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STANDARD TERMS AND CONDITIONS OF BUSINESS FOR THE INTRODUCTION OF CANDIDATES FOR BOTH CONTRACT AND PERMANENT HIRES
Company Name: Highventures Executives LLC and its Subsidiaries (“the Company”Or”Highventures’)
Document Topic: Privacy Policy Date: April 2023
Version: Data Protection
Financial year end: 30.12.23
Introduction Definitions What Kind of Personal Data does Highventures collect?
I. Candidate Data II. Client Data III. Supplier Data IV. Individuals whose Personal Data we receive from Candidates and Staff, such as Referees, Emergency Contacts and Dependents
V. Website Users
How does Highventures collect Personal Data?
I. Candidate-related Personal Data
II. Client Data
III. Website Users
Why does Highventures Collect your Personal Data and how is it Used?
I. Candidate Data
Business
Regulations 2003 (“the Conduct Regulations”), as amended. II. Client Data
III. Supplier Data
IV. Individuals whose Data we receive from Candidates and Staff, such as Referees and
Emergency Contacts and Dependents V. Website Users
How do we Safeguard your Personal Data? Who do we Share your Personal Data with? How long do we Keep your Personal Data for? How can you Access, Amend or Take Back the Personal Data that you have given to Us?
I. Right to Object II. Right to Withdraw Consent III. Data Subject Access Request (DSAR) IV. Right to Erasure V. Right to Restrict Processing VI. Right to Rectification VII. Right to Data Portability VIII. Right to lodge a Complaint with a Supervisory Authority
Who is Responsible for Processing your Personal Data on Highventures’s Website? How do we Store and Transfer your Personal Data Internationally? Our Legal Basis for Processing your Data
I. Legitimate Interests
II. Consent III. Establishing, Exercising or Defending Legal Claims IV. To Exercise our Rights or Carry out Employment or Social Security Law Obligations
Cookies Policy How to Contact Us?
Introduction
Highventures Executives LLC (1164 Bishop St, Ste 940 #142 Honolulu, Hawaii 96813 USA) and its Affiliates (“Highventures”, “we”, “us” or “our”) is a Headhunting & Consulting company focused in recruitment and staffing business that sources niche technology, sales, health talents for some of the world’s biggest corporations. Highventures is headquartered in Honolulu, Hawaii 96813 USA. Highventures is committed to protecting the privacy of our Candidates, Clients and Website Users of https:itexo.io in accordance with all data protection legislation, including but not limited to the European General Data Protection Regulations 2016/679 (“GDPR”) as well as other national legislation based on the locations of our offices.
This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
For the purpose of the GDPR, the company responsible for your data is Highventures Executives LLC 1164 Bishop St, Ste 940 #142 Honolulu, Hawaii 96813 USA.
It is important to point out that we may amend this Privacy Policy from time to time. Please check regularly if you want to stay up to date, as we will post any changes here.
This Privacy Policy was last updated in April 2023.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
This Privacy Policy incorporates the highest standards and applies in all relevant countries throughout our international network. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.
Affiliate Candidates
Clients Delete
Definitions
Any holding company and subsidiary of Highventures Executives LLC as defined by the Companies Act 2013.
All Applicants for roles advertised or promoted by Highventures, including permanent, part-time and temporary positions and freelance roles with Highventures's Clients; as well as people who have supplied a speculative CV to Highventures which does not relate to a specific job. Individual contractors, freelance workers and employees of Suppliers or other third parties who put forward for roles with Highventures, Clients as part of an MSP offering or otherwise will be treated as candidates for the purposes of this Privacy Policy.
Highventures’s customers, clients, and others to whom Highventures provides services in the course of its business.
While we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to erase it, some of your personal data may still exist within our Systems, for example, if it is waiting to be overridden. We however ensure that your personal data is “put beyond use”, meaning that while the date technically exists on an archive System, it cannot be readily accessed by any of our operational Systems, processes or members of Staff. Further, it may be necessary for Highventures to retain personal data for legal, regulatory, risk management and/or auditing purposes.
General Data Protection Regulation (GDPR) A European Union statutory instrument which aims to harmonize European data protection laws. It came into effect on 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
Managed Service Provider (MSP) Clients' outsourcing of the management of external staff (including freelance workers, independent contractors and temporary employees) to an external provider.
Recruitment Process Outsourcing (RPO) services Full or partial outsourcing of the recruitment process for permanent employees to a recruitment provider.
Staff
All current and former employees and interns engaged directly in the business of Highventures (or who have accepted an offer to be engaged) as well as certain other workers who are or were engaged in the business of providing services to Highventures (even though they are not classed as employees). For these purposes we also include employees of Highventures who are engaged to work on Clients' premises under the terms of RPO or MSP agreements. For the avoidance of doubt, 'Staff' does not include individuals hired by Highventures for the purpose of being placed with Clients outside of an RPO/MSP arrangement. These individuals are treated in the same way as Highventures's Candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for Highventures fall within the definition of a 'Supplier' for the purposes of this Privacy Policy.
Partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Highventures. In certain circumstances, Highventures will sub-contract the services it provides to Clients to third- party suppliers who perform services on Highventures's behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Highventures requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
Telephone, computer, internet and Wi-Fi systems, software and portals, accounts and/or networks belonging, controlled or used by Highventures that are used to transmit, undertake and/or receive communications or are otherwise used in the course of Highventures's business, including candidate portal software and CRM systems.
Any individual who accesses any of the Highventures’s websites.
What Kind of Personal Data does Highventures collect?
Suppliers
Systems
Website Users
The below information is in addition to any personal data Highventures is required by law to process in any given situation.
I. Candidate Data
Depending on the relevant circumstances and applicable local laws and requirements, Highventures may collect some or all of the information listed below to enable us to offer you employment opportunities tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions:
(whether you need a work permit);
II. Client Data
Highventures only collects a very limited amount of Client data. This usually entails
III. Supplier Data
Highventures only collects a very limited amount of Supplier data. This usually entails
IV. Individuals whose Personal Data we receive from Candidates and Staff, such as Referees, Emergency Contacts and Dependants
V.
Information we receive from Referees is only a confirmation of Candidate or Staff personal data we already have on file. We further store names and contact details about the referees.
Information we receive concerning emergency contacts usually contain names and contact details.
Information concerning dependants usually includes names, date of birth, contact details and potentially some health information if a member of our Staff has put you down as a dependant or any other kind of beneficiary for a benefit connected with their employment or if a member of our Staff exercises certain employment rights.
Please note that the above list of categories of personal data we may collect is not exhaustive.
Website Users
Highventures only collects a very limited amount of Website Users data. The data help us to improve your experience when using our website and help us manage the services we provide.
The data we collect include
I. Candidate-related Personal Data
We collect Candidate-related personal data in two primary ways:
may be shared with us by the providers.
Please note that the above list of categories of personal data we may collect is not exhaustive.
II. Client Data
We collect Client-related personal data in two ways:
1. Personal data you provide us with
In order to provide you with the best service possible and successfully help you with your staffing requirements, we may receive data directly from you in two ways:
consultants’ business development activities more generally.
2. Client-related Personal Data to the we receive from other Sources
Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources, generally by way of due diligence or other market intelligence including:
III. Website Users
We automatically collect certain information from our Website Users, whether or not they decide to ultimately use our services. These include:
I. Candidate Data
We generally use Candidate Data in five ways:
1. Recruitment Activities
Highventures’s main business activities relate to recruitment – i.e. finding the right position for our Candidates. Where appropriate and in accordance with local laws and requirements, we use and process your personal data as follows:
2. Marketing Activities
We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. Sending you marketing information may help to:
Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.
If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
3. Equal Opportunities Monitoring
We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) collect about you comes under the umbrella of "diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with local laws and requirements, we'll use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.
This diversity information is what is called ‘sensitive’ or 'special category' personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
We may collect other sensitive/special category personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions if this is appropriate in accordance with local laws and is required for a role that you are interested in applying for. We will never do this without your explicit consent unless we have another valid legal basis to do so.
Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive/special category data.
If you are not happy about this, you have the right to withdraw your consent at any time.
4. Establishing, exercising or defending Legal Claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
5. In relation to the Conduct of Employment Agencies and Employment Business Regulations 2003 (“the Conduct Regulations”), as amended.
We may collect your data for internal record keeping in relation to the Conduct Regulations, as amended. If applicable, we are obliged to keep a record of your information for a period of at least one year after the date on which we last provided services to you in the course of our business.
II. Client Data
We generally use Client Data in three ways:
1. Recruitment Activities
Highventures’s main business activities relate to recruitment through
In order to facilitate this, we are storing your data in the following ways:
2. Marketing Activities
Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address. If you are not happy about this, you have the right to opt out of receiving marketing materials from us. Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities.
3. Establishing, exercising or defending Legal Claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
III. Supplier Data
We will only use your information:
to store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements; to offer services to you or to obtain support and services from you; to perform certain legal obligations;
to help us to target appropriate marketing campaigns; and in more unusual circumstances, to help us to establish, exercise or defend legal claims.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address. f you are not happy about this, in certain circumstances you have the right to object. Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements.
IV. Individuals whose data we receive from Candidates and Staff, such as Referees and Emergency Contacts and Dependents
We will only use the information that our Candidate gives us about you for the following purposes:
V. Website Users : Organizations whose data we receive from Clients or Third parties or Recruiters or Hiring companies
How long do we keep your Personal Data for?
