This Privacy and Security Policy is provided for the benefit of customers and clients of ETHNUS Technologies Pvt. Ltd. (“ETHNUS”) as well as other consumers and parties who seek information from or about ETHNUS and/or its website(s), particularly inpiq.com (“Website” or “inpiq.com”), and/or applications (“Apps”) (collectively, “ETHNUS Services”).
1. OPENING STATEMENTS
1.2 Our Commitment to Privacy
At ETHNUS, we respect the privacy and the confidentiality of our customers’ information, particularly our customers’ PII (also commonly referred to as personally identifiable information) (“PII”). We are committed to keeping confidential the PII you share with us. This Privacy and Security Policy explains how ETHNUS collects, uses, discloses and protects the information we obtain.
1.3 Applicability of Privacy and Security Policy
Our Privacy and Security Policy applies to all individuals and entities from whom or for the benefit of whom we receive PII, whether it be collected through our corporate owned websites; Apps; traditional mailing and/or faxing channels; telephone or electronic communications; from some other medium; and/or from our clients.
1.4 Website and Apps Not Directed to Minors
The Website is a professional website directed toward employers and staffing companies (either directly as customers of ETHNUS or through Staffing Customers that use ETHNUS Services) seeking to hire individual job seekers, individual consultants, or consultant groups or consultant groups for employment. In this context, the website also accepts individuals as customers who respond to certain invitations to use ETHNUS Services. As such, an individual must be aged sixteen (16) or over to create an account through the Website. As such, the Website is not directed toward children or minors. This also applies to all ETHNUS Apps.
2. PERSONAL INFORMATION COLLECTED AND HOW IT IS USED
2.1 Personally Identifiable Information or PII
is any information that would, by itself, identify you or tend to identify you as a particular individual or entity. This PII may include, but not be limited to, your name, your address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver’s license number).
2.1.1 PII does not include any public information that is readily attainable through federal, state or local public record distribution channels.
2.1.2 PII does not include any information that, by itself, could not identify you as a particular individual or entity.
2.1.3 PII also does not include raw data that becomes aggregated for statistical purposes and cannot, thereafter, be identified with you as a unique individual or entity.
2.1.4 ETHNUS does consider your Internet Protocol (“IP”) address to be PII and will treat it as such.
2.2 Information Collected
2.2.1 ETHNUS collects information that is considered PII and other information that, by itself, would not be considered personally identifiable information (“Non-PII”).
2.2.2 When you create an account and register for any of our ETHNUS Services (whether through a Website, App, or other portal), we collect information submitted by you including, but not limited to, your full name, company name (if applicable), email address, phone number, and IP address. We use this information to identify our customers and send notifications related to the use of our ETHNUS Services. We reserve the right to request additional information from you.
2.2.3 For our business customers, ETHNUS shall also collect information relating to one or more of your financial accounts for purposes of processing payments to provide you with ETHNUS Services. This information may likely contain both PII and Non-PII depending on the nature of the account holder information.
2.2.4 ETHNUS provides its services for free to individuals invited to use ETHNUS by one of its business customers. As this constitutes the only basis for which individuals can use ETHNUS Services at this time, there exists no reason for an individual customer to provide financial information to ETHNUS or any of its business customers inviting such individuals to use ETHNUS Services. Based on the foregoing, business customers of ETHNUS are expressly prohibited from requesting and/or collecting consumer financial information through any ETHNUS Services. Should any consumer be requested to provide such information, please report it immediately to ETHNUS at email@example.com.
2.3 Collecting and Using Personally Identifiable Information
2.3.1 ETHNUS will explain how it intends to use PII either before it collects the information (such as in this Privacy and Security Policy) or contemporaneously with the solicitation of such information. Exceptions may exist where the intended use is obvious to a reasonable person.
2.3.2 Generally, ETHNUS collects personal identifiable information when an individual registers with or uses any of the ETHNUS Services. This information typically includes, at a minimum, a full name, company name (if applicable), email address, phone number, mobile phone number, and any additional information provided by the account holder that could identify that account holder. For persons seeking employment, it should be recognized that a collection of information that would otherwise be considered non-PII could transform into PII (eg employment history, employment position at a company). Consequently, an individual account holder must be cautious in making public through any of the ETHNUS Services information that could identify them where they seek to keep private their search for employment. The same can be said of consultants and employers in certain circumstances.
2.3.3 We will use the PII collected only for the purposes explained to you. Further, we limit the collection of PII to only that information which is necessary for the purposes explained to you.
