CCPA ADDENDUM

Last updated:

August 09, 2022

This policy for California residents supplements the information contained in the Data Privacy Policy of White Crow Research Private Limited (““WhiteCrow / Our””) through the website ‘www.whitecrow.co’ (“Website”) featuring the portals ‘talent.whitecrow.co’ (“Talent Platform”) and ‘hire.whitecrow.co’ (“Talent Marketplace”) (Talent Platform and Talent Marketplace are collectively referred to as “Portals”). WhiteCrow has prepared this addendum to the Data Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws applicable (“CCPA Addendum”). This CCPA Addendum applies only to information submitted to and collected by WhiteCrow / Website including its Portals, through the use of the Services by:

(i) the candidate accessing/signing-up on the portal ‘talent.whitecrow.co’ / Talent Platform, with the intent to seek job opportunities (““Individual Candidate””); or

(ii) the client and/or the designated employees of such client, subscribing to the portal ‘hire.whitecrow.co’ / Talent Marketplace with the intent to search for appropriate talents from across the internet to suit an employer’s job profile requirements (“Subscribing Candidate”). (Hereinafter, the Individual Candidate and the Subscribing Client who reside in the State of California are collectively referred to as “You / Your”).

It is to be noted that as this CCPA Addendum supplements the Data Privacy Policy / Agreement, the capitalized terms unless defined herein shall have the same meaning assigned to them in the Terms and Conditions and the Data Privacy Policy.

1. Information :

   1. WhiteCrow through the Website / Portals may collect the following list of PII in connection with Your use of the Services:

      • ‘Identity Data’ such as name of the employer entity/Subscribing Client, name of the Individual Candidate, employer entity’s website, social media profiles, username, real name, alias, postal address, unique personal identifier, online identifier, ‘Internet Protocol’ address, email address, account name or other similar identifiers.
      • ‘Personal Data’, in case of Individual Candidate, such as gender, nationality and place of residence.
      • ‘Contact Data’ such as physical address, email address, social media address, telephone number and any other contact information You provide to WhiteCrow / Website.
      • ‘Professional Data’, in case of Individual Candidate, such as qualification, training and certifications, professional skills and experience, language skills.
      • ‘Employment Data’, in case of Individual Candidate, such as current/recent role, including job title, department, reporting line, responsibilities, salary, benefits and notice periods.
      • ‘Transaction Data’, in case of Subscribing Client, such as details about payments to and from the Subscribing Client, and details regarding the subscribed Services through the portal ‘hire.whitecrow.co’ / Talent Marketplace.
      • ‘Technical Data’ such as device IDs, Your login data, access dates and times, browser type and version, device information, ‘Cookie data’, time zone setting, browser plug-in types and versions, platform and other technology on the devices You use to access the Website / Portals.
      • ‘Profile Data’ such as Your username and password, searches made by You, preferences, user-generated content, feedback and survey responses.
      • ‘Usage Data’ such as information about how You use the Website / Portal and the Services.
      • Personal information categories listed in the California Customer Records statute [Cal. Civ. Code § 1798.80(e)], such as a name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
      • Similar networking activities such as Your browsing history, search history, information on Your interaction with a website, application or advertisement.

   2. As stated above, WhiteCrow / Website collects information that identifies, relates to, describes, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with You or device used by You. WhiteCrow / Website does not collect PII as stated below:

      • Protected classNameification characteristics under California or federal law.
      • Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
      • Biometric information such as genetic, physiological, behavioural and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face-prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
      • Sensory data.
      • Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, className lists, student schedules, student identification codes, student financial information or student disciplinary records.
      • Publicly available information from government records.
      • De-identified or aggregated consumer information.

      • Information excluded from the CCPA’s scope, such as:

        • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
        • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CalFIPA), and the Driver’s Privacy Protection Act of 1994.

   3. WhiteCrow / Website obtains the categories of personal information listed in Clause 1.1, above, from the following categories of sources:

      • Directly obtained from You. For example, from documents that You provide to WhiteCrow / Website during implementation and regular usage of Our Services.
      • Directly and indirectly from Your activity on the Website/ Portals. For example, from submission of the Subscription Form (for the Subscribing Client) or the information submitted otherwise through the Website and through usage details collected automatically.

