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Privacy

LAST UPDATED NOVEMBER 2022

The purpose of this Privacy Notice (“Notice”) is to inform corporate and contracted employees (“employees”) of A.B. Closing Corporation DBA Kavaliro (the “Company” or “we” or “us”), of the categories of Personal Information we collect and the purposes for which we use such personal information. This Privacy Notice describes the types of personal information we collect on the Kavaliro website (the “Sites”), how we may use the information and with whom we may share it. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked with a particular individual, and includes the categories and types of information listed below. This Notice is intended to comply with all applicable laws, including but not limited to the California Consumer Privacy Act. If any provision below conflicts with a legal requirement, then the Company will comply with the applicable law.

COLLECTION OF PERSONAL INFORMATION

With respect to visitors of the Site, we collect the following categories of information from your browser or directly from you when you visit our Site:

  1. Internet activity, such as your browsing activity on the Site, your IP address, cookies, installed plug-ins, JavaScript objects, and geolocation data.
  2. Identifiers if you wish to download certain reports like our salary guides, in which case you will need to provide your first and last name, and email.
  3. Professional information if you wish to download certain reports like our salary guides, in which case you will need to provide your job title

With respect to job applicants, candidates, and our employees, we collect the following categories of information from you:

  1. Identifiers, such as your name and contact information (email, address (mailing and home) and phone number), and any login ID or email address and password created by you.
  2. Professional or employment-related information, such as your job search criteria and preferences, your availability to work, your employment experience, educational history, your skills, reference information, background check information, pay / compensation expectations, ability to work in the United States, languages spoken, and other information contained in your resume.
  3. Emergency contact information consisting of full name and phone number.
  4. Information protected against security breaches such as bank information if you work with us and elect to be paid via direct deposit consisting of bank account numbers and direct deposit information.

With respect to customers, we collect the following categories of Personal Information from you or from our service providers such as job boards:

  1. Identifiers such as your name, business phone number, and work email.
  2. Professional or employment-related information such as your company name, department, and job title.
  3. Information protected against security breaches such as bank and payment information if we render services to you, depending on how you elect to pay for services rendered.

With respect to vendors and independent contractors, we collect the following categories of Personal Information from you or Kavaliro’s business contacts who may wish to recommend you:

  1. Identifiers such as your name, business phone number, and work email.
  2. Professional or employment-related information such as your company name, department, and job title.
  3. Information protected against security breaches such as bank account information, so we can pay you for providing products or services to Kavaliro.

With respect to marketing recipients and prospective customers, we collect the following categories of Personal Information from you, from our service providers such as job boards, or from information that is publicly available on the internet:

  1. Identifiers such as your name, business phone number, and work email.
  2. Professional or employment-related information such as your company name, department, and job title.

By providing your mobile phone number to us, you opt in and consent to receive text messages from us, which includes but is not limited to text messages sent through an automatic telephone dialing system. Consent to receive marketing text messages is not required as a condition of working with us. If you do not wish to receive marketing text messages, do not provide us with your mobile phone number.

USE OF PERSONAL INFORMATION

We use Personal Information to register you with the Sites to provide you with information regarding employment opportunities and career-related information, to manage our relationship with you, to develop and carry out marketing activities, and to otherwise provide you with requested information or services. We may from time to time use your Personal Information to send you automated email messages, text messages (message and data rates may apply), or marketing materials regarding our services, including employment information. We may also use Personal Information for our business purposes, such as data analysis, audits, protecting the Site from abuse, and improving our services. Please note that we do not collect from candidates all of the personal information identified below – we only collect and use these records for employees of the Company.

