Categories of Personal Information

Our Business Purposes

Identifiers, including name, alias, postal address, email address, telephone number and other contact information, information of professional and personal references and referral sources, emergency contact information, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number and other similar identifiers

• To manage, administer and otherwise provide the DeWinter Group Services
• To complete transactions, fulfill terms or obligations, and otherwise perform DeWinter Group Services
• To identify and contact Candidates for job opportunities with Clients seeking talent
• To help Candidates identify strengths and preferences for better job placement
• To match job opportunities, including those of Clients seeking talent, to Candidates
• To match Candidates to job opportunities
• To meet legal obligations as an employer or potential employer, and
• to assist our Clients in doing so
• To contact identified person(s) in case of an emergency
• To notify you of changes to our Site(s), our Services, or our policies and practices
• To respond to your inquiries
• To personalize our Site(s) to Visitors
• To verify the identity of consumers or their Authorized Agents who submit requests relating to their personal information
• To send you emails, mail, messages and other communications about DeWinter Group for marketing, advertising and other promotional purposes
• To deidentify, aggregate and/or anonymize data for statistical analysis purposes
• To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to physical safety of any person, and/or violations of DeWinter Group policies, procedures and/or contracts
• To comply with applicable laws and legal requirements, such as court orders, subpoenas, and search warrants, and cooperate with regulatory agencies and law enforcement
• To establish or exercise legal rights and/or defend against legal claims of DeWinter Group, of its Clients, and of others for whom DeWinter Group has a legal duty to do so

Professional or employment-related information, and educational information, including information on your resume or CV, employment history, education history, certifications, languages, security clearance information, work authorization, past and expected compensation, and other work-related information

• Same as above

Inferences drawn from any other personal information, including assessment of aptitudes, abilities and preferences

• Same as above

Audio, electronic, visual or similar information, included voicemail messages, phone and/or video interviews, recorded phone calls, etc.

• Same as above
  

Characteristics of protected classes, including race, nationality, ethnic origin, gender, gender identity, gender expression, age, disability status, military and veteran status, and other protected classifications under California and federal law

• Same as above
• For purposes of equal opportunity or affirmative action programs, as required or permitted by law

Commercial information, including records of personal property, and purchasing or consuming histories or tendencies

• Same as above
• To evaluate our Site(s) and Services
• To modify, improve and enhance our Site(s) and Services

Internet or other electronic network activity and geolocation data, including Internet Protocol (IP) address, browsing history, search history, interaction with websites, applications or advertisements 

• To protect DeWinter Group’s Site(s) and Services
• To modify, improve and enhance DeWinter Group’s Site(s) and Services
• To analyze visits and activity on our Site(s)
• To promote and market DeWinter Group and its Site(s) and Services.
• For more information about our use of cookies and online tracking, please see our Cookie Notice below.
• To detect security incidents, protect against malware, illegal activity, and/or pursue those responsible
• Identify and repair errors that impair functionality

III. WHEN, TO WHOM AND WHY WE SHARE THIS INFORMATION 

DeWinter Group does not sell your personal information, and it has not sold any personal information in the preceding 12 months.

We share or disclose your personal information as follows:

• To perform our Services:  If you are a Candidate or prospective Candidate, we may share your personal information with Clients and other employers looking for talent, for the purpose of providing our Services, e.g. looking for job opportunities, conducting executive searches, recruiting, hiring and/or filling job positions on a consulting or contract basis to meet our Clients’ accounting, finance and IT professional staffing needs.
• Vendors, consultants and other service providers: We use vendors, consultants and other service providers to assist us in providing our Site(s) and Services, and it may be necessary for us to provide them with access to your personal information, e.g., vendor, consultants and service providers who provide IT support, who provide background checks, and who provide online software solutions as part of our Services, such as the online platform for Candidates to apply for job opportunities.
• In compliance with laws, at your consent or direction, and to protect rights, property and safety: We may preserve and disclose your information if we believe doing so is legally required or appropriate: (i) to comply with applicable laws and regulations, law enforcement or national security requests and legal process, such as a court orders or subpoenas; (ii) in response to your consent or at your direction to disclose the information; (iii) to protect your, our, or another’s rights, property, or safety; or (iv) to enforce our policies or contracts.
• Merger, Sale, or Other Asset Transfers:  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be shared as part of such a transaction as permitted by law and/or contract.
• With your consent: We may share or disclose your personal information for other purposes per your request or with your consent.
• Note re our Clients’ own policies and procedures:  If you are or have been contracted or employed by a Client as a result of our Services, DeWinter Group’s Client will process your personal information in accordance with its own policies and procedures.

IV. CALIFORNIA PRIVACY RIGHTS 

If you are a resident of California, effective January 1, 2020, you have rights with respect to your personal information under the California Consumer Privacy Act (“CCPA”), as follows:

• Right to be informed: You have the right to be informed of the categories of personal information collected about you, the sources from which your personal information was collected, and the business or commercial purposes for which your information is used, disclose or sold, as well as the categories of third parties to whom your information is disclosed or sold.
• Right of access and to obtain a copy:  You have the right to request access to and obtain a copy, no more than twice in a twelve-month period, of your personal information collected during the 12 months before your request.
• Right of deletion: You have the right to request that your personal information be deleted, subject to certain exceptions. For example, your request to delete is subject to the need to complete transactions for which the personal information was collected and comply with legal obligations.
• Right to opt-out of the sale of personal information: DeWinter Group does not sell personal information to third parties.
• Right not to be discriminated against: In exercising any of the foregoing consumer privacy rights, you have the right not to be discriminated against. DeWinter Group will not deny you Services or provide you a different level of services for exercising our rights, unless the difference is reasonably related to the value of your information.

