciding to disclose any personal information in these forums.
If you have any questions about this Notice or if you wish to exercise Your Privacy Rights please contact:
285 Davidson Avenue Suite 406
Somerset, NJ 08873-4153
ATTN: Privacy Officer
Changes to this Notice
If we change this Notice, we will post the revised Notice on our sites, with an updated revision date. If we make significant changes to our Notice, we may also notify you by other means, such as sending an email or posting a notice on our home page. We will update the “Effective Date” at the top of this page to indicate the date from which any changes take effect.
Some High5 services may have additional privacy notices about how such websites, products, and services process personal information. In addition, sometimes High5 acts as a data processor, for example when processing personal information it receives from one of its customers as part of its staffing and recruiting services, including IT staffing and consulting solutions, workforce management or talent advisory services. Any time that High5 acts as a data processor, it will process personal information according to the contractual obligations it has with the applicable data controller. To the extent High5 receives requests from individuals regarding the processing of their personal information by High5, it will refer them to and coordinate with the appropriate data controller.