Privacy Notice

1.

Application and Scope

This Privacy Notice applies to your use of Sourcinc’s services and website.

2.

Definition of Personal Information

Personal information means any information about an identifiable individual.

3.

Collection and Use of Personal Information

As recruiters, we may collect personal information about you directly from you and from third parties whom you authorized to share such information with us, such as LinkedIn and Indeed. We may use such information to service our customers and for our internal purposes.

Sourcinc generally collects personal information from or about its customers, candidates and other individuals with whom it deals, and thereafter uses it, for the following purposes:

• to establish, develop and preserve its business relationship respectively with its customers and other individuals with whom it deals;
• to create, establish and administer customers’ accounts and to respond to customer or supplier inquiries;
• to provide the services that it offers, or receive the products or services that it requests, and ensure that all related transactions are supported and implemented;
• to establish or verify the credentials of candidates that it refers to its customers;
• to authenticate the identity and preserve the privacy of customers and candidates contacting Sourcinc by telephone, electronic means or otherwise;
• for internal training and quality assurance purposes;
• as necessary, to establish or verify the credit of persons that use, or intend to use, one or more of the services offered by Sourcinc;
• to manage its businesses and ensure the efficiency, reliability and security of its systems;
• to meet legal and regulatory requirements and allow Sourcinc to meet contractual requirements relating to the services provided to customers and candidates;
• to ensure its records are accurate and to protect customers and Sourcinc from error and fraud;
• to understand and assess the interests, wants and changing needs of customers with a view to improving its products and services and developing new ones;
• to provide personalized services as well as product recommendations to customers; and
• to conduct surveys on the quality of our products and services.

4.

Your Consent

When you use our services or visit our website, you agree to be bound by this Privacy Notice.

5.

Right to Withdraw Consent

You can withdraw your consent to our use of your personal information at any time. If you do so, we may not be able to provide with all of our services. We may nonetheless keep your information if we have a legal basis to do so.

Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, Sourcinc may limit the services it is able to provide users, customers and candidates. You may also withdraw your consent as follows:

• Recruitment communications. You may decide that you do not want to be contacted by us on behalf of our customers who are looking for candidates. In such a case, you may advise us by email or telephone by communicating with our team using the contact information detailed in the How to Contact Us section below.
• Telephone marketing and Quality control communications. You may decide that you prefer Sourcinc not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by telephone for marketing purposes or by email for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the How to Contact Us section below.
• Commercial Electronic Communications, marketing emails. You can always limit the communications that Sourcinc sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.

6.

Sharing of Personal Information

We may share your personal information with our clients who are looking for candidates and with service providers who are assisting us with our operations. We may also share your information when required to do so under applicable law or to a person who we believe is authorized to represent you. Finally we may provide your information to third parties should we undergo a business transaction, reorganize or finance our business.

Your information may be made available by Sourcinc to third-parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. Sourcinc will NOT sell, rent or trade your personal information to any third party. However, we may share your personal information when authorized by law or as follows:

• To clients. We offer talent sourcing services to our clients who mandate us from time to time to identify potential employment candidates. We then search the Internet, including but not limited to professional social media sites, to identify individual profiles which may meet our customer’s requirements. We then gather the information you agreed or decided to publish on those websites and create a report for our client which list basic information about potential candidates. We may contact you directly to discuss our client’s employment opportunities. In addition, if the client decides to move forward with the recruitment process and identifies you in our report as being interesting, we may contact you to inquire whether you would be interested in such opportunity.
• To third party service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by Sourcinc to perform work on its behalf, including for the collection of customer accounts, customer credit verification, installation of services and quality control assessment. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. Sourcinc will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Sourcinc itself.
• As permitted or required by law. From time to time, Sourcinc may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
• Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
• Other types of sharing. We may provide your information to an individual who, in the reasonable judgement of Sourcinc, is acting on behalf of the individual in question, such as through a power of attorney.

7.

Website Privacy

We collect and use the personal information you agreed to share directly with us or with third parties. We collect technical information through our website and social media channels, using cookies and other similar technologies. You can block these cookies but in such a case we may not be able to provide you with all our website’s functionalities.

Sourcinc generally collects and uses personal information from or about its website visitors and users as follows:

