Privacy Policy

Last Update / Effective Date: January 27, 2021

This Privacy Policy (“Policy”) describes the personal information collected by or on behalf of The Infosoft Group LLC, d/b/a Circa and its affiliates (“Company,” “we,” “us,” or “our”) through this website and our affiliates’ websites (“Sites”) and our interactions with you, and how personal information is used, shared and protected.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE SECTION 11 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.

We may modify this Policy at any time. All changes will be effective immediately upon posting to the Sites.

If you use the Sites, you agree to our Term of Use found at https://circaworks.com/terms-of-use/.

1. Categories of Personal Information We Collect

In the last 12 months, we have collected the following categories of personal information and have disclosed the following categories of personal information for our Business Purposes, as defined under the California Consumer Privacy Act of 2018 (“CCPA”)

Contact Information: Identifying and contact information such as name, postal address, telephone number, email address, internet protocol address (“IP Address”), or other similar identifiers.

Demographic Information: Characteristics such as gender, ethnicity, veteran or military status, education level, and citizenship.

Commercial Information: Information voluntarily provided by employers regarding completion of hire.

Internet Activity: Internet or other electronic network activity information for security purposes, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

Geolocation Data: We may collect data regarding your location.

Employment Information: Professional or employment-related information and educational information.

This Policy does not apply to any information that is publicly available.

2. Categories of Sources

We may collect all categories of personal information listed above from the following categories of sources:

Directly From You. We collect personal information that you provide directly to us to create online accounts, contact us via email, phone, or our Contact Us form (where we may retain the content of your message and our response), submit job application materials, receive or request data from us (e.g., newsletters), and respond to surveys.

Marketing Communications. If you opt-in to receive marketing communications from us, you must submit your email address. We use this data to send you promotional and other electronic and hardcopy communications. We may use third-parties or service providers to deliver communications to you. You may opt-out of such marketing emails by using the unsubscribe link in the email. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your account or transactions.

Feedback. When you provide comments or feedback about our Sites, the content on the Sites, or our services (“Feedback”), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

Applying to Work with Company. To submit job application materials online to work with Company, you will be redirected from our Sites to a third-party website. You may be required to create an account with that vendor. We encourage you to review the terms and privacy policy posted on that vendor’s website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with Company and its affiliates.

Live Chat Conversations. If you use our Sites’ chat feature, we will collect all text and other data that you submit via that chat feature. If you use a chat feature, we may collect information about your communication with us.

Professional Information. We collect personal and professional information about you when you upload your resume to our Sites.

We Collect Personal Information Automatically. We automatically collect certain information from you when you access our Sites.

Account Activity. We may collect data about how you use (i) your online account, and (ii) the Sites when you are logged into your account.

Cookies & Other Tracking Technologies.

We may use analytics services, cookies and other tracking technologies (collectively “Cookies”) on our Sites. A cookie is a small text file that a website saves onto your computer or device when you use the Site. We use Cookies to make our Sites function properly, monitor the security of our Sites, help with our marketing efforts, tailor our communications with you and help to improve our Sites and the services we offer. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Sites that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.

What type of information do Cookies collect? The Cookies on our Sites may collect information such as:

  • the IP addresses assigned to electronic devices you use;
  • approximate geographic location;
  • the pages you have visited or clicked;
  • the date and time you visited the Sites, and the amount of time spent on the Sites;
  • your operating system, browser type, search requests, and other similar information;
  • the websites you access before and after visiting the Sites, and
  • data related to how and when you use the Sites.

We may combine information from Cookies with personal information, including data obtained from other sources.

How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Sites. Not all features or functions of the Sites may work properly if you disable Cookies.

Interest-based Advertising. We use service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including our Sites) over time and across different websites.

The data collected by these service providers may be associated with your personal information. These advertisements may appear on the Sites and on other websites and may be sent to you via email.

In particular, we use Google Analytics to collect and process information about your use of the Sites. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Sites.

We may also implement additional add-on services to Google Analytics, such as:

  • Demographics, which gathers information such as the age and gender of users.
  • Remarketing with Google Analytics, which uses user behaviors on our Sites to help us identify users for our remarketing campaigns.
  • Google Display Network Impression Reporting, which provides us information about how often our ads are shown.
  • Google Search Console, which helps us measure the Sites’ traffic and performance, fix issues, monitor, maintain, and troubleshoot the Sites’ presence in Google Search results.
  • Google Data Studio, which allows us to review data in an informative, easy to read, easy to share, and fully customizable dashboards and reports.
  • Google Ads, which we use to serve ads across various websites. Google uses Cookies to collect data about your visits to the Sites to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Sites.

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting out of targeted advertising does not opt you out of all ads, just those targeted to you.

