Privacy and Cookie Policy

Effective January 25, 2022

 Overview and scope

This privacy policy addresses how Phenom People, Inc. (“Phenom People'', “we”, “us”, “our”) collects, uses and discloses your personal information while on our sites owned or operated by us at www.phenompeople.com, and our platform (the "Site"), and in connection with the services provided by us (the "Service", the "Phenom People Service").

This privacy policy does not relate to any personal information that Phenom People collects on behalf of, or under the direction, of its Clients. When you log on to the Site you will have access to the privacy policy of the prospective employer that is a client of Phenom. This privacy policy should explain how they process your personal information and your rights in relation to such information. We may be asked by our Clients to amend, update, or delete your personal information on behalf of our Clients in which case we will do so in accordance with the terms of our contract with our Clients.

This policy also explains what cookies are used on the Site (see below for further details in the cookie policy).

1. The personal information that we collect and use

The information that we collect directly from you includes your name, email address, and phone number that you provide when you use our Service. If you choose not to provide the information requested it may limit the ability of Phenom People to provide you with a specific service or particular content.

We also collect certain information about you and your device in accordance with our cookie policy.

We do not actively request or collect special categories of personal information unless you provide this to us when you use our Site and Service.

2. How we use your personal information and the basis on which we use it

We use your personal information to:

provide our Site and Services e.g. allow you to request a demo and complete a job application. deal with your enquiries and requests. verify your identity. contact you in connection with your use of the Site and Service.

contact you with marketing and offers relating to products and services offered by us (unless you have opted out of marketing, or we are otherwise prevented by law from doing so).

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

to fulfil our contractual obligations to you, for example to provide the Site and Service.

to meet our legitimate interests, for example to understand how you use our Site and Services and to enable us to derive knowledge from that to enable us to develop new services, such as for the purpose of fraud monitoring and prevention, audits, and to promote the safety and security of the Site. When we process personal information to meet our legitimate interests we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, cookies and tracking technologies or when we process sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy policy.

3. Your rights over your personal information

In certain countries (for example in the UK and EU) you may have the right under applicable local law to request access, change or delete certain personal data that we hold in relation to you, or to object to or restrict the processing of certain personal information, receive personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability), and lodge a complaint with a local data protection authority.

We will contact you if we need additional information from you in order to honor your requests.

If you want to update the information that we hold about you or if you no longer desire our Service, you may correct, delete inaccuracies, or modify the information we hold by send an inquiry using our online Privacy Webform Given the nature of the services that we provide we may have shared your personal information with employers and other third parties. You may need to make requests to such third parties in accordance with the instructions in their privacy policies if you require them to update the records that they hold about you.

If you want to discuss or exercise any of your rights under this policy, please contact our online Privacy Webform.

4. Information Sharing

We may share your personal information with third parties under the following circumstances:

Phenom People Clients: Phenom People works with Clients to provide the Service. Information about your use of the Service and visits to the Site may be shared with the specific Client for which you visited the Site and to which you subscribed. Clients using Phenom People Services to attract job applicants may receive or access your personal information in conjunction with their use of the Services.

Service providers and business partners: We may provide your personal information to companies that provide services to help us with our business activities, such as sending emails or SMS text messages through the platform, live help feature or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy policy.

5. Information Security and Storage

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information and include the encryption of personal information using secure socket layer technology. We evaluate these measures on a regular basis to ensure the security of the processing.

6. International Data Transfer

Your personal information may be transferred to, stored, and processed in a country other than the one in which it was provided, which may not be regarded as ensuring an adequate level of protection of your personal information under applicable law. When we do transfer your personal information we put in place appropriate safeguards (such as standard contractual clauses) in accordance with applicable data protection laws. For more information on the appropriate safeguards in place, please contact us using the contact details set out at the end of this privacy policy. 