If you would like to exercise your rights, please contact DeWinter Group:

• By calling us at: 1-833-DWG-DATA or (1-833- 394-3282)
• By emailing us at:  Privacy@DeWinterGroup.com
• By writing to us at:

DeWinter Group

Attention:  PRIVACY REQUEST

1919 South Bascom Avenue, Suite 250

Campbell, California 95008

You may also designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with your written and signed permission to act on your behalf and by directly confirming with us that you have provided the authorized agent permission to submit the request. As permitted by law, we may require you to verify your identity in response to a request even if you choose to use an agent. The authorized agent will also need to verify its own identity directly with us.

After you or your authorized agent submit a request, we require a high degree of certainty that we have verified that the requester is, in fact, the consumer whose personal information is the subject of the request. We will endeavor to do so using the personal information that we, or one of our vendors, consultants or service providers, have about the consumer. We may need to obtain additional personal information from the consumer or from other third-party sources to verify the requester’s or authorized agent’s identity, in which case, such additional personal information will be used solely for verification purposes. If we are unable to verify your identity, we reserve the right to deny your requests.

Other California Privacy Rights:  California’s “Shine the Light” law (California Civil Code section 1798.83) gives customers who are California residents the right to ask, once a year, (1) what personal information was disclosed to third parties for those third parties’ direct marketing purposes in the prior calendar year; and (2) the identities of the companies with whom the information was shared. The terms “customers” and “personal information” have the meaning given by the Shine the Light (California Civil Code Sec 1798.83). 

We do not share personal information, as defined in California Code Civil Section 1798.83, with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with California’s Shine the Light law by sending us a written request to privacy_inquiry@dewintergroup.com or by mailing us a letter to: DeWinter Group, 1919 South Bascom Avenue, Suite 250, Campbell, California 95008, (Attention: Privacy Inquiry). Any such written request must include “California Shine the Light Law Request” in the first line of the description and include your name, street address, city, state, and zip code. We are only required to respond to one Shine the Light law request per customer per year, and we are not required to respond to requests made by means other than through this email address and mailing address. Further note that “Shine the Light” rights and CCPA rights are provided under different statutes and must be exercised separately.

V. YOUR CHOICES

Marketing and Promotional Communications: In accord with your marketing preferences and applicable privacy and data protection laws, we may send you updates via email about opportunities or services we think may be of interest to you, such as active job postings that match your criteria, newsletters, articles, surveys, and event information. If you would like to discontinue receiving such marketing or promotional communications from us, you can unsubscribe or opt-out from receiving such marketing communications from us. Where you have consented to our processing of your information, you may withdraw that consent at any time and opt-out of further processing.

VI. COOKIES AND ONLINE TRACKING; “DO NOT TRACK”

DeWinter Group uses “cookies” and similar technologies to help us tailor our Site(s) and your online experiences, and for analytical purposes. For more information about cookies, the types of cookies we use, and how we use them, please see our Cookie Notice. 

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals. For information about “do-not-track”, please visit https://allaboutdnt.com/.

VII. CHILDREN’S PRIVACY

Our Site(s) are not directed to children under the age of 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. The terms “personal information” and “child” have the same meaning given to them by the Children’s Online Privacy Protection Act (COPPA). If we learn that a user is under this age, we will not use or maintain his/her personal information. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

VIII. SECURITY OF YOUR INFORMATION

We maintain reasonable safeguards to protect your information against unauthorized access, use, or disclosure or accidental loss or destruction, and we require third parties providing services on our behalf to do the same. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us.

IX. LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT

Our Site may contain links to other third-party websites that are not owned or operated by us. Our Privacy Policy only applies to our Site, and we are not responsible for the privacy practices or the content of other third-party websites. Any information you disclose to other websites are not subject to the provisions of this Privacy Policy. You should check the privacy policies of those sites before providing your information to them.

X. DATA RETENTION

We will retain your information for as long as needed to provide our Services or as otherwise required or permitted by law. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

XI. CHANGES AND POLICY UPDATES

We may change information on the Site and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the Site. We may also notify you by other means, such as sending you an email. We encourage you to periodically review this page for the latest information on our privacy practices.

XII. CONTACT US

If you are disabled and would like access to this Privacy Policy in an alternative format, or if you have any questions about this Privacy Policy, please call us at 1-833- 394-3282, email us at Privacy@dewintergroup.com, or send us a written letter to DeWinter Group, 1919 South Bascom Avenue, Suite 250, Campbell, California 95008, (Attention: Privacy).

Your Privacy Rights

At the DeWinter Group, we take your privacy very seriously, and we never sell your information; we use it to enhance your experience working with us. 

When it comes to your rights as a consumer, we want to make sure you have everything you need to make informed decisions. You have the right to:

Know how your personal information is used;

Access, request and receive the personal information we have collected in a portable manner;

Object to having your data sold or shared;

And request that we delete your personal data.

To submit a request via phone, contact 1-833-DWG-DATA or 1-833- 394-3282. To submit a request by email, please email privacy@dewintergroup.com.