Version: September 15, 2017

This Privacy and Cookies Policy applies to the website www.cielotalent.com (the “Site”) which is owned by Cielo, Inc. (“Cielo”, “we”, “us”, “our”) of 200 South Executive Drive, Suite 400 Brookfield, WI 53005 for itself and for other Cielo companies.

Cielo recognizes the importance of honest and responsible use of your personal information. This Privacy and Cookies Policy (the “Policy”) explains how Cielo collects, uses and discloses personal information about you when you visit this Site and when you contact Cielo, whether by e-mail, post, fax or telephone using the contact options on this Site.  The information you provide to us through the Site will initially be collected by Cielo, but may then be shared with other Cielo companies.  All references to “Cielo” in this Privacy and Cookies Policy therefore include Cielo and its group companies (the “Group”), unless stated to the contrary.  

Depending upon your relationship with Cielo, we may also provide you with further separate details about our use of your personal information, for example where you apply for a job with us online you will be provided with our Online Recruitment Privacy Notice.  Those notices would apply to our collection and use of your personal data for purposes other than the operation of this Site.

1. What types of information does Cielo collect and why?

1.1              When you visit our Site, we may collect:

1.1.1           information about your Internet service provider, your operating system, browser type and/or domain name;

1.1.2           the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device); and

1.1.3           your access time(s).

1.2            This information helps us to understand which parts of the Site are popular or need changing.  We do not retain this information in a manner that is attributable to you as an individual and this means it is not your “personal data” (as described below). 

1.3            If you use our Site search facility, queries and results are logged anonymously without any user specific details being collected. Our collection of website use information may also involve the use of cookies and web beacons.  Please see the Cookies section below for more information.

1.4            If you want to contact us or to use certain facilities we provide on this Site, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application.  This information (either on its own or in combination with other information we hold about you) may allow us to identify you as an individual.  This type of personal information is called “personal data”.  If you do choose to provide us with your personal data, we will collect that information for the purposes described in this Policy.

2. What type of personal data does Cielo collect?

2.1            Where you choose to provide it to us, we may collect the following personal data from you:

2.1.1           your full name;

2.1.2           your work and/or home contact details e.g. company name, job title, address, postal code, country, fax number, telephone numbers and/or e-mail address;

2.1.3           other company information e.g. number of employees and industry sector;

2.1.4           the reason for your contact such as a query in respect of a job application or information about our products and services;

2.1.5           (subject to your consent where necessary under applicable law) information about services that interest you;

2.1.6           information necessary for legal compliance; and/or

2.1.7           where you “like” us or make posts on our pages on social networking websites. 

2.2            We only collect personal data from you that is relevant for the purposes for which it is to be used.

2.3            This information will be collected primarily from you but we may also collect it, where lawful to do so, from (and combine it with information from) public sources, third party service providers, government, tax or law enforcement agencies, and other third parties.  We may also collect personal data about you from your use of other Group services.

2.4            If we collect sensitive information from you (i.e. personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), we will give you the affirmative or explicit (opt in) choice if the information is to be (1) disclosed to a third party or (2) used for a purpose other than those for which it was originally collected or subsequently authorized.

3. How does Cielo use your personal data?

3.1            We may use information about you:

3.1.1           to respond and/or deal with your request or enquiry;

3.1.2           to improve our products and services;

3.1.3           to administer the Site;

3.1.4           for internal record keeping;

3.1.5           to contact you (directly, either by Cielo or by the Group or through a relevant partner or agent) by e-mail, post/mail or phone for the above reasons;

3.1.6           subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing;

3.1.7           where necessary as part of any restructuring of Cielo or sale of a relevant Group company’s business or assets;

3.1.8           to perform any contract Cielo has with you; and

3.1.9           for compliance with legal, regulatory and other good governance obligations.

3.2            This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate.  

3.3            Subject to applicable law, we may also process your personal data for other legitimate business purposes including management analysis, audit, forecasts, business planning and transactions, ensuring our compliance with applicable laws, regulatory requirements and Cielo policies, and dealing with legal claims and related administrative activities and related records retention.  We may also process it to establish or exercise our legal rights and to comply with law enforcement or other government agency requests or court orders.

3.4            Cielo or Group may also convert personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Cielo/Group performance.  For more information, please see the Aggregated Information section below.

4. Aggregated Information

Aggregated personal information does not personally identify you or any other user of the Site.  It may be used for statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, risk assessment and analysis of costs and charges in relation to our products and services.

5. Does Cielo share personal data with third parties?

5.1            Your personal data will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible management, human resources, accounting, legal, logistics, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Group. Please note that certain individuals who will see your personal data may not be based at Cielo or in your country (please see below).

5.2            We may share personal data within the Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this Policy.

5.3            Your personal data may also be made available to third parties (within or outside the Group) providing relevant services under contract to Cielo, or the Group (see below for further details), such as employment recruiters, human resources support services, auditors and compliance managers, providers or call centres and IT hosting and IT maintenance providers.  These companies may use information about you to perform their functions on our behalf.  

5.4            We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Personal data may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Cielo, our employees, agents, customers, and others, as well as to parties to whom you authorise Cielo to release your personal data.

5.5            In addition, we may disclose your personal data to prospective or actual buyers in the event that Cielo or any part of the Group sells all or any of its business or assets.

6. Will your personal data be transferred abroad?

6.1            Individuals within the European Economic Area (“EEA”) should be aware that recipients of their personal data, whether within the Group or external third parties (as mentioned in this notice), may be located in countries or territories outside the EEA which may not have adequate data protection laws equivalent to those in the EEA. 

