Privacy Policy
Last Updated: May 22, 2018
Regarding the Collection and Use of Personal Data
The Larry L. Hillblom Foundation, Inc. and its affiliates (collectively “LLHF” “we” or “our”) develop and administer pre-employment assessments, job performance questionnaires, surveys, job simulations, and Virtual Job Tryout™ experiences (our “Services” and “Sites”). Our policy is to respect and protect the privacy of the users of our Services and Sites. This Privacy Policy states our data privacy practices and applies to all users who access our Services or Sites.
BY VISITING OUR SITES, SUBMITTING REGISTRATION OR LOGIN INFORMATION TO ANY OF OUR SERVICES, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY AND ANY RELATED TERMS OF USE. YOUR USE OF OUR SITES OR SERVICES INDICATES YOUR CONSENT TO BE SUBJECT TO THIS PRIVACY POLICY AND YOUR CONTINUED USE INDICATES THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO THE SAME. IF YOU DO NOT AGREE TO BE SO BOUND, DO NOT VISIT OR LOG IN TO OUR SITES OR SERVICES.
We reserve the right to modify this Privacy Policy at any time without notice. For example, we do not need to provide notification if we modify our practices regarding the collection or use of information. We will revise our “Last Updated” date to reflect any revisions to this Privacy Policy. Your continued use of our Sites or Services after any such revision shall constitute your consent to be bound by such revised Privacy Policy.
Collection of Personal Data
We may collect personal data from users of our Services and Sites. Such personal data may include: email address, first and last name, address, country, other contact information, and answers to various questions (e.g., work history, work preferences, personal interests, behaviors, motives, talents, aptitudes, and competencies). LLHF does not collect demographic personal information, such as age, race, and gender, unless a user voluntarily elects to disclose such information through our Services or Sites. Personal data is generally provided directly by the users of our Services and Sites themselves.
LLHF may capture certain information automatically on or through our Sites or Services, regardless of whether a user provides us with personal data. This information may include a user’s device and/or network information (e.g., Internet protocol (IP) address, user agent strings, device identification number (IMEI), geolocation data, browser type, page access history, linking information, click stream data, page visits, page views, and/or website log files). If we identify that a user is accessing our Sites or Services through multiple devices, we may associate each such device with the user’s profile.
We may also use operational data (e.g., cookies, log files, clear GIFs, pixels and/or similar devices) to identify our users and their device(s) in order to track our users’ interactions with our Sites and Services; we use this operational data to enhance certain activities available on our Sites or Services. A user has the right to remove or reject persistent cookies by following the directions provided in the user’s Internet browser’s “Help” file. If a user removes a persistent cookie, such user may be requested to reregister or log in again upon returning to our Sites or Services. If a user rejects persistent cookies, the functionality of our Sites or Services may be impaired or unavailable.
Use of Personal Data
LLHF uses personal data to maintain user accounts and to provide the Services. Personal data collected through our Services and Sites may be provided to our clients so that they can make personnel decisions (e.g., evaluate applicants or current employees, hire applicants, promote current employees, etc.), and when necessary our clients may further disclose such information to their clients. We may also use both personal data and non-personal data (as defined below) for research purposes in connection with the further development of our Services. In addition, a user grants LLHF and its direct or indirect clients the right to process the data submitted and it may be disclosed as part of the Services to LLHF employees, direct or indirect clients, and professional advisors.
This information may also be provided to certain third party technology services providers as necessary to provide our Services. Any such third party technology services providers (which may include software development, application and data hosting, wireless network services providers, and payment processing agents) shall be subject to protecting such personal data, including their compliance the terms of this Privacy Policy.
Except for our third party technology services providers, we will not voluntarily share personal data with a third party without a user’s prior authorization, unless doing so is necessary (1) to enforce this Privacy Policy, to comply with law, regulation or other legal processes or to protect the rights, property or safety of us or others, (2) to comply a valid order or process from a government regulator or law enforcement agency, (3) in emergency situations, (4) to protect against misuse or unauthorized use of the Services, (5) to detect or prevent criminal activity or fraud, or (6) in the event that we or substantially all of our assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, in which case personal data may be one of the transferred assets.
We may use any data that has been de-identified, which has been subjected to pseudonymization or is non-identifiable aggregated data (collectively “non-personal data”). LLHF may use or disclose such non-personal data in its sole discretion.
Security of Personal Data
Data security is implemented through physical, administrative, and technical safeguards we put in place and operational procedures we follow to protect personal data. We protect our users’ personal data transmitted over the Internet using Secure Sockets Layer (SSL) technology, password protected databases. We restrict access to our users’ personal data in our Services or Sites to our authorized employees, our agents, and certain of our authorized partners.
Please note that we do not have any control over or responsibility for information a user shares through any websites outside of our Sites or Services; including any third party websites accessed or linked through our Sites. All such sharing of information and content is done at the user’s own risk; and LLHF makes no representations or warranties that these security measures will prevent a security incident or breach.
Children’s Privacy
The Services and Sites are not intended for use by children under the age of 13. We will not knowingly collect any personal data from users under the age of 13 online through our Sites and Services. If you think that we have collected personal data from a visitor under the age of 13, please contact us.
Contact Us
If you have any questions, comments or concerns about this Privacy Policy or your privacy rights please contact us at support@llhf.org or via the contact information provided in the next section.
Individuals have the right to access their personal data or request limiting the use of their personal data by submitting a request to LLHF through any of the means listed above.
Compliance with Federal and International Regulations
LLHF complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. LLHF has self-certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, LLHF commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact LLHF at:
- support@llhf.org
- (707) 762-6691
- The Larry L. Hillblom Foundation, Inc.
755 Baywood Drive, Suite 180
Petaluma, CA 94954
For any complaints related to the Privacy Shield frameworks that cannot be resolved with us directly, we have chosen to cooperate with the relevant data protection authority for resolving disputes as specified in our self-certification form. Please contact us to be directed to the relevant contacts. As further explained in the Privacy Shield Principles, binding arbitration is available to address residual complaints not resolved by other means. We are also subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).