2.3.4 Generally, we use the PII collected and/or received about you in connection with our Apps, Website, ETHNUS Services, and their various features. We also use information collected and/or received about you in connection with other users and advertisers that purchase ads through the Apps or on the Website.
For example, we may use the information we receive about you (a) as part of our efforts to keep ETHNUS safe and secure; (b) to provide ETHNUS Services; (c) to make suggestions to you and other users on ETHNUS; and (d) provide support.
Granting us this permission not only allows us to provide ETHNUS as it exists today, but it also allows us to provide you with innovative features and services we develop in the future that use the PII we receive about you in new ways.
We may use your PII to communicate with you for the foregoing and other reasons by email, text message, phone call, or other electronic, written or oral communication method, unless you expressly indicate to ETHNUS not to use a particular method of communication.
While you are allowing us to use the PII we receive about you, you always own all of your information. Your trust is important to us, which is why we don't share PII we receive about you with others unless we have received your express permission for the information to be used for such purpose.
Additionally, we may use aggregated information derived from PII to improve the ETHNUS Services and any related matters thereto.
2.3.5 Unless we are required to do so by law, we shall not obtain your consent before collecting PII about you from parties other than ETHNUS. Rather, ETHNUS shall presume that you have previously provided such consent to any such third party from whom ETHNUS obtains such information. This only applies to information provided by third parties to ETHNUS. ETHNUS does not provide third parties with access to your account information and only shares your information with third parties where we have your consent to do so.
2.3.6 In the normal course of its business operations, ETHNUS restricts the use of your PII to ETHNUS’s personnel and its Strategic Partners. However, by using ETHNUS Services, you may necessarily disclose PII to potential employers and Staffing Customers when they access your information, profiles, interviews, and other Content. Indeed, as individuals will only be using ETHNUS Services at the invitation of an employer or staffing company, you necessarily will be providing such entity with information when you respond to the invitation.
2.3.7 We shall not sell your PII in the normal course of business operations. Should all or any part of ETHNUS’s business operations be sold, this paragraph shall not by itself restrict the transfer of your PII as part of the Website sold to a third party. However, the ability to transfer such information may be governed by law in your applicable jurisdiction. In such cases, ETHNUS shall comply with applicable law, provide notice, and seek consent prior to any such transfer.
2.3.8 We may also use the PII you provide in registering with and using ETHNUS to inform you by electronic mail, phone, text or other communication method of additional products and services about which you might be interested, which may include our periodic e-newsletters and other promotional communications from ETHNUS.
2.4 Disclosing Personal Information
18.104.22.168 ETHNUS may use PII in the normal course of providing the ETHNUS Services; to operate or improve the Apps, Website and/or ETHNUS Services; to outsource certain services to Strategic Partners; to complete a transaction that has been requested; to develop aggregate information; and/or as otherwise disclosed to you.
22.214.171.124 In particular, by the very nature of the ETHNUS Services, information submitted by our customers seeking employment or employees will be shared with other customers as applicable to the customers’ particular use of ETHNUS Services.
126.96.36.199 Additionally, Staffing Customers that use ETHNUS Services may provide their employer customers, Third-Party Customers, limited information about ETHNUS customers for the specific purpose of matching individuals using ETHNUS Services to the needs of their employer Third-Party Customers. In some cases, Third-Party Customers may not be ETHNUS Customers. ETHNUS requires its Staffing Customers to ensure that their Third-Party Customers agree to process the information at the same level of privacy protection as outlined in the Privacy Shield Principles. Upon notice of unauthorized processing by Third-Party Customers or ETHNUS Customers, ETHNUS will take reasonable and appropriate steps to stop and remediate unauthorized processing.
188.8.131.52 In some cases, ETHNUS Customers may be able to download your videos and other public information, and store them on, their computers and servers. Other ETHNUS Customers may also be able to use shared links by which they provide related parties who might not also be ETHNUS Customers access to your content.
2.4.3 Strategic Partners. ETHNUS may employ, engage or retain certain trusted third parties (“Strategic Partners”) to perform functions and/or provide services on its behalf, such as web hosting, integrated services, or advertising. ETHNUS will share PII with these Strategic Partners only to the extent necessary to perform the functions and/or provide the services for which they have been employed, engaged or retained. ETHNUS shall also secure contractual obligations from our Strategic Partners to maintain the privacy and security of the PII shared with them at the same level of privacy protection as outlined in the Privacy Shield Principles. Upon notice of unauthorized processing by a Strategic Partner, ETHNUS will take reasonable and appropriate steps to stop and remediate unauthorized processing. Some of the Strategic Partners that may receive access to your PII to provide the ETHNUS Services have been listed below.
