Privacy Policy

This Fulsy Privacy Notice provides a framework of understanding about the personal data that is collected by Fulsy and its subsidiaries and affiliates listed here (as applicable, thereinafter each separately and/or jointly called the "Data Controller"). Personal data collected by the Data Controller will be controlled and processed in accordance with the terms of this Privacy Notice.

This Privacy Notice applies to (1) our job candidates and recipients of our career services, (2) our associates, who are people we source or place on assignment with one of our clients, or individuals to whom we provide outplacement or career transition services, (3) users of the websites and apps listed here (the "Sites"), and (4) representatives of our business partners, clients and vendors.

This Privacy Notice describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data. We also describe how you can contact us about our privacy practices and to exercise your rights. In general, our privacy practices conform with local law and regulation. Accordingly, our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements; and you can view specific local terms by visiting our local websites.

Information We Collect

We collect personal information about you in various ways, such as through our Sites and social media channels; at our events and through phone and fax; through job applications and in connection with in-person recruitment; and in connection with our interactions with clients and vendors. We may collect the following types of personal information (as permitted under local law):

• contact information (such as name, postal address, email address and telephone number);
• username and password when you register on our Sites;
• information you provide about friends or other people you would like us to contact. (The Data Controller assumes that the other person previously gave an authorization for such communication);
• other information you may provide to us, such as in surveys or through the "Contact Us" feature on our Sites

In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data (as permitted under local law):

• employment and education history;
• language proficiencies and other work-related skills;
• Social Security number, national identifier or other government-issued identification number;
• date of birth;
• gender;
• bank account information;
• citizenship and work authorization status;
• benefits information;
• tax-related information;
• information provided by references; and
• information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment.

We may also collect the following types of personal data upon receiving your explicit consent (where required by applicable law):

• disabilities and health-related information; and
• results of drug tests, criminal and other background checks.

In addition, we may collect information you provide to us about other individuals, such as information related to emergency contacts.

How We Use the Information We Collect

The Data Controller collects and uses the data gathered for the following purposes (as permitted under local law):

• providing workforce solutions and connecting people to work;
• creating and managing online accounts;
• processing payments;
• managing our business partner, client and vendor relationships;
• where permitted under law and consistent with this Privacy Notice, to send promotional materials, alerts regarding available positions and other communications;
• where permitted under law, for communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
• responding to individuals' inquiries and claims;
• operating, evaluating and improving our business (including developing, enhancing, analyzing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
• protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities; and
• complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.

All processing will be carried out based on adequate legal grounds which may fall into a number of categories, including:

• consent or explicit consent from the data subject, where required by applicable law;
• to ensure that we comply with a statutory or contractual requirement, or a requirement necessary to enter into a contract (e.g. processing your personal data to ensure that your wages and taxes are paid correctly); or
• it is essential and necessary for the legitimate interest of the Data Controller, as described in more detail below (e.g. allowing access to a website in order to provide the services offered).

In addition to the activities listed above, if you are an associate or job candidate and you apply for a position or create an account to apply for a position, as permitted under local law, we use the information described in this Privacy Notice for the following purposes:

• Providing you with job opportunities and work;
• providing HR services to you, including administration of benefit programs, payroll, performance management and disciplinary investigations or actions;
• providing additional services to you, such as training, career counselling and career transition services;
• assessing your suitability as a job candidate and your associate qualifications for positions; and
• performing data analytics, such as (i) analyzing our job candidate and associate base; (ii) assessing individual performance and capabilities, including scoring on work-related skills; (iii) identifying skill shortages; (iv) using information to match individuals and potential opportunities, and (v) analyzing pipeline data (trends regarding hiring practices).

We also may use the information in other ways for which we provide specific notice at or prior to the time of collection.

Information We Share

We do not disclose personal data that we collect about you, except as described in this Privacy Notice or in separate notices provided in connection with particular activities. We may share personal data with vendors who perform services on our behalf based on our instructions. We do not authorize these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.

In addition, we may disclose personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).