Privacy Policy - 2012-01-15

Introduction

  1. We don't just have a privacy policy but a Pledge of Privacy which is a promise to you that we will do everything we can to use the information you give us to help showcase your skills and talents to Organizations you are following and your Brave New Talent network.
  2. We will use your data to give you are great, enhanced experience, for example, building you cool infographics and helping you understand your personal network better.
  3. We like to keep in touch with you but if you don't want to hear from us, you don't have to. It's easy to unsubscribe from our newsletters directly from the email.
  4. If you want to split, that's ok. We'll be sorry to see you go, but you can remove your account anytime.
  5. The above is a summary of your privacy. Below you can read the full privacy policy.
  6. (And if you're an Organization, you should definitely read it as you will need to abide by our user code too.)

Policy

  1. Note: unless otherwise specified, all definitions used have the same meaning as in the Terms of Use or Acceptable Use Policy for the Site, of which this privacy policy forms part.
  2. If you register as a Talent, you will be taken to have agreed in full to our Privacy Policy on completion of registration with the Site. You accept that all information you provide us with is provided voluntarily, including personal information which is considered "sensitive" by applicable law (for example ethnicity, gender, religion). You consent to the processing of your personal information by us in line with this Privacy Policy. You can withdraw your consent at any time by closing or deactivating your account with us.
  3. If you reside outside the United Kingdom, your personal information will be transferred to the United Kingdom and processed and stored there in accordance with the Data Protection Act 1998. By accessing and using the Site and in providing personal information to us, you consent to this.
  4. If you are an Organization please read this Privacy Policy carefully as you will be expected to adhere to it as a User and to respect the personal information and data protection rights of the Talent. How we manage Organizations' personal information is set out in the Organization Terms which agree to on creation of your Organization Profile.
  5. We will protect, and limit our use of the personal information that you provide to us when you register with us and contained in your Talent Profile in accordance with our Privacy Policy.
  6. This Privacy Policy sets out the basis on which any personal information that we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
  7. We are the data controller for the purpose of the Data Protection Act 1998 (the "Act"). Our nominated representative for the purpose of the Act is Lucian Tarnowski.
  8. Your personal information is processed in accordance with the Data Protection Act 1998 and The Privacy and Electronic Communications (EC Directive) Regulations 2003.
  9. Unless otherwise stated the expression "you" means a Talent.

Purpose of the Site

The purpose of the Site is to:

  • Enable you to create and maintain an online professional Talent Profile, which provides information about yourself which can then be shared with Organizations you elect to follow and/or connect to via the Site.
  • Enable you to showcase your skills, qualifications and experience within your own networks of friends, colleagues as well as educational establishment and Organizations you are following. Organizations will see the Talent Profiles of all the Talent who are following them.
  • Increase your professional visibility on Google (unless you have made your Talent Profile ‘private’ in your privacy settings)
  • Enable you to follow and/or connect with other Talent, colleagues and business acquaintances who use the Site to develop a network of like-minded contacts.
  • Enable you to follow skills Talent and Skills that others follow on the Site. Organizations being followed are visible to all users of the Site.
  • Enable Organizations to follow you and if you have connected to an Organization, to facilitate communication between you both via the services provided or to be provided by the Site.
  • Enable you to interact with your other online networks, including using Facebook Connect to import your friends and contacts from Facebook and LinkedIn respectively onto the site.
  • Enable you to upload your CV data using our CV parsing facility.

We obtain personal information from you during registration, through Talent Profile creation and by your activities on the Site. We use this information in order for you to receive the benefits of the Site and Services and specifically to achieve the purposes in section 1.1. We may also use this information to stay in touch with you.