2.4.4 Business Transfers. ETHNUS reserves the right to sell, transfer or otherwise share some or all of its assets, including PII, in connection with a sale of assets; a merger, acquisition, or reorganization; or, filing for bankruptcy. You will have the opportunity to opt out of any such transfer if the planned processing of your information by the purchaser differs materially from that set forth in this Privacy and Security Policy.
2.4.5 Legal Compliance. ETHNUS may be required to disclose any information about you and/or Content created by you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose any information about you and/or Content created by you as we, in our sole discretion, believe necessary or appropriate to: (1) comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority; (2) respond to claims, court orders, or other legal process (including subpoenas); (3) to enforce the terms of this and other ETHNUS agreements as well as to protect the property and rights of ETHNUS, its Strategic Partners or other third parties; (4) to protect, in ETHNUS’s sole discretion, the public or any person from harm; (5) to investigate, prevent, stop, or take other action regarding any action perceived to be fraudulent, illegal, unethical, or legally actionable in ETHNUS’s sole discretion; and/or, generally, (6) to comply with the law.
2.4.6 Notice. Unless restricted from doing so, ETHNUS will attempt to notify you before it releases any of your PII or Content pursuant to (1) and (2) in paragraph 2.4.5 only. In such cases, ETHNUS will also provide you with general information on how you may seek to block such a release of information and/or direct you to resources that can provide such general information. The provision of such general information to you is not and should not be construed as providing you with legal advice. Additionally, ETHNUS is under no other obligation to assist you in challenging or opposing a release of your information
2.4.7 Onward Transfer Liability. ETHNUS may be liable for onward transfers of personal data to third parties in violation of this policy and the Privacy Shield.
2.5 Non-Personally Identifiable Information
2.5.1 In addition to collecting PII as previously described, ETHNUS also collects other non-PII.
2.5.2 Non-PII collected by ETHNUS may be utilized without restriction
2.5.3 Although non-PII can be used in a number of ways, you can be assured that the use of the non-PII cannot identify you as a particular individual.
2.5.4 Because non-PII cannot be used to identify you, ETHNUS may in its discretion provide non-PII to other persons or entities.
Information Obtained From Use of ETHNUS’s Websites
2.6.1. Cookies can be defined as bits of data stored on your computer that allow website(s) to identify your browser and session.
184.108.40.206. If you reject all cookies, you may not be able to use the ETHNUS Services or products that require you to “sign in” and you may not be able to take full advantage of all offerings.
220.127.116.11. Most web browsers automatically accept and collect Cookies. However, most browsers also allow you to configure them to accept all cookies, reject all cookies, or notify you when a cookie is set. Depending upon your web browser’s security settings, you may have the ability to reject all cookies.
18.104.22.168 The ETHNUS Website uses its own cookies for a number of purposes including, but not limited to:
A. Requiring you to re-enter your password after a certain period of time has elapsed to protect you against others accidentally accessing your account contents;
B. Keep track of preferences specified by our users while using the ETHNUS Website;
C. Estimate and report our total audience size and traffic; and,
D. Conduct research to improve the content and services provided on the ETHNUS Website.
E. Identify to Third Parties that you have visited our Website
22.214.171.124 More specifically, when you use ETHNUS Services, cookies may be placed on your computing device that informs third parties you visited our services. Because of this, you may receive advertisements relating to ETHNUS. Although ETHNUS provides these ads to third parties and requests that they be placed when the advertising services find our cookies, we do not control the timing, location, and placement of the ads. So, though ETHNUS controls generally when and to what type of individual or cookie receives an ad, we do not control whether a specific user or consumer receives an ad. Should you wish to cease receiving such advertisements, you should opt out of these re-targeting services directly on the third party websites or platforms where possible.
2.6.2. Google AdWords Marketing
126.96.36.199. ETHNUS may use, from time to time, Google Adwords marketing campaigns to promote its products and services. In particular, ETHNUS intends to use Google AdWords “Remarketing” campaigns
188.8.131.52. In using Google Adwords marketing campaigns, Google will place a cookie on your computer when you visit ETHNUS’s website(s). As you leave ETHNUS’s website(s), this cookie will later enable banners and other materials to appear through which you can return to ETHNUS’s website(s).