  1. Contact and identification information: such as your name, home and work address, personal and work telephone numbers, personal and work email addresses, photo, physical description, and signature.
    1. We will use this information to open and maintain your candidate profile and employee records, confirm your identity, communicate with you for internal business purposes or emergencies, maintain an internal employee and candidate directory, and grant you access to internal systems.
  2. Job-related information and qualifications: such as position applied for, previous job roles, education, awards, qualifications, certificates, licenses, financial relationships, compensation and salary information, eligibility for and participation in benefit schemes and award programs, and any other information you choose to provide in your resumes and/or applications as well as work anniversary information and skills and experience over the employment period.
    1. We will use this information to assess your personal and professional development, your suitability for job placements, promotions, benefits and other awards, job moves and staff restructuring, conflict of interest reporting, and to fulfill our obligations to regulators (including demonstrating the suitability of employees for their role or the suitability of candidates for particular positions).
  3. National identification information: such as your country of birth or the country where you are a registered national or citizen, and any visa or other right to work.
    1. We will use this information to determine your eligibility to work and fulfill our obligations to relevant government authorities.
  4. Age and benefits information: including your date of birth, social security number, marital status, information about your pension and other welfare benefits, insurance policy information.
    1. We will use this to maintain employment and candidate records and assess your eligibility for and/or pay you any statutory or other benefits to which you may be entitled.
  5. Beneficiaries, dependents, and emergency contact information: information about any beneficiaries, dependents, emergency contacts and next of kin.
    1. We will use this information to maintain your employment records and contact the designated contacts in the case of an emergency.
  6. Financial Information: such as your bank account details.
    1. We will use this information to pay you or provide other benefits and process any expense claims.
  7. Results of background checks and screening: such as education verification, criminal records, and driver’s license checks.
    1. We will use this to determine your suitability for certain job roles (to the extent permitted or required by law) and determine your eligibility for certain benefits (such as a company car).
  8. References: such as opinions and comments of any previous employers.
    1. We will use this to determine your suitability for certain job roles and to fulfill our obligations to regulators (including demonstrating the suitability of employees for their role to regulators and professional bodies).
  9. Salary and benefits information: salary details, bonus payments, pension details, medical insurance, share scheme details, company car scheme details.
    1. We will use this information to allocate resources and process payments of benefits, salary, and any other amounts we owe you.
  10. Performance and development records: training records, records of courses and training undertaken, performance reviews and assessments.
    1. We will use this information for career planning and skills monitoring, assessing your suitability for promotions, job moves, job placements, and staff restructuring, providing references for future applications and fulfill our obligations to regulators (including demonstrating the suitability of employees for their role to regulators and professional bodies).
  11. Disciplinary, capability and conduct records: details of warnings and other records relating to conduct.
    1. We will use this information for assessing and taking action in relation to disciplinary, capability, grievance and conduct issues, maintaining your employment records, monitoring and improving our human resources procedures and processing and fulfilling our obligations to regulators.
  12. Absence records: records relating to time away from the office, including vacation, illness and paternity/maternity leave.
    1. We will use this information to monitor absences and sickness, make decisions relating to human resource allocation, salary and benefit changes and address other issues that may arise from absences.
  13. Information we obtain from monitoring: such as records of your use of our computer systems or the Internet, and recordings from surveillance cameras on our business premises.
    1. We will use this to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism, and damage.
  14. Equal opportunities monitoring information: such as your ethnicity, religion, gender, and sexual orientation.
    1. We will use this to conduct equal opportunity and diversity monitoring where permitted or required by law.
  15. Information regarding your phone or mobile device: such as your mobile phone number and mobile phone or device billing and usage records.
    1. We will use this, in accordance with applicable policies, to reimburse you for use of your mobile phone or device for employment-related purposes.

NO SALES OF PERSONAL INFORMATION

We have not sold any of your personal information in the preceding twelve (12) months.

DISCLOSURE

Disclosure of personal data will only be done in a manner consistent with the purpose for which personal data has been collected.

​For business and commercial purposes, Kavaliro may disclose to third parties the following categories of Personal Information:

  • Identifiers such as your name and email address.
  • Characteristics of protected classifications under California or Federal law such as gender.
  • Internet or other electronic activity information such as network activity information or information obtained from your device like browsing history on the Site, IP address, search history on the Site, your interaction with an advertisement, installed plug-ins, and JavaScript objects on your device.
  • Information protected against security breaches like your direct deposit or bank account information so that workers can be paid, and Customers can pay us.
  • Geolocation data
  • Professional or employment-related information
  • Education information

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​Kavaliro may disclose such Personal Information to the following categories of third parties:

  • Service Providers. We may share Personal Information with our third-party service providers who perform business functions and services on our behalf such as the provider of Kavaliro’s customer relationship management solution.
  • Customers and Prospective Customers. Customers and prospective customers may request professional and employment-related information for purposes of evaluating a Candidate’s credentials, skills and experience. Customers may also need to approve and process timesheet information for Candidates.
  • We may share Personal Information of our Customers or prospective customers to Candidates such as when a Candidate must know information about whom to contact when going on an interview or an assignment with a customer or prospective customer.
  • As required or appropriate by law. We may disclose Personal Information to regulatory authorities, government authorities or courts to comply with applicable laws, the service of legal process, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of Kavaliro or its affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of the users or the public.
  • Business transfers. We also may disclose or transfer information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

