Privacy Policy

Last modified: December 1, 2019

1. Introduction

This Privacy Policy describes how Harqen collects and uses Personal Data about you through the use of our Websites, mobile applications, and through email, text, and other electronic communications between you and Harqen.

Harqen, LLC (Harqen or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the websites https://studentselect.ai, https://harqen.ai/, and https://va.harqen.com/login (each, a “Website”), or when you communicate with us through mobile or desktop applications or similar platforms (“Apps”), email, text, or other electronic means of communications, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

Except as set forth above, it does not apply to information collected by:

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or Apps. By accessing or using these Websites and Apps, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of these Websites and Apps after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Data Processor

Harqen is the data processor of the Personal Data you provide on the Websites and/or Apps. Contact information for Harqen is provided at the end of this Privacy Policy.

Harqen is the data processor of your Personal Data. The data controller is the hiring party that advertised the employment opportunity to which you are applying. You may contact Harqen to obtain contact information for the controller of your data. At this time, Harqen is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so. Harqen may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

3. Children Under Age 18

Our Websites and Apps are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites and Apps. We will remove any information about a child under the age of 18 if we become aware of it.

Our Websites and Apps are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Websites or Apps. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Websites or Apps or on or through any of their features, register on the Websites or Apps, make any purchases through the Websites or Apps, use any of the interactive or public comment features of our Websites or Apps or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at support@studentselect.ai.

4. Notice of Recording

If you are participating in an interview on our Websites and/or Apps that involves an audio or video component, it will be recorded and provided to the hiring party that advertised the employment opportunity to which you are applying.

By participating in an interview using our Websites and/or Apps, you acknowledge that you have been informed that you may be recorded as part of the interview process. Further, by participating in an interview using our Websites and/or Apps, you grant your irrevocable consent to Harqen to provide any recording created through your use of the Websites and/or Apps to the hiring party that advertised the employment opportunity to which you are applying, and for any other legal purpose, subject to the terms of this Privacy Policy.

All audio or video recordings of any interview you participate in using our Websites and/or Apps, and any works derived therefrom, shall be the sole property of Harqen or the hiring party that advertised the employment opportunity to which you are applying, as applicable, and you waive any and all rights of publicity, privacy, or other rights therein. You further waive any and all rights to bring an action at law or equity related to such interview(s) against Harqen, its successors, assigns, and licensees, and release them from any and all liability whatsoever.

If you do not agree to the above terms or if you do not wish to be recorded, you should not participating in any interviews using our Websites and/or Apps.

5. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

GENERALLY

We collect several types of information from and about users of our Websites and Apps (“Personal Data”):

We collect this information:

INFORMATION YOU PROVIDE TO US

The information we collect on or through our Websites and Apps are:

The Personal Data we collect from you is required to enter into a contract with Harqen, for Harqen to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and/or Apps and to deliver a better and more personalized service by enabling us to:

COOKIE POLICY

When you visit the Site and App, we ask your browser to store small text files containing a string of alphanumeric characters known as a cookie. Harqen uses both session cookies and persistent cookies. If you have chosen to identify yourself on a Site, we use session cookies containing encrypted information to identify you and facilitate your use of the Site. Session cookies are required to access much of the content and services offered on the Site and App. After you leave our Site and App and close your browser or mobile application, a persistent cookie remains. Persistent cookies can be removed by following your help file directions in your web browser. If you refuse our cookies, some features of the Site and App may not function properly.

6. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

7. Special Categories of Information

We may process some Personal Data considered sensitive when necessary to carry out our obligations under the law or to protect our legitimate interests.

Some Personal Data processed by Harqen on behalf of the controller may be considered sensitive, including personal data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade unions membership, or personal data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions. Harqen processes this information only to the extent necessary to carry out its obligations under the law or to the extent necessary to protect Harqen’s or the controller’s legitimate interests.

8. Automated Recommendation Index

We may process your Personal Data with automated decision making processes. A high-level description of the algorithms we use below.

Our processing of your personal data on behalf of the controller may include automated decision making, including profiling, which may produce a legal effect concerning you or similarly significantly affect you. The algorithms used for our automated decision making assign a recommendation index based on the use of certain words during an interview.

9. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

We use information that we collect about you or that you provide to us, including any Personal Data:

With your consent, we may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Websites and/or Apps and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request at support@studentselect.ai. For more information, see Choices About How We Use and Disclose Your Information.

10. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

We may also disclose your Personal Data:

11. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

12. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data. Please note that in many of the cases set forth below, we will only be able to direct you to the applicable data controller.

13. Do Not Track Signals

We do not track you over time and across other third-party websites or services.

We do not track you over time and across third-party websites or other online services for any purpose.

14. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites and/or Apps confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All data collected will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites and/or Apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites and/or Apps. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites and/or Apps.

15. Consent to Processing of Personal Data in the United States/In Other Countries Outside the European Economic Area

We may process your Personal Data outside of your home country, including in the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.

If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.

Your Personal Data is transferred by Harqen to another country only at the request of the applicable data controller, if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Websites and/or Apps, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Websites and/or Apps. To ensure your Personal Data (other than Personal Data you provide directly to us on our Websites and/or Apps) is treated in accordance with this Privacy Policy, Harqen uses Data Protection Agreements between Harqen and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.

16. Data Retention Periods

Harqen will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:

17. Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Websites. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the primary email address specified in your account and/or through a notice on the Websites’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and/or Apps and this Privacy Policy to check for any changes.

18. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us at the contact information below or through the “Contact” page on our Websites. Please note that questions concerning the processing of your Personal Data will be directed to the applicable data controller.To Contact Harqen (Processor)

Harqen
320 East Buffalo Street
Suite 403
Milwaukee, WI 53202
USA
+1 (414) 755-1962
support@studentselect.ai
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