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Effective Date: June 30, 2024
CDL Marketing Group, LLC d/b/a Career Now Brands (“Career Now Brands”) provides technology-enabled digital solutions dedicated for the employment and education industries (“Services”). This Privacy Policy (“Privacy Policy”) explains how Career Now Brands, including our affiliates, subsidiaries, and family of brands (collectively “Career Now,” “we”, “our,” or “us”) processes and collects information relating to you and your household, including your personal information.
By accessing or using any of the Career Now Brands family of websites (collectively the “Site”), or otherwise providing us with personal information, you agree to the terms and conditions of this Privacy Policy and any updates we make to it. If you do not agree to the terms and conditions of this Privacy Policy, then please do not provide us with your information. Please note, however, that if you choose to limit the information that you provide to us while using the Site, you may not be able to use or participate in certain features of the Site.
Changes and Updates to This Privacy Policy
We reserve the right to revise or update this Privacy Policy at any time, and you should periodically read the Privacy Policy to learn of any revisions or updates. We will notify you of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its “Effective Date” on the Site. Using the Site thereafter constitutes your agreement to and acceptance of the Privacy Policy and its revisions or updates.
Collection of Your Personal Information
We collect both personally identifiable information and non-personally identifiable information about you to help you use our Services. “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
We collect Personal Information about you in various ways, including:
directly from you
automatically when you use our Site
from third parties
Information We Collect Directly from You
You may provide Personal Information to us directly in numerous ways. For example, when you:
opt in on our Site
participate in job or career fairs
communicate with us via email, phone, chat, or otherwise
We may collect the following types of Personal Information from you directly:
Identifiers, including real name, account name, postal address, online identifiers, internet protocol (IP) address, email address, signature, telephone number, insurance policy number, cookies, pixel tags, date of birth, age, browser type and version, device type, operating system type and version, display settings, language preferences, and unique pseudonyms
Legally Protected Characteristics Under California or Federal Law, including military or veteran status
Biometric Information, including voice messages
Information Typically Detected by the Senses, including voice messages
Professional/Employment Information, including vehicle licensure, experience, and time employed
Education Information, including graduation date
Inferences Drawn from the Personal Information Used to Create a Profile, including preferences, behavior, abilities
Information We Automatically Collect About You
Career Now and third-party service providers may automatically collect data about you when you use our Site. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics so that we can improve our products and Services. This information includes:
Internet or Other Electronic Network Activity Information, including browsing history, clickstreams, search history, information regarding your interaction with our Site, IP address, cookies, pixel tags, browser version, operating system
Geolocation, including IP address
Information We Receive from Third Parties
In some instances, Career Now may receive Personal Information about you from other parties, such as our affiliates, business partners, and service providers. That information may be obtained online, offline, or through publicly available resources. We may combine this data with the information you provide, and other data we already have about you.
Cookies & Similar Technologies
Cookies are text files that are sent by servers to web browsers and stored on your computer. They tell us which parts of our Site you’ve visited so we can save your preferences for future visits. Web beacons and pixel tags are images embedded in a webpage or e-mail for the purpose of measuring and analyzing usage and activity. Our Sites, or third-party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality. Some cookies and other technologies may serve to recall Personal Information previously provided by a visitor.
We use information collected from cookies and other technologies to improve your experience and the overall quality of our Site. We use cookies to help us identify and track visitors, your usage of our Site, and your access preferences. We may use your Personal Information to see which web pages you visit, which website you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our websites and how to improve them. If you do not wish to have cookies placed on your computer, you should set your browsers to refuse cookies before using our Site. Please understand that if you do so, you may not be able to fully utilize our Site and therefore we disclaim, and you hereby waive, any claim or liability that may arise due to your partial or incomplete access to the content of any of our Site as a result thereof.
How We Use Your Information
We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:
To operate and provide Services to you
To process your requests
To communicate with you about your account, our Services, and making announcements like changes to our Privacy Policy
To contact you relating to customer service and support
To improve and administer our Services and Site
To enforce our Terms and Conditions
To comply with the law and legal requirements, including valid court orders
For any other purpose if we anonymize the data such that it no longer reasonably identifies you or your household
As otherwise set forth in this Privacy Policy
We use Google Analytics on our site to help us analyze the traffic on our Site. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/ You may opt out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We also use Facebook Pixel Tags to better measure, optimize, and retarget our marketing campaigns. More information about the protection of your privacy can be found in Facebook’s Data Policy: https://www.facebook.com/about/privacy/. For information about Facebook’s opt-out options, please visit: https://www.facebook.com/help/568137493302217.