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Phenom People participates in and has certified its compliance with the EU-U.S. and the Swiss-U.S. Privacy Shield Framework.  Phenom People is committed to subjecting all personal data received from the European Union (EU) member countries, the United Kingdom and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://ww w.privacyshield.gov/list]

Phenom People is responsible for the processing of personal data it receives, under the Privacy Shield

Framework, and subsequently transfers to a third party acting as an agent on its behalf.  Phenom People complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the United Kingdom and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework,

Phenom People is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Phenom People may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshi eld.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.  

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedb ack-form.truste.com/watchdog/request.

7. Changes to this policy

We may update this privacy policy from time to time. If we make any material changes, we may notify you by email (sent to the email address specified in your account), by means of a notice on this Site prior to the change becoming effective, or by posting the updated privacy policy on this Site. We encourage you to periodically review this page for the latest information on our privacy practices.

8. Contact Us

If you have a question about this privacy policy, or wish to inquire about our personal information handling practices, please contact us as follows:

Phenom People, Inc.

300 Brookside Avenue

Building 18, Suite 200

Ambler, PA 19002

or use our online Privacy Webform

Cookie Policy

1. What are Cookies?

We use the term 'Cookies' to refer to all technologies which store and access information on the device that you use to access the Site, such as your computer, tablet, or mobile phone. For example, we use http cookies, which are small data files (typically made up of numbers and letters) that are downloaded when you access our Site and allow us to recognize your device.  We also use technology like pixel tags, which are embedded in our Site.

We use Cookies to help us to enhance the online experience of our visitors and to better understand how the Site is used. For example, Cookies may tell us whether you have visited the Site before or whether you are a new visitor.

Our Site uses first party cookies (i.e., cookies set directly by us to your device) as well as cookies served by third parties on our behalf for example by data analytics companies. Some of the cookies the Site uses only remain on your device while your browser is open (these cookies are known as 'session cookies'). We use session cookies to make it easier for you to navigate our site. Other cookies on the Site remain for longer periods (these are known as 'permanent cookies').  We set a persistent cookie to store your password, so you don’t have to enter it more than once. Persistent cookies also enable us to enhance your experience on our Site.

2. Which cookies do we use and why do we use them?

The Site uses the following cookies:

As is true of most web sites and apps, we gather certain information automatically 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 send you push notifications from time-to-time to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

3. How can you exercise your Cookies choices?

If you do not want the Site to collect information using cookies, you can set your web browser to reject cookies from the Site. Each browser is different, so you should check your browser's "Help", "Tools" or "Edit" menu/facility to learn how to change your cookie preferences.  For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, please visit www.all aboutcookies.org and www.youronlinechoices.eu.

If you reject cookies, you may still use the Site, but the Site may not function as intended. For example, you cannot register for the Talent Community to receive future email alerts when jobs of interest to you become available.

4. Contact us

If you have any questions about our use of cookies, please contact us at 888-985-7755 or email us at support@p henompeople.com.

APPLICABLE ONLY TO USERS LOCATED IN CALIFORNIA AND NEVADA

Privacy Notice for California, Nevada, and Delaware Residents

The California Consumer Privacy Act of 2018 (“CCPA”), and its implementing regulations, as well as Nevada Revised Statutes Chapter 603A.300 et seq and Delaware Online and Personal Privacy Protection Act, require us to make certain disclosures regarding our privacy practices.   

This Privacy Notice applies to personal information of California and Nevada residents that we collect, use, and disclose on the Site as part of the Service.  Phenom employees are subject to a separate privacy policy

For the purposes of this section only, “personal information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

Collection, Use, and Disclosure of PI

As previously stated in our privacy statement, we may hold data on you in our role as a service provider to a client company, and we may hold data about you on our own behalf. We collect, use, and disclose personal information as follows.

Categories of Personal Information We Collect

Identifiers: name, postal address, online identifier, internet protocol address, email address, phone number. Commercial information: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other electronic network activity information: browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement

Audio and Video: if you visit our facilities that employ CCTV, we may capture your likeness on video as you pass through secured areas.