COLLECTION AND USE OF OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. We may collect Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, date, and Internet browser type and version. We use this information to ensure that the Sites function properly.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of Site users and email recipients, market our services to you, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
  • Analytics: We use third-party analytics providers such as Google Analytics and HubSpot on the Sites. Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. We have also engaged Inspectlet to analyze the activities of visitors to this Site, and HubSpot’s authorized use of cookies and other tracking technologies enable it to have access to Personal Information of visitors to this Site. Such access to and use of Personal Information by HubSpot is governed by HubSpot’s privacy policy, available at https://legal.hubspot.com/privacy-policy
  • Site Security: We use the reCAPTCHA service provided by Google to protect the Site and your submissions via internet submission forms on this Site. reCAPTCHA uses the following to evaluate your use of the Site: IP address, your device type and information about your device, cookies placed on your device (such as from Google), language and date information, installed plug-ins, and JavaScript objects. Your use of reCAPTCHA on the Site is subject to the Google Terms and Privacy Policy.
  • IP address: Your “IP Address” is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Sites, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Sites. We may also derive your approximate location from your IP Address.

​In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the sites, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We may link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. We also may use third-party website analytics tools that collect information about visitor traffic on the Site. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Site. 

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The providers of third-party apps, tools, widgets and plug-ins on the Site, such as third-party login services and Facebook “Like” buttons, also may use automated means to collect information regarding your interactions with these features. This information is subject to the privacy policies or notices of these providers.

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THIRD PARTY SERVICES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Sites link.

SECURITY

We use reasonable organizational, technical, and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

CHOICES RELATING TO RECEIVING EMAIL FROM US

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by using the mechanism contained in each such email. Otherwise, you may unsubscribe by doing either of the following:

CHOICES RELATING TO SMS TERMS

If you no longer wish to receive marketing-related texts from us on a going-forward basis, you may opt-out by texting “STOP” to us at any time. You may text “HELP” to us or call 407-243-6006 for assistance relating to text messages we send.

USE OF SITES BY MINORS

The Sites are not directed to individuals under the age of eighteen (18) and we do not knowingly collect Personal Information from individuals under 18. If you are a resident of California, under 18 and a registered user of the Sites, you may ask us to remove content or information that you have posted to the Sites by writing to contactus@kavaliro.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

NEVADA RESIDENTS

We do not sell personal information. Nevada residents may email questions regarding our practices relating to personal information to contactus@kavaliro.com

JURISDICTIONAL ISSUES

The Sites are controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States.

ACCESS OR DELETION REQUESTS FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the right, subject to certain exceptions defined in the California Consumer Privacy Act (“CCPA”) and other applicable laws and regulations, to request that Kavaliro disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. You will not receive discriminatory treatment for exercising your rights under the CCPA. If you would like to exercise your rights to make an information access request or a deletion request, please click the applicable links below. In order to verify your request, you will need to provide your legal first and last name, email address you use to correspond with Kavaliro, your relationship with Kavaliro, and the state you currently reside in. After you submit the form, you will need to verify your email by clicking on a “Confirm Email” button in the email we will send you.

If you authorize an agent to make an access or deletion request on your behalf, please have the authorized agent call the toll-free number at 407-243-6006 because Kavaliro will need to verify the authorization before processing the request. The authorized agent will need to submit documentation evidencing your authorization of this agent to make the request and the authorized agent will need to verify their identity with Kavaliro.

To make an online information access request, please click on this link: https://kavaliro.com/contact-us/

To make a deletion request, please click on this link: https://kavaliro.com/contact-us/

You may also make an information access and/or deletion request by contacting us the toll-free phone number at 407-243-6006 by email at contactus@kavaliro.com or postal mail at the address in the “Contact Us” section below.

CONTACT US

Mailing Address:

Kavaliro. Attn: Terms of Use / Privacy Policy

12612 Challenger Parkway Suite 400 Orlando, FL 32826

Email Address: contactus@kavaliro.com

Please note that e-mail communications will not necessarily be secure; accordingly, you should not include credit card information or other sensitive information in your e-mail correspondence with us.