You have the option to configure or modify your web browser settings to either accept or decline cookies. If you opt to decline cookies, you can still access our Site; however, certain features and sections may have limited functionality. The methods for refusing cookies through your web browser settings differ depending on the browser you use, so we recommend consulting your browser's help menu for detailed instructions.
Additionally, many advertising networks provide the opportunity to opt out of personalized advertising. For further details, please explore the following link: http://www.aboutads.info/choices/.
How We Disclose Your Information
We share some information with service providers and partners who assist us in operating our Site and Services and, in some cases, legal authorities.
With our service providers and partners.
We use third parties and vendors to help us operate and improve our Site and Services. These third parties assist us with various tasks for business purposes, including website support and analytics. We do not allow these parties to use your information for any purpose other than to perform those services.
Per your instructions.
We may share and disclose Personal Information to employers and educational institutions in accordance with your instructions, including any applicable terms in our Terms of Use and in compliance with applicable law and legal process.
Other situations. We also may use and disclose information outside of our day-to-day business practices and in ways unrelated to our Site and Services.
In the Event of Merger, Sale, Divestiture, or Change of Control. We may transfer or assign Personal Information to an entity that acquires all or substantially all of our assets or stock whether by merger, acquisition, reorganization, or otherwise.
Other Disclosures. We may disclose Personal Information about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) enforce our Terms of Use or Terms of Sale, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to our, your, or third parties’ rights, property, or safety.
We do not sell your Personal Information for monetary or other valuable consideration.
Your Choices About Your Information
You have choices about how we use your information. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of our Site or Services.
Marketing
If you have provided your email address to us, we may send you emails or notifications to provide you with information, to inform you of new events or content, to solicit your feedback, or to keep you up to date on us. You can opt out of our communications at any time by clicking Unsubscribe or otherwise following the opt out prompts on these communications. You also may ask us not to send you other communications by contacting us as specified in the "Contact Us" section below, and we will honor your request. Please note that even after you are removed from our contact lists, we may still send you transactional communications, such as responding to service requests.
Advertisements
Advertisements appearing on our Site may be delivered by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers.
Third Party Links
Our Site may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us—and which may link to other websites, services, or applications. Please be aware that we are not responsible for the privacy or practices of other websites or third parties. We do not make any guarantee regarding those third-party websites, services, or applications, and we are not liable for any loss or damage caused by the use of such sites. Any data collected by third parties is not covered by this Privacy Policy. You should review the policies of the third parties and contact them directly if you have any questions about their services or practices.
Do Not Track Disclosure
Many web browsers include a Do Not Track (“DNT”) feature or setting that signals your preference not to have data about your online browsing activities monitored and collected. However, there is currently no uniform standard for recognizing and implementing the DNT signals. As such, Career Now does not monitor or respond to DNT browser requests. If a standard is adopted that we must follow in the future, then we will inform you about that practice in a revised version of this Privacy Policy.
Confidentiality & Security
Career Now values your privacy and is committed to protecting your information. We have commercially reasonable administrative, technical, and physical safeguards in place commensurate with the size, scope, and nature of our business to ensure the integrity and security of your information.
Information Retention
We keep your personal data only as long as necessary to provide you with our services and for legitimate and essential business purposes, such as maintaining the performance of our Site and Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
Children
We do not knowingly collect or solicit personal information from children under the age of 16. If you are under 16, please do not provide use our Site. By providing information via the Site, you represent that you are at least 16 years old. If we learn we have inadvertently received or collected Personal Information from a child who is under the age of 16, we will attempt to immediately delete that information from our files and records. If you believe a child who is under the age of 16 has provided us with Personal Information, please contact us at the address listed below in “Contact Us.”
International Visitors
Our Site is intended solely for residents of the United States and we do not do business outside the U.S. If you provide Personal Information to us, please note that it will be transferred, processed, collected, used, accessed and/or stored in the United States and subject to U.S. laws. The laws in the United States may not provide the same protections for your Personal Information as the jurisdiction in which you are located. Do not provide your Personal Information to us if you do not want this information to be transferred or processed outside of your country, or if the laws in your country restrict such transfers.