We reserve the Delete your personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for three years (or for such longer period as we believe in good faith that the law or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. When we refer to "meaningful contact", we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services. If you are a Candidate, we will consider there to be meaningful contact with you if you submit your updated CV onto our website or take part in any of our online training. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact – this will only occur in cases where you click-through or reply directly.
How can you Access, Amend or Take Back the Personal Data that you have given to Us?
One of the GDPR's main objectives is to protect and clarify the rights of EU-citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
I. Right to Object
This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our Website Users, Candidates, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
II. Right to Withdraw Consent
Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
III. Data Subject Access Request (DSAR)
You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify
your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws.
IV. Right to Erasure
You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
V. Right to Restrict Processing
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either:
(i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU- or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
VI. Right to Rectification
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
VII. Right to Data Portability
You further have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Highventures account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to:
(i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
VIII. Right to lodge a Complaint with a Supervisory Authority
You also have the right to lodge a complaint with your local supervisory authority.
If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You may ask to unsubscribe from job alerts and any other marketing communications from us at any time. Please reach out to us via the contact details on our website.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
Who is responsible for Processing your Personal Data on Highventures’s Websites?
The Highventures entity responsible for processing the personal data of Highventures and Itexo.io Website Users, Candidates, Clients and Suppliers depends on where you use Highventures’s services or supply Highventures with services.
The legal entity responsible for processing the personal data of Website Users of Itexo.io and all its websites, Candidates, Clients and Suppliers in the USA is Highventures Executives LLC.
How do we Store and Transfer your Personal Data Internationally?
In order to provide you with the best service and try to carry out the purpose described in this Privacy Policy, your data may be transferred:
Our Legal Basis for Processing your Data
We process your data in on one or more out of the following legal bases:
I. Legitimate Interests
Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it "is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone's a winner! However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please see above.Please note that in certain of the jurisdictions in which we operate, a different legal basis for data processing might apply in certain cases.
1. Candidate Data
We think it is reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it is looking like you may get the job, your prospective employer may also want to double check any information you have given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.We want to provide you with tailored job recommendations and relevant articles to read to help you on your job hunt. We therefore think it's reasonable for us to process your data to make sure that we send you the most appropriate content.We also think that it might help with your job search if you take part in our specialist online training or some of our more interactive services, if you have the time. These are part of our service offering as a business, and help differentiate us in a competitive marketplace, so it is in our legitimate interests to use your data for this reason.We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.We have our own obligations under the law, which it is a legitimate interest of ours to insist on meeting! If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
2. Client Data
To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.
3. Supplier Data
We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.
4. Individuals whose Data we Receive Candidates and Staff, such as Referees and Emergency Contacts
If you have been put down by a Candidate or a prospective member of Staff as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.If a Candidate or Staff member has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.
II. Consent
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.Article 4(11) of the GDPR states that (opt-in) consent is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." In plain language, this means that:
We will keep records of the consents that you have given in this way.We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to the recruitment services we provide to you as long as you do not actively opt-out from these communications.Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding consenting to receive marketing materials.As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found further above.
III. Establishing, Exercising or Defending Legal Claims
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity".This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
IV. To Exercise our Rights or Carry out Employment or Social Security Law Obligations
For some Candidates, and for individuals whose personal data is provided by Candidates and Staff, it will sometimes be necessary for us to process your sensitive/special category personal data. Article 9(2)(b) of the GDPR allows us to do this where the processing is "necessary for the purposes of carrying out the obligations and exercising [our or your] specific rights... in the field of employment and social security and social protection law", as long as this is allowed by law.
We process Candidates sensitive/special category personal data for the purpose of ensuring our compliance with our equal opportunities obligations where this is in accordance with local law, (for example, for some Candidates during the course of the recruitment process). We may also process the sensitive/special category personal data of individuals connected with Candidates or Staff for other reasons, for example to allow the relevant Staff member to access certain benefits or employment rights. You can find out how we process your sensitive/special category personal data under "What Kind of Personal Information Do We Collect?" above.
Cookies Policy
Please refer to our Cookie Policy which can be found on our website in reference to
While we hope there is no need to, if you would like to complain about our use of your personal information, please send an email detailing your complaint to our Data Protection Officer at the following address:
Hicham GHARIB,
HIGHVENTURES EXECUTIVES LLC
1164 Bishop St, Ste 940 #142Honolulu, Hawaii 96813USA
We take privacy seriously so we will get back to you as soon as possible.
Alternatively, you can send an email to:
hicham.gharib[@]highventuresexecutives.com
Signed for and on behalf of Highventures Executives LLC.
1164 Bishop St, Ste 940 #142 Honolulu, Hawaii 96813, United States.
By M. Hicham GHARIB
Title: CEO, Managing Director.
Date: 23rd of April, 2023.
We love our customers, so feel free to visit during normal business hours.
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