Google Maps. The Sites contain maps provided by third parties and/or service providers for your convenience. Company and such other parties may collect data about how you interact with the maps. For example, Google may collect usage data on maps embedded on the Sites. Even if you do not interact with the maps, Google may still collect certain information about your interactions with our Sites if you are signed into your Google account when accessing our Sites. Please see Google’s Privacy Policy for more information.

We Collect Personal Information From Third-Party Sources. We obtain data about individuals from various third-party companies and public sources and we may combine that data with personal information or other data we collect. This enhances our existing data about our users (e.g., adding address data), improves our ability to contact you, and enhances our marketing capabilities.

3. Purpose for Collecting Personal Information

We may use all categories of personal information listed above for the following business purposes:

To Communicate With You. We may use personal information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use personal information to respond to your questions, comments, or complaints. We may also use personal information as requested or consented to by you.

Administration. We use personal information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, to understand the Sites’ demographics and user preferences, for evaluating applications, and managing profiles.

Site Management. We use personal information for managing our Sites, including troubleshooting problems, improving the content and functionality of the Sites, statistical and other analyses of the Sites, and to customize the Sites to you and our users.

Advertising and Communications. We may use personal information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Sites, to notify you of changes to our Terms or this Policy, and for other similar communications.

To Protect Our Rights. We may use personal information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites. We may also use personal information to seek business, financial or legal advice, in response to requests from law enforcement officials and to respond to other legal requests/Law enforcement.

4. Categories of Third Parties and/or Services Providers with Whom We Share Personal Information

We may share all categories of personal information listed above with the following categories of third parties and/or service providers:

Affiliates. We may share personal information with our affiliates who have a need to know the information for our business purposes.

Service Providers. We may share personal information with companies that provide services for us. For example, we may share personal information with vendors to help us host and manage the Sites; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide public relations; provide email services; provide data processing; and support or provide the security of the Sites.

Customers. We share your personal information with our customers when you apply for a job opening, when you request us to share your information or when you post your resume to our resume database.

Government Officials/Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose personal information: (i) if we believe in good faith we are legally required to disclose that personal information, (ii) if we are advised to disclose personal information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Company or any other party.

Professional Advisors. We may share personal information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Company.

Change in Ownership. In the event (a) Company is subject to a change of control, (b) the Sites change ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide personal information to the subsequent owner(s), including as part of any due diligence process.

Other. We may share personal information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

5. Use and Disclosure of De-Identified or Aggregated Information

Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Company is the sole and exclusive owner of such de-identified and aggregated information, including if Company de-identifies personal information so that it no longer considered personal information under applicable laws.

6. Children

The Sites are not directed at children under 13 years of age. We do not knowingly collect, use, or share personal information from children under 13. If a parent or legal guardian learns that their child provided us with personal information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such personal information.

7. Social Media

We are active on social media, including Facebook, Twitter, YouTube and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our Social Media pages any comments or content that you post on our Social Media pages.

The Sites allow you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Site may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Sites.

Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

8. Data Security

We use commercially reasonable technical and organizational measures to help secure personal information against loss, misuse, and alteration appropriate to the type of personal information processed. If a breach of your personal information occurs, we will notify you of the breach if required under applicable law.

NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

9. Access from Outside the United States

The Sites are intended for consumers in the United States. If you access the Sites from outside the United States, please be aware that personal information may be transferred to, stored in, and processed in the United States.

10. Third-Party Websites

The Sites may link to, or be linked to, websites not owned or controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

11. Terms Applicable to California Residents Only

This Section 11 provides additional terms that apply to residents of California. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for California residents. In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).

For the categories of personal information, we collect and disclose for our Business Purposes, see Section 1 above.

Your Right to Opt-Out of the Sale of Personal Information. California residents have the right to opt out of the Sale of their personal information at any time.

In the last 12 months, we have not Sold your personal information as that term is defined in the CCPA.

Your Rights to Access and Deletion. California residents have certain rights under the CCPA, such as the right to request certain information or request deletion of their personal information. Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:

Right to Request Access. You have the right to request access to any of the following which occurred in the prior 12-month period: (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting or Selling your personal information, (d) the categories of third parties with whom we shared your personal information, (e) the specific pieces of personal information we collected from you and (f) a list of categories of personal information we Sold or disclosed for a Business Purpose in the last 12 months.

Right to Request Deletion. You have a right to request that we delete personal information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

How to Exercise Your Rights of Access and Deletion. To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:

Email: ccpa@circaworks.com

https://circaworks.com/opt-out/

Verifying Your Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use personal information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your personal information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this Section.

Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with Company, and (c) directly confirm with Company that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.

We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.

Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your personal information within the past year for direct marketing purposes, and (b) a description of the categories of personal information disclosed, by contacting us per the “Contact Us” Section below.

CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT RESPOND TO “DO NOT TRACK” REQUESTS.

12. Contact Us

Privacy Contact:
Attn: General Counsel
1000 N. Water St.
Milwaukee, WI 53202
414-278-0700
privacy@circaworks.com

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