Personal Information

  1. You provide your personal information to us voluntarily and having agreed to this Privacy Policy on your registration on the Site.
  2. We need to collect and use your information in order to allow you to benefit from the Site.
  3. You can manage your privacy preferences by going to privacy settings. Please be aware though that if you restrict the use of your personal information you may not be able to use and enjoy all the benefit and services of the Site.
  4. We collect your personal information in the following ways:
    Registration
    When you register as a Talent, we ask for your name, email, country, location, date of birth, gender, university attended and your chosen password. This personal information is necessary to allow Users to identify you. We will only use your date of birth and gender for internal, analytical and statistical purposes.
    Talent Profile
    When you create, change or add to your Talent Profile, you will provide us with further information about yourself, such as your education history and qualifications, skills, university course, personal preferences and interests, work experience and personal overview. You provide your Talent Profile information at your discretion, but the more information and more complete your Talent Profile is, the more opportunity you will have to impress and encourage communication with Organizations and also to build a Talent network.
    Talent Connections
    In order to invite others to follow or connect with you directly through the Site, you may use the Services to invite them if they are a Talent to connect, or enter their names and email addresses to encourage them to become Talent. You can also use our integration with LinkedIn and Facebook to bring your friends and connections onto the Site as Talent Connections. We use this information to manage the invitation and to send reminders (by email or instant message). The names and email addresses of people that you invite will be used only to send your invitation and reminders. We retain this information to allow you to see the invitations you have sent and also so we can analyze the invitation service. Any person you invite can ask us to remove this information.
    Your Communications and Site Activities
    Through your activities on the Site, in particular:
    • your activities in chat rooms;
    • use of bulletins;
    • participation in forums;
    • blogging;
    • posting of materials;
    • instant message and other forms of electronic transmission;
    • wall-to-wall features;
    • communications with other Talent;
    • communications with Organizations you connect to or follow,
    you will be providing us and other Users of these facilities and potentially other third parties with your personally identifiable information. This information could be used to then send you unsolicited messages. This is not our responsibility and your accept that your personally information might be used in this manner. By being registered as a Talent on the Site, Users (specifically other Talent and Organizations) will be able to view and search your full Profile and Talent Connections and Organizations being followed on the Site. . In addition, this information may be made available to third-party search engines in much the same way as other professional networking sites do. However you can control how much information is available to them. We are in the business of showcasing your talent as a registered Talent of the Site, using various internet and digital means. You can manage your privacy by our privacy settings. If you post materials or make contributions on the Site, you do so at your own risk. In your use of the Site and in your interaction with other Talent and with Organizations, you can choose the level of contact information you share with them. We cannot control and are not responsible for the actions of Users with whom you share your personal information. We do not guarantee that your personal information will not be viewed by unauthorized persons.
    Communications with us
    We may collect information through the Site or by "contact us" in order to deal with an enquiry, comment or complaint you may have about the Site or Services. We or one of our authorized partners on our behalf may ask you to complete surveys that we use for research purposes, product and Site development purposes, although you do not have to respond to them.
    Web log files, cookies and other recognition technologies
    We may collect information and details of your visits to our site including, but not limited to, traffic personal information, location personal information, weblogs and other communication personal information, whether this is required for our own billing purposes or otherwise and the resources that you access. See section 6 on cookies, web log files and other recognition technologies.
    Automatic information - IP Address / URLs
    We automatically receive from your internet use such information as your IP address, the URLs of sites from which you arrive or leave our Site, your type of browser and your ISP.
    • Any information you provide at registration or in your Talent Profile that is not personally identifiable may be used in the same manner and extent to which other information that is not personally identifiable is permitted to be used hereunder, including for the purpose of serving advertisements through the Service. If you opt-out you may lose the potential benefit of being a User, including receiving ads and communications that are more targeted to your interests.
    • Please note that information that does not personally identify you is collected by us. We own this information exclusively and can use it in any manner we think appropriate.

What we do with the information we gather

  1. We will use information held about you in the following ways:
    • administer and manage your account with us;
    • to alert you to requests to connect from other Talent or Organizations;
    • to keep you updated as to events and forums we think are relevant to you;
    • to send you service-related announcements from time to time through the general operation of the service or by email, instant message or SMS.
    • to ensure that content from the Site is presented in the most effective manner for you and for your computer and is responsive to your personal preferences;
    • to provide you via the Site, SMS, email or other electronic communication (such as Twitter), with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
    • to carry out our obligations arising from any contracts entered into between you and us;
    • to allow you to participate in any interactive features of our service, when you choose to do so; and/or
    • to notify you about changes and updates to our Services or those within the Brave New Group (and you have the option to unsubscribe should you wish);
    • so you can manage your privacy settings;
    • so you can manage your Talent Profile;
    • so you can manage your connections and followings with skills, other Talent and with Organizations;
    • in conjunction with third parties, in order to deliver the Site or Services;
  2. We may also provide your information to third parties involved in the development or maintenance of the Site and the Services we offer, such as third party programmers and website developers, and to third party consultants and our professional advisers in connection with the development of our business.

Disclosure of Your Information

  1. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 Companies Act 2006 (replacing section 736 of the Companies Act 1985).
  2. We may disclose your personal information to third parties:
    • in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
    • if we or substantially all of business or our assets are acquired by a third party or if we have a corporate reOrganization, in which case personal information held by it about its customers will be one of the transferred assets;
    • if we integrate with another social networking site to enhance the Services we provide;
    • if we are under a duty to disclose or share your personal information in order to (i) comply with any legal obligation; (ii) to enforce or apply our terms of use or acceptable use policy; or (iii) protect the rights, property, or safety of our company and business and assets, our employees, our Users, our service providers or others. This includes exchanging information with other companies and Organizations for the purposes of fraud protection and credit risk reduction.
  3. From time to time, we or our business partners would like to contact you with information on products or services we think would be valuable or of interest to you. As such we would like to share your information with our business partners for this purpose. We or they may contact you by mail or telephone to let you know about any goods, services or promotions, which may be of interest to you. We will always give you an option to opt out on registration. You are also given the option to opt in to receive such information by email or SMS and we will only send this information to you if you have opted in. Please be aware that if you do opt out (or opt in, as the case may be) you may not be made aware additional benefits, products or services that could be of assistance or useful to you.
  4. We will not supply your information to a third party for marketing purposes if you tell us not to.
  5. You may also exercise your right to opt out of the use of your information being supplied to a third party, for marketing purposes at any time, by going to privacy settings. Should you do this, your details will be added to a suppression list to ensure we deal with your request, but please note that this may take a little time to be effective (in other words, your notification is not retroactive).
  6. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users in general terms. We may also use or we may permit our advertisers to use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in London). We may make use of the personal information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to a target audience with a particular demographic.