“Shine the Light” Law
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of Personal Information, such as name, e-mail, mailing address, and type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties.
If you would like to exercise any of the rights provided under the “Shine the Light” law, please contact us by using the “Contact Us” section below with a reference to “Shine the Light.”
State-Specific Data Subject Privacy Rights
This section is applicable to residents of California, Colorado, Connecticut, Iowa, Montana, New Jersey, Oregon, Texas, Virginia, and Utah residents. If you are a resident of any of these states, you have certain rights described below.
Collection & Sharing of Personal Information
During the 12-month period prior to the effective date of this Privacy Policy, we have not sold any Personal Information for monetary consideration, but we may have collected, shared, or disclosed the following categories of Personal Information for a business purpose with certain categories of third parties, as described below:
Your Data Subject Rights
This section applies only to the Personal Information of California, Colorado, Connecticut, Iowa, Montana, New Jersey, Oregon, Texas, Virginia, and Utah residents to the extent the information is subject to the applicable state privacy and data protection laws, or any amendments or acts thereto upon their effective dates (“Applicable Data Protection Laws”).
California, Colorado, Connecticut, Iowa, Montana, New Jersey, Oregon, Texas, Viriginia, and Utah residents have the following rights as defined under Applicable Data Protection Laws:
Right to Request Information. You have the right to request that we disclose the following information to you:
The categories of Personal Information that we collected about you;
The categories of sources from which the Personal Information is collected;
The business or commercial purpose for collecting or selling Personal Information;
The categories of third parties with whom we share Personal Information;
The specific pieces of Personal Information that we have collected about you;
The categories of Personal Information that we disclosed about You for a business purpose or sold to third-parties; and
For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
Right of Deletion. You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
Right to Opt-Out. We do not sell or share your Personal Information for monetary payments. However, like many companies, we do use services that help deliver interest-based online advertisements to you. You can opt out of such “sale” or “sharing” by clicking on the Do Not Sell or Share My Information link at the footer of the Site. You may also contact us by using the “Contact Us” section below with a reference to “Data Subject Request.”
Right to Opt-In. Unless proper consent is acquired, a business may not sell or share the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age. We do not collect, share, or sell the Personal Information of minors under the age of 16.
Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on sharing, use, or disclosure of your sensitive Personal Information, as defined by California privacy laws, which is collected or processed for “the purpose of inferring characteristics about a consumer.” However, we do not collect or process sensitive Personal Information.
Right to Correction. You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.
Right to Non-Discrimination. We may not discriminate against you because you exercise any of your rights, including, but not limited to:
Denying goods or Services to you;
Charging different prices or rates for goods or Services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or Services to you; or
Suggesting that you will receive a different price or rate for goods or Services or a different level or quality of goods or Services.
Exercising Your Data Subject Rights
You may exercise any of your data subject rights by contacting us using the “Contact Us” section below with a reference to “Data Subject Request.”
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the "Contact Us” section to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
The authorized agent to provide proof that you gave written permission to the authorized agent to submit the request;
You to verify your identity directly with us; or
You to directly confirm with us that you provided the authorized agent permission to submit the request.
Identity Verification and Appeal Process
If you request to access, correct, or delete your Personal Information under California, Colorado, Connecticut, Iowa, Montana, New Jersey, Oregon, Texas, Virginia, or Utah law, we are required by law to verify your identity before processing your request. When you make such a request, you can expect the following:
We will verify your request. You will need to provide us with your email address and full name. We may ask for additional information if needed.
We will confirm that you want your information accessed, corrected, and/or deleted.
We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your request, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.
If you are not satisfied with our response regarding your data subject request, you have the right to appeal our decision. For more information, please contact us using the contact details provided under the “Contact Us” section. If you are not satisfied with the result of the appeal, you may have the right to contact your respective attorney general depending on where you reside.
Contact Us
If you have any questions or concerns about this Privacy Policy or the information practices of our Services, please contact us at privacy@careernowbrands.com, or call us at 877-634-4529, or send a letter to the following address:
Career Now Brands
Attention: Data Protection Officer
302 East Parent Avenue
Royal Oak, Michigan 48067