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Effective December 1, 2020
If the provisions any federal, provincial, state or local laws establish higher or other standards for the protection of Personal Information, those laws will take precedence.
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Website, your transmission is at your own risk
ICT collects information that personally identifies or relates to you (“Personal Information”) which may include the following:
The Personal Information we collect will vary depending on how you use the Website and our relationship with you. We may require this information to properly serve you or to improve our service to you.
We also automatically collect aggregate and other information in connection with the use of our Website. This information may include the type of web browser you use, the type of device you use, your operating system and version, the pages you view, the frequency and duration of visits, the date and time of visits, and other such information. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as data on usage of our Website.
ICT uses these types of cookies:
We also use technology that enables us to track certain characteristics of a user’s visit to the Website. This helps us to manage our Website by providing us with information as to the effectiveness of content, and how visitors arrive, depart and engage with the Website. The technology usually involves either (1) “tracking pixels” (executable code embedded in a web page to track usage activity including pages viewed, and when and how long they are viewed), and (2) “clear gifs.” (tiny graphics with unique identifiers embedded in web pages or email messages that track whether or not a user has viewed a particular web page or email message). This user activity information may be associated with additional information about a user’s Website session and Personal Information (if provided by the user).
Our Website includes social media features, such as the Facebook and LinkedIn widgets, which may collect information about your IP address and the pages you visit on our Website as well as other Personal Information. A cookie may be set to ensure that such features properly function. Any interactions with such features are governed by the privacy policies of the companies that provide them.
The Website may contain links to third party websites (including social media platforms as noted above). Please be aware that if you access these links, you will be leaving our Website. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.
Also, certain third parties may collect Personal Information and/or information on usage from users of our Website through automatic information collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or information on usage by these third parties is governed by their privacy policies.
We use Personal Information for business purposes including:
We may provide your Personal Information to third parties who provide services to us or to you on our behalf in areas including:
We require that service providers use Personal Information that we provide to them only as specified by us, and they are expected to use reasonable security measures to protect your Personal Information.
If you provide a testimonial, we may post it publicly on the Website or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email, products and services email, or email about your use of the Website. We may receive a confirmation when you open an email from us. ICT uses this confirmation to improve the Website and our services. When you receive e-mail from ICT, you can opt out of receiving further e-mails by following the included instructions contained therein to unsubscribe
We may collect Personal Information when you apply for employment with any affiliate in the ICT group through the Website. This information may include name, education and employment background, contact information, job qualifications, and jobs for which you may wish to be considered, and may include additional information such as your resume or CV, employment references, and salary requirements. Your provision of any information to apply for employment with ICT is voluntary. This information is collected and maintained by ICT as necessary for employment decisions. We may also collect publicly available information, such as information you post on public social media accounts, or information related to your education, employment history or qualifications for employment (for example, information collected from references, through background checks, etc).
We use Personal Information collected in connection with applications for employment to: (i) evaluate candidates, including carrying out background checks and drug screening, checking references, employment history, and employment eligibility; (ii) communicate with you and respond to your application; (iii) enable your use of our Website; (iv) analyze, develop, improve and maintain the security of our Sites; and (v) comply with applicable laws and regulations.
Where you have provided Personal Information for the purposes of potential employment with ICT, you agree that ICT and third parties who perform support services for ICT, may use the information submitted for the purpose of processing your application. ICT may also use your Personal Information to notify you of job openings within ICT which may be of interest to you. The information you provide on the application form will be kept on file by ICT in our CV management system for a period of six (6) months from the date of submission. If after that period no job has been matched to the information you provided, your personal information will be deleted from our database. If you are contacted directly by ICT’s human resources department after the date of submission of your CV, ICT will be bound by the relevant legislation regarding the retention of your CV on its database during the period when it is considering hiring or employing you and if you are employed, during your employment period.
As a condition of receiving ICT products or services, we may require you to pay in advance by credit card or debit card. By providing credit card or debit card information to ICT (“Card Payment Information”), you are expressly agreeing that we are authorized to keep such Card Payment Information on file and charge you the fees, charges, or other amounts owing for the products or services provided to you by ICT. When you provide Card Payment Information, our system will attempt to verify the information you entered. We do this by processing an authorization hold, which is a standard practice. We do not charge you in connection with this authorization hold.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate (i) to respond to legal requests (including court orders, investigative demands, and subpoenas), (ii) to protect the safety, property, or rights of ourselves, consumers, or any other third party, (iii) to prevent or stop any illegal, unethical, or legally actionable activity, (iv) or to comply with law.
For Canadian residents, Personal Information about you may be stored or processed in or outside Canada. The information will be protected with appropriate safeguards and comparable levels of protection as required by the laws of Canada and of any province or territory of origin, but may be subject to the laws of the jurisdiction where it is held in addition to being subject to the laws of Canada and the applicable laws of any province or territory of origin.
ICT will only retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected unless we are required to retain the Personal Information in order to meet our legal and regulatory requirements. In all cases our need to use your Personal Information will be assessed on a regular basis and information that is no longer required will be securely deleted. Employment Applicant Information is retained as set out in Section 5 above.
If you are a resident of California, you have additional rights to access and control your Personal Information under the California Consumer Privacy Act (“CCPA”).
A) Application of this Section 10
B) Your CCPA Rights
California residents have the following rights regarding their Personal Information:
To exercise any of these rights, please submit a request to email@example.com or call __________________. You must describe your request with enough detail so we can understand and respond to it. A verifiable consumer request is one made by an individual who is: (i) the consumer who is the subject of the request; (ii) a consumer on behalf of the consumer’s minor child; or (iii) by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer. We may request that you provide us with information to verify your identity and/or authority to act on behalf of a consumer. Personal Information collected to determine whether your request is a verifiable consumer request will not be used for any other purpose. We will respond to your request within 45 days of its receipt, unless we notify you that we need more time.
C) California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Website does not respond to “do not track” signals.
11. Your Choices
You can always opt not to disclose Personal Information even though it may be needed to take advantage of or to register for certain features of the Website, our products or services. You are able to add to or update information on certain Website pages as shown on those pages. When you update information, however, we often maintain a copy of the unrevised information in our records. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
You may request deletion or inactivation of your ICT account by sending an e-mail to __________________. Please note that some information may remain in our records after deletion of your account.
If you do not wish to receive email or other mail from us, please indicate this preference during the registration process, by changing your account settings, or by notifying us at the following address: ___________________________________.