184.108.40.206. The foregoing being said, through the use of any Google AdWords marketing campaign, ETHNUS:
A. SHALL NOT run an interest-based advertising campaign that collects PII;
B. SHALL NOT use or associate PII with remarketing lists, cookies, data feeds, or other anonymous identifiers;
C. SHALL NOT use or associate targeting information, such as demographics or location, with any PII collected from any Google AdWords ad or landing page associated with it;
D. SHALL NOT target children under the age of 13 through any Google AdWords campaign;
E. SHALL NOT share any PII with Google through ETHNUS’s remarketing tag or any product data feeds which might be associated with ETHNUS’s ads;
F. SHALL NOT, when creating a remarketing list, use any sensitive information (as defined by Google), or products associated with such sensitive information, about visitors to ETHNUS’s Website(s), any of its Webpages, or Apps, whether ETHNUS collected it directly or associated it with a visitor, based on the visitor's profile or behavior on ETHNUS’s website(s), webpages, and/or through its Apps;
G. SHALL NOT create a remarketing list or ad that seeks to reach people through prohibited methods; and,
H. SHALL NOT create or produce ad content that implies knowledge of PII or sensitive information.
220.127.116.11. ETHNUS has no objection to Google providing notice or labels to disclose interest-based advertising to its users.
18.104.22.168. ETHNUS has no objection to Google displaying to its users the remarketing lists, including those of ETHNUS, upon which they appear.
22.214.171.124. For your protection, Google will not disclose ETHNUS remarketing lists or other similar audience lists to another advertiser without ETHNUS’s consent. At this time, ETHNUS shall not permit such disclosures.
2.6.3. Browser and Session Information
ETHNUS may collect information about your browser and session at the Website and/or using the Website Services.
2.6.4. IP Addresses
126.96.36.199. ETHNUS maintains a log of Internet Protocol (IP) addresses when ETHNUS computers, servers, Services, and/or websites (including, the Website) have been accessed. An IP address by itself does not allow us to collect additional PII about you.
188.8.131.52. IP addresses may be used for various purposes including, but not limited to:
A. Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP;
B. Estimate the total number of users visiting a ETHNUS computer, server and/or website from specific geographical regions.
C. Help determine which users have access privileges to certain content, services or resources offered; and,
D. Monitor and prevent fraud and abuse.
184.108.40.206. OTHER THAN YOUR IP ADDRESS, ETHNUS DOES NOT DIRECTLY COLLECT ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU UNLESS YOU VOLUNTARILY PROVIDE US WITH THIS INFORMATION.
2.7 Data Retention
2.7.2. The length of time for which ETHNUS retains PII and other information will vary depending on the nature of the services for which the information has been collected and the nature of the information.
2.7.3. Although this period may extend beyond the end of your relationship with ETHNUS, it will be retained for only so long as necessary for ETHNUS to respond to any issues arising from your relationship with ETHNUS.
2.7.4. When ETHNUS no longer needs or requires your personal information in the normal course of business operations and/or due diligence, or where a business customer no longer needs or requires your personal information and either consents or requests to the deletion of such content, ETHNUS will destroy, delete, erase or convert information to an anonymous form without notice to you.
2.7.5. Depending on the package of services purchased, ETHNUS may delete information including, but not limited to, stored messages, interviews, videos, audio, other content, and records of your account without notice to you. ETHNUS recommends that you back up on your own computer any critical and important information prior to allowing your ETHNUS Services to terminate or expire.
2.7.6. Should your account be terminated, ETHNUS may immediately and permanently delete all stored messages, interviews, videos, audio, other content, and records of your account without notice to you.
2.7.7 The foregoing being said, the employer or staffing company for whom you have provided information may be required to retain information beyond ETHNUS’s direct use of such information. Because of this, ETHNUS must defer to the specific employer or staffing companies’ retention requirements.
3.1. ETHNUS may obtain personal information about you through a variety of sources. For each source or method, the manner of consent may differ.
3.2. In general, ETHNUS operates on an “Opt-IN” basis. That is, ETHNUS will obtain your consent to use information provided to it by describing the intended use and requesting that you indicate your agreement.
3.3. At any time, you may expressly inform ETHNUS you do not wish your information to be used in a particular manner through account settings. While there is no penalty to change your settings, ETHNUS may not be able to provide certain services without the ability to use your information in particular internal settings.
3.4. Where ETHNUS obtains information about a consumer from its customers or other third parties, ETHNUS presumes that the consumer has previously provided appropriate consent to the party from whom ETHNUS obtains the information. In any case, the consumer can be assured that this Privacy and Security Policy applies to any information obtained from a third party.