2. Use of Personal Information:

   WhiteCrow / Website may use or disclose the personal information WhiteCrow / Website collects for one or more of the following business purposes:

   • To carry out Our obligations and enforce Our rights arising from the Agreement/agreement(s) entered into between You and WhiteCrow, upon subscription/accessing/signing-up to the Services provided on the Website / Portals, including Services, billing, and collections.
   • To fulfill or meet the reason for which the information is provided.
   • To provide You with information or Services that You request from WhiteCrow / Website.
   • To provide You with alerts and other notifications/notices concerning Our Services or events or news, that may be of interest to You.
   • To improve the Website and the Portals and present its contents to You.
   • For testing, research, analysis and product/Service development.
   • As necessary or appropriate to protect Your rights, property or safety, and the rights, property or safety of WhiteCrow / Website, Customers or others.
   • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
   • As described to You when collecting PII or as otherwise set forth in the CCPA.
   • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by WhiteCrow / Website is among the assets transferred.

   WhiteCrow / Website may use or disclose Your PII for the purposes mentioned in the Data Privacy Policy in addition to the above list of use or disclosure of Your PII, which is not inconsistent with the CCPA Addendum.
   
   WhiteCrow / Website will not use the PII WhiteCrow / Website collected for materially different, unrelated or incompatible purposes, without providing You notice.

3. Your Rights and Choices:

   The CCPA provides You (California residents) with specific rights regarding their personal information. This section describes Your CCPA rights and explains You how to exercise those rights.

   Access to Specific Information and Data Portability Rights:

   You have the right to request that WhiteCrow / Website disclose certain information to You about WhiteCrow’s / Website’s collection and use of Your PII over the past 12 months. Once WhiteCrow / Website receives and confirms Your verifiable consumer request, WhiteCrow / Website will disclose to You:

   • The categories of PII collected about You.
   • The categories of sources for the PII collected about You.
   • Our business or commercial purpose for collecting or selling that PII.
   • The categories of third parties with whom WhiteCrow / Website shared that PII.
   • The specific pieces of PII collected about You (also called a data portability request).

   • If WhiteCrow / Website has sold or disclosed Your PII for a business purpose, two separate lists disclosing:

     • sales, identifying the PII categories that each category of recipient purchased; and
     • disclosures for a business purpose, identifying the PII categories that each category of recipient obtained.

4. Deletion Request Rights:

   You have the right to request that WhiteCrow / Website delete any of Your PII that WhiteCrow / Website collected from You and retained during the Term / Subscription Term / Renewal Term / Trial Subscription Term, as the case may be, subject to certain exceptions. Once WhiteCrow / Website receives and confirms Your verifiable request, WhiteCrow / Website will delete Your PII from Our records, unless an exception applies.

5. Exercising Access, Data Portability, and Deletion Rights:

   To exercise the access, data portability and deletion rights described above, please submit a verifiable request to WhiteCrow by either:

   • Email: ccpa@whitecrow.co
   • Contact at: +91-22-69229111

   Only You and/or a person registered with the California Secretary of State that You have authorized to act on Your behalf, may make a verifiable request related to the PII.

   The verifiable candidate request must:

   • Provide sufficient information that allows WhiteCrow / Website to reasonably verify that, You are the person about whom WhiteCrow / Website collected personal information or an authorized representative thereof.
   • Describe Your request with sufficient details that allows WhiteCrow /Website to properly understand, evaluate and respond to it.

   WhiteCrow / Website cannot respond to Your request or provide You with PII if WhiteCrow / Website cannot verify Your identity or authority to make the request and confirm that the PII relates to You. WhiteCrow / Website will use the PII provided in the verifiable request to verify the requestor’s identity or authority to make the request.

6. Non-Discrimination:

   WhiteCrow / Website will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, WhiteCrow / Website will not:

   • Subject to the terms as stipulated in the Terms and Conditions, deny You Services.
   • Charge the Subscribing Client different prices or rates for Services, other than as mentioned in the Subscription Form or on the portal ‘hire.whitecrow.co’.
   • Subject to the provisions of the Service Level Agreement, provide You a different level or quality of Services.
   • Subject to the provisions of the Service Level Agreement, suggest that the Subscribing Client may receive a different price or rate for Services or a different level or quality of Services.

7. Changes to Our Privacy Notice:

   WhiteCrow / Website reserves the right to amend this CCPA Addendum at Our discretion and at any time. When WhiteCrow / Website makes changes to this CCPA Addendum, the same will be notified to You by posting it on the Website and shall indicate the date of the last revision.

8. Contact Information:

   If You have any questions or comments about this CCPA Addendum, the ways in which WhiteCrow / Website collects and uses Your PII, Your choices and rights regarding such use, or wish to exercise Your rights under the California law, please do not hesitate to contact WhiteCrow at:

   • Email: ccpa@whitecrow.co
   • Contact at: +91-22-69229111