How We Collect Personal Information

We have collected the above categories and types of personal information directly from individuals through our website or during customer support contact, directly from our business customers, and through business documents such as our contracts and other shared documents. We also collect personal information automatically using cookies and similar trackers. Please see above for our Cookies Policy for further details.

How We Use Personal Information

We may use your personal information for the following business purposes:

providing the Service to our business customers. fulfilling your requests.

communicating with you about our Services or the Site; conducting business together. protecting our legal interests and abiding by our legal obligations. protecting the security of our systems and facilities. analyzing our business and web site performance; and marketing to you (with your consent, as required by applicable law).

How We Share Personal Information

We may disclose your personal information with third parties for a business purpose.  These third parties include analytics providers and other service providers under contract to us. These service providers are prohibited from using your personal information except at our direction. We may also disclose your personal information to government entities or other third parties associated with legal or tax requirements, or in the case of a proposed merger, acquisition, asset sale, or other corporate transaction.

Your Choices

Please refer to the Contact Us section above if you would like to update their information on the Phenom platform

The Site does not currently respond to “Do Not Track” signals.

Your Rights as a California Resident

If you are a California resident, you have certain rights (subject to certain limits under California law), such as:

Right to Know and Right to Request Information

You may have the right to request that we disclose what personal information we collect, use, disclose or sell. You have the right to request information about the personal information we’ve collected about you within the last twelve months.  You may request to know if we have collected, sold, or shared with third parties for a business purpose the following information:

The categories of personal information we have collected about you;

The categories of sources of personal information we collected about you;

Our business or commercial purpose for collecting or selling personal information about you;

The categories of third parties with whom we share personal information;

The specific pieces of personal information we have collected about you;

Whether we have sold your personal information and if so the categories of personal information that each category of recipient purchased; and

Whether we have disclosed your personal information for a business purpose and if so, the categories of personal information that each category of recipient received.

You may request this information no more than two times per year.

Right to Request Deletion

You have the right to request that we delete the personal information we have collected about you. Under certain circumstances we may be unable to delete your personal information; for example, to comply with legal obligations, or for our legitimate business purposes.  

Right to Opt-Out of the Sale of Personal Information

The CCPA provides California residents the right to opt out of sales of their personal information to third parties. We do not engage in sales of personal information and have not sold the personal information of California or Nevada residents in the preceding twelve months. We also do not sell the personal information of minors under the age of 16 years of age.  This fact notwithstanding, you can submit a request to be opted out of any future data sales by sending a request using our online Privacy Webform.

Right to Non-Discrimination

You have a right not to receive discriminatory treatment for exercising your privacy rights under the CCPA.

To exercise your rights as a California resident, you may make a request in the following ways:

Using the online Privacy Webform; or

Calling our toll-free number at 1-800-501-4049

When you submit a request, we will verify your request and identity, and we reserve the right to take additional steps necessary for verification.  For example, we may seek to establish your identity by requesting additional information from you that we can match with information that we have in our records.

You may designate an authorized agent to make a request to know or a request to delete your personal information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly.  We will deny any requests from agents that do not submit proof of authorization.  Requests submitted via authorized agents will be subject to similar verification processes as direct requests.

 If you wish to exercise your rights pertaining to the personal information we may hold about you as a service provider to a client company, please direct your request(s) to that company.

Changes to this policy

We may update this privacy policy from time to time. If we make any material changes, we may notify you by email (sent to the email address specified in your account), by means of a notice on this Site prior to the change becoming effective, or by posting the updated privacy policy on this Site. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have a question about this privacy policy, or wish to inquire about our personal information handling practices, please contact us as follows:

Phenom People, Inc.

300 Brookside Avenue

Building 18, Suite 200

Ambler, PA 19002

or use our online Privacy Webform