6.2            Where personal data is transferred to countries outside of the EEA and Switzerland (other than the U.S.) Cielo will put in place other measures to ensure that those transfers are adequately protected (as required by applicable law).

6.3            Individuals in other regions may also have their personal data transferred outside their own country.

7. What choices does Cielo offer you with regard to direct marketing?

7.1            Cielo may wish to provide you with information about new products, services, promotions and offers from Cielo and/or the Group, which may be of interest to you, and may invite you to take part in market research or request feedback on Cielo and/or Group products and services. This communication may occur by email, SMS or telephone. We will obtain your consent where we are required to do so in accordance with applicable law.

7.2            If required by applicable law, Cielo will ensure that any direct marketing or market research that you receive or are contacted about by electronic means will provide a simple means for you to refuse further marketing.  For example, in emails it may provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request.  Cielo will take steps to stop any marketing to which you object or in respect of which you withdraw your consent within a reasonable period, in order to allow sufficient time for the change to be administered.

7.3            In such cases Cielo would not necessarily remove all your personal data from its database(s) but would note and respect your modified direct marketing preferences.

8. What safeguards are in place to protect your personal data?

8.1            Cielo takes steps to seek to protect the security of your personal data in accordance with applicable law.  As for all website operations, we cannot guarantee the security of any transmission of personal data over the Internet.  Communications over the internet such as emails are not secure unless they have been encrypted.  So while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us.  Please do not submit personal data through the Site unless you accept the inherent security implications of dealing online.

9. What rights do you have to access, review and amend personal data?

9.1            We take reasonable steps to ensure that data about you is reliable for its intended use, accurate, complete, and current. You have the right to request copies of, access, and, in certain circumstances under applicable laws oppose the processing of your personal data and/or request the deletion of your personal data held by Cielo and to have certain inaccurate information about you corrected. 

9.2            If you would like to exercise any of your rights of access, rectification, cancellation and/or opposition or if you have any questions about this notice, please contact us at: privacy@cielotalent.com.

9.3            If you believe that any information we have about you is incorrect or incomplete, please write to or e-mail us as soon as possible.  We will take steps to seek to correct or update any information as necessary and in accordance with applicable law and pursuant to our checks on whether that information is in need of correction or update

10. Keeping you informed

10.1          We will keep your details on record until we have completely dealt with your request, enquiry or application and then for a reasonable period afterwards, in accordance with applicable law.

10.2          Cielo may keep your details on record for as long as is necessary for the purposes for which it may use your personal data, as set out above.  

11. Cookies

11.1          We use “cookies” for certain areas of our Site.  Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our Site and your experience.  We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor and to tailor your experience of the Site according to your preferences.  We may also use cookies for targeting or advertising purposes. 

11.2          We may also use “web beacons” on our Site or in our e-mails.  Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of the Site and to tell if an e-mail has been opened and acted upon.    

11.3          To delete or block cookies by browser settings at any time and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.

11.4          The cookies used on our Site are categorised, as follows:

11.4.1        Cookies which are “strictly necessary” for functionality of the Site’s platforms. These cookies are essential in order to enable users to move around the Site and use its features.

11.4.2        “Functionality” cookies which allow the Site to remember choices you make and your preferences for example where you register/sign-up for events, products and/or services.

11.4.3        “Performance/Analytical” cookies which collect information about how users navigate the Site, for example, which pages users access most frequently. They identify how users interact with our Site, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our Site works and understand what interests our Site’s users.

11.4.4        “Targeting or advertising” cookies used to deliver adverts relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the Site to ensure advertisements about similar products displayed on the Site are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement as well as to help measure the effectiveness of an advertising campaign. They may also remember that the Site has been visited from a device and share that information with marketing organisations. The marketing cookies on our Site are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards our Site so that we know whether it is worth us investing in that particular advertising source.  If your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads, we will alert our partners to suspend use.  As described more fully herein, we allow our advertising partners to collect personal information about your online activities when you leave our Site.

12. Google Analytics

12.1          The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses its own cookies to help us analyze how you and other users use the Site. The information generated by the cookies about your use of the Site (which may include your IP address, the internet browser and language you use, preferences, the date and hour of your access to the web page and the websites you access after visiting the Site) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.

12.2          Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Site. By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

12.3          To opt out of being tracked by Google Analytics, visit Google Analytics at https://tools.google.com/dlpage/gaoptout/ .

13. Your consent to our use of Cookies

13.1          The below explain the cookies used on the Site and if you visit the Site, they will be placed on your machine.

Cookie Name/Type

Expiration Period

Purpose

Category of cookie as defined in the ICC Cookie Guide

doubleclick.net
4816478.doubleclick.net

6 years

Collects and attributes user converted events for the purpose of measuring paid search marketing efforts.

Targeting/Advertising

Marketo Munchkin munchkin.marketo.net

2 years

Tracks web page visits, clicks, and form fill outs.

Performance/Functionality

SmartPixel JavascriptTracking Code

90 days

AdRoll tracking anonymous visitor data

Targeting/Advertising

14. Changes to this Privacy and Cookies Policy

14.1          We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.  We will update the date at the top of the Policy accordingly.

14.2          We encourage you to check this Policy for changes when you revisit the Site.  

14.3          By using the Site, submitting your personal data to us and/or registering an account, you consent to the use of your personal data as described in this Privacy and Cookies Policy (as amended from time to time).

15. Contact us

If you have any questions about this Privacy and Cookies Policy, please contact us at privacy@cielotalent.com

Complaints and Dispute Resolution

Please direct any complaints or requests for dispute resolution under this Policy to:

CIELO

Attn: Vice President, Technology Solutions

200 South Executive Drive, Suite 400

Brookfield, WI 53005