3.5 You have the right to object to targeted marketing.
4.1 You have the right to access your personal data. Subject to certain limitations imposed by applicable privacy laws, you have the right to request that ETHNUS provide you with a copy of your account and/or personal information and/or information regarding how we have used that personal information.
4.2 Any requests for access to information should be directed to our Privacy Officer at the contact information provided below.
4.3 We will make every effort to respond to your request in a reasonable timeframe consistent with applicable law.
4. We provide you the means to correct much information that ETHNUS may have about you. Where you cannot change incorrect information about you in our system, you may request incorrect information to be corrected at any time by contacting firstname.lastname@example.org.
5. We respect the right to delete information. However, as the employer or staffing company has obtained such information for their purposes and ETHNUS serves as a Data Processor (AND NOT Data Controller), any requests for deletion of date made to ETHNUS will be forwarded to the relevant data controller for handling.
5.1. ETHNUS takes the issue of protecting your anonymity and personal information very seriously. ETHNUS protects the information it obtains about you with appropriate, commercially reasonable safeguards and security measures consistent with standard information practices. These measures include commercially reasonable technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.
5.2 For security purposes, ETHNUS does not disclose all of its security measures. Be assured that ETHNUS does employ commercially reasonable industry standard measures to protect your information. ETHNUS may routinely complete audits of its systems.
6. DISPUTE RESOLUTION
6.1 Should you have any complaints with respect to ETHNUS Services’ compliance with our Privacy and Security Policy, we encourage you to contact us directly to resolve any such complaints. ETHNUS is committed to remedying any issues as they arise and expressly commits to resolve complaints about our collection or use of your personal information. We value our customers and their privacy. As such, this commitment reflects our general business philosophy but also complies with Privacy Shield and other applicable principles. Consequently, we want to hear from you should you have any issues regarding our privacy practices. You may send an email to email@example.com.
7. DISCLAIMER AS TO THIRD-PARTY CONTENT
Although our corporate owned websites may contain links to other third-party websites and/or may be advertised on such third-party websites, ETHNUS is not responsible for the privacy practices or the content of such websites and specifically disclaims any such responsibility. ETHNUS does not monitor the privacy practices or content of these websites. If you have any questions about the privacy practices of a website other than a ETHNUS owned website, you need to contact the Privacy Officer of the website about which you have a question.
As stated above, ETHNUS cannot control the targeted advertising you receive when you leave our ETHNUS Services. Depending on your settings, you may receive ETHNUS advertisements off of our website because your browser contains retained data from ETHNUS Services. While ETHNUS provides third parties with advertisements and your computing devices may retain data that you visited ETHNUS Services, we cannot control the computers or servers owned by third parties. You can adjust settings with some of these Third Parties to opt out of targeted advertising. You can also choose to use an incognito or other function that precludes retention of browser information. But. Modifications of your browser settings may affect the quality of ETHNUS Services you receive.
8. INCORPORATION OF OTHER APPLICABLE TERMS
8.2 As a business customer of ETHNUS, you expressly agree that you shall and have met any and all requirements specified above that have been imposed upon it as to the quality and sufficiency of efforts to protect data and individual privacy.
9. PRIVACY OF CHILDREN
We make it a practice not to knowingly obtain and/or retain information about individuals under the age of sixteen (16). Indeed, no part of ETHNUS Services is directed to anyone under the age of sixteen (16).
10. ADDITIONAL INFORMATION
10.1 When you post content on and/or through the ETHNUS Services, you have the ability to post content which may include personally identifiable information or PII about yourself. You are responsible for the information you (a) post online; (b) post through use of the ETHNUS Services; or, (c) share with another website that you link to from our Website. You do so at your own risk. ETHNUS warns you to be careful in posting information accessible to the public.
10.2 If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties or other unwanted and possibly harmful contact. ETHNUS warns you to be careful in posting information accessible to the public.
11. CUSTOMER OBLIGATIONS
12. REVISIONS TO PRIVACY AND SECURITY POLICY
12.2. ETHNUS shall provide notice of such changes by posting the revised policies to the applicable ETHNUS owned websites and by either (a) providing you a message the next time you login into your account or (b) sending you electronic mail to the email address you provided when creating your account.
12.3. With respect to this Privacy and Security Policy, you should visit our website at inpiq.com from time to time to review the then-current terms. At any time, the current-posted policies govern and shall be binding.
For Additional Information or Questions, Contact Our Privacy Officer
ETHNUS has a designated Privacy Officer. If you have additional questions or concerns regarding how ETHNUS is managing or using your personal information, please send your concerns in writing to our Privacy Officer by e-mail at firstname.lastname@example.org.