Security

  1. We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
  2. Emails and instant messaging and similar means of communication with other Users are not encrypted and we strongly request you not to communicate any confidential information through these means

Third Party Service Providers

  1. We use third party service providers in order to manage and administer your account and provision of the Services, to perform functions and to provide services to us, including website hosting, development and maintenance, customer relationship management (for Organizations in particular), market and User research, database management and direct marketing campaigns. Your personal information will be shared with these third parties but only to the extent necessary for functions or services to be performed. Third party services providers enter into contracts with us obliging them to keep secure your personal information.

How we use Cookies and IP Addresses

  1. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical personal information about our users' browsing actions and patterns, and does not identify any individual. The connection between you personally identifiable information and your IP address will not be shared with third-parties without your permission or except when required by law or regulation.
  2. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. A cookie asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
  3. We use traffic log cookies to identify which pages are being used. We use persistent cookies to recognize you after your first login to the Site post registration and we sometimes use session cookies to. Additionally, if you log out of the LinkedIn website you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a "session" cookie, identify a particular visit to the Site.
  4. We use traffic log cookies to identify which pages are being used. We use persistent cookies to recognize you after your first login to the Site post registration and we sometimes use session cookies to. Additionally, if you log out of the LinkedIn website you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a "session" cookie, identify a particular visit to the Site.
  5. From time to time we may allow other companies to serve advertisement or other communications to Users. We may target some of these advertisements to a selection of Talent who fit a certain general profile (for example 'those studying law'). We do not use personally identifiable information for targeting or provide such information to any third party advertiser outside of the Brave New group.
  6. We may also include a file, known as a web beacon, from these companies within pages served by us so they may provide anonymized, aggregated auditing, research and reporting for advertisers as well as to target advertisement to you while you visit other websites.
  7. Web-log files, cookies and other recognition technologies help us:
    • to improve the Site and to deliver a better and more personalized service for Users;
    • estimate audience size and usage pattern;
    • store information about your preferences, and so allow us to customize the Site according to your individual interests;
    • to speed up your searches;
    • to recognize you when you return to our site, and to analyze personal information about web page traffic.
  8. A cookie in no way gives us access to your computer or any information about you, other than the personal information you choose to share with us. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Site.
  9. Please note that by opting out of cookies, web-log files or other recognition technology, it may affect your user experience on the Site.
  10. Please note that our advertisers and Organizations websites' may also use cookies, over which we have no control.

Links to Other Websites

  1. The Site may contain links to enable you to visit other websites of interest easily. We also facilitate your ability to link to and from other social networking sites, including Facebook and LinkedIn. However, once you have used these links to leave the Site or interact with other social networking sites, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such other websites and such other websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Where we Store Your Personal Information

  1. The Site is intended to be used by people all other the world.
  2. The personal information that we collect from you may be collected from, transferred to, and/or stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff or our service providers operating outside the EEA who work for us or for one of our suppliers. By registering and submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy policy.
  3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
  4. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Your Rights and Obligation

  1. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
  2. You may request details of personal information which we hold about you under the Personal information Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to: BraveNewTalent Parker Tower 43-49 Parker Street Holborn, London WC2B 5PS United Kingdom
  3. If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
  4. You have the right to ask us not to process your personal information for marketing purposes. Usually we will inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information.
  5. The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
  6. As a User, you have certain obligations toward the other Users with whom you will be communicating. Certain of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members, such as ours. In particular you must:
  7. Any violation may lead to the restriction, suspension or termination of your account, as we take these principles seriously.
  8. You can update your personal information, choose how your personal information is dealt with (including what is on your public profile and what is private) as well as visibility and accessibility. You can also tell us to close your account at any time. If you update your personal information we may keep a copy of your original personal information or older versions provided in our backup files or on our database.
  9. You can also close your account. On account closure, we will use our reasonable endeavors to remove your name and other personally identifiable information from public view, however this may not be possible if other search engines (e.g. Google) or social networking sites (e.g. Facebook) have your information. We may retain certain information or Site content contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, or if required by law.

Contact

  1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us at the address above.

Governing Law

  1. This policy is governed by the Law of England and Wales. Any disputes arising from or in connection with this Policy shall be subject to the exclusive jurisdiction of the English Courts.

Variation

  1. We may revise this Privacy Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. If you use the Site or Services after notice of variations have been published on our site, you hereby provide your consent to the variations.
  2. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on the Site.