• Information you provide. In many cases, we collect personal information directly from you when you visit or use our website. For instance, we may collect the following types of information:
  • Inquiries. We may collect your name, contact information, e-mail address and any information you provide us when you make an inquiry or contact us through our website. We will only use this information to provide you with the information requested or to contact you in order to answer your questions and/or requests.
  • Candidates. We may collect your name, contact information, e-mail address, work history, education history when you submit your candidacy to us. We will only use this information to identify relevant employment opportunities for you based on the recruitment needs of our customers.
  • Requests for Services. We may collect your name, contact information, e-mail address and any other information provided to us when you sign up to receive our newsletter or when you submit a request or an order for Sourcinc services. We will only use this information to process and answer your request or to manage our everyday business needs in connection with such participation or request.
  • Your Account. We may collect your information when you log-in on our website through our Login page and interact with us through your account. For instance, you may decide to subscribe to pre-authorized payments and modify your account information or other preference settings. We will only use the information that you provide us in accordance with this Notice.
  • Satisfaction Survey. When you visit our website, you may, from time to time, be invited to participate to a satisfaction survey. In such case and if you decide to participate to our survey, we may collect your postal code, email address and other information deemed important to complete such survey. We will only use your information for quality assurance purposes.
• Technical information. When you visit our website, we may collect, using electronic means such as cookies, technical information. This information may include information about your visit to our website, including the IP address of your computer and which browser you used to view our website, your operating system, resolution of screen, location, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of page views, information you entered, advertisements you have seen, etc. This data is used to measure and improve the effectiveness of our website or enhance the experience for our customers. For instance, it may be used to ensure that the services advertised on our website are available in your area [or that we are not showing you the same ads repeatedly]. We treat this information as personal information when it is associated with your account or contact information. For instance, we may collect and use the following type of information when you visit and/or interact with us on our websites:
  • Social media. This information will be collected primarily from you as information voluntarily provided to us through our Website or social media channels but we may also collect it from you where we communicate with you by telephone, post, email or other means of communication.  We may also collect personal information about you from your use of social media networks (LinkedIn, Indeed, Facebook, Instagram, Pinterest, Twitter, You Tube and Snapchat) you participate in (“Social Media Channels”). Where lawful to do so we may also obtain it (or combine it with information from) from public sources, third party service providers and individuals who have indicated you have agreed for them to provide your personal information. You may also choose to participate in a third party application or feature (such as our Facebook page) through which you allow us to collect (or the third party to share) information about you, (including personal information) such as details of your friends/connections, "likes", comments you have shared, groups and location. In addition, we may receive information about you (including your personal data) if other users of a third party website give us access to their profiles and you are one of their friends/connections or information about you is otherwise accessible through your friends’/connections´ web page, profile page, or similar page on a Social Media Channel or other third party website or interactive service. We may supplement the information we collect about you directly with the information we receive from third parties in order to enhance our ability to serve you, to tailor our content to you and send you employment opportunities which we believe may be of interest to you.
  • Google Analytics: We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
  • Google AdWords: We use Google AdWords Remarketing to advertise Sourcinc across the Internet and to advertise on third party websites (including Google) to previous visitors to our websites. AdWords remarketing will display ads to you based on what parts of the Sourcinc website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
  • Interest-based Advertising. Sourcinc may also allow a limited number of trusted third parties to install cookies on your hard drive from our websites. Our websites may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about you, such as your page views on our website, your information requests or purchases on our websites. We do not provide any personal information to advertisers or to third party sites that display interest-based ads on our websites. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on our websites are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on our websites directly to your browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. We do not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by our Privacy Policy. Please contact them directly for more information about their privacy practices. You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Digital Advertising Alliance of Canada  - by visiting the DAAC opt-out page  or of the European Interactive Digital Advertising Alliance by visiting http://www.youronlinechoices.eu/
• Your Choice with Cookies. You can block the use of cookies by activating the settings in your browser. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to withhold consent, or subsequently block cookies, you may not be able to access all or part of the content of our website. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer.
• Privacy Policies of Third Parties. This Privacy Notice only addresses the use and disclosure of information by Sourcinc. Other websites that may be accessible through our Website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.
• Mobile Apps. In the event that you download and/or use any of our applications, we may require and collect, directly from you, information necessary to authenticate you. We may also record your IP geolocation, allowing us to block the access when the user is outside of Canada or France.

8.

Personal Information Stored or Processed Outside of Canada and France

We store and process your personal information in Canada, France and other countries where we or our service providers maintain facilities. We strive to protect your personal information in accordance with this Privacy Notice, wherever it is stored or processed.

• Personal information collected by us may be stored and processed in your region, or in any other country where Sourcinc or its affiliates, subsidiaries or service providers maintain facilities. Sourcinc maintains its services in Canada and France. Typically, the primary storage location is in the customer’s region. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the information we collect under this Privacy Notice is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.
• Where personal information that we manage is transferred, processed and stored outside Canada or France, and therefore may be available to government authorities under lawful orders and laws applicable there. Sourcinc will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protec

9.

Security of Personal Information

We protect your personal information against security incidents.

10.

Retention

We only retain your personal information to fulfill the purpose for which it was collected and in accordance with applicable law.

• Sourcinc retains personal information for as long as necessary to provide the services and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise required by law. Personal information that is no longer required to fulfil the identified made anonymous.
• Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria we use to determine the retention periods include:
  • How long is the personal information needed to provide the services and operate our business? This includes such things as maintaining and improving the performance of those services, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most data retention periods.
  • Do users provide, create, or maintain the information with the expectation we will retain it until they affirmatively remove it? Examples include your curriculum vitae. In such cases, we maintain the data until you ask us to delete or to cease using it, or until our retention policy settings are fulfilled.
  • Is Sourcinc subject to a legal, contractual, or similar obligation to retain the data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.

11.

Access and Correction

12.

How to Contact Us

If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Sourcinc has about you, please contact us by email at By email at: Privacy.office@sourcinc.com or by mail at:

1.

Lawful Bases for Processing

We will only process your personal information lawfully.

We only process your personal information if we have a lawful base to do so, which includes:

• Consent: where you have given your consent,
• Contract: where processing is necessary for the performance of a contract with you (e.g. to provide the services you have requested), or
• Legitimate interests: for example, we may process your personal data to protect you, us, or others from threats (such as security threats or fraud), to comply with laws that apply to us; to enable or administer our business (such as for quality control, consolidated reporting, and customer service), to manage corporate transactions, (such as mergers or acquisitions); or to understand and improve our business or customer relationships generally.

2.

Transfer of Your Personal Information Outside of the EEA or Switzerland

We may process your personal information outside of your country of residence.

3.

Additional Rights Regarding Your Personal Information (Restriction of Processing; Deletion; Objection to Processing; Data Portability)

You have the right to restrict how we process your personal information, to object to our processing, to ask that we delete your personal information and to request a copy of your information in a machine-readable format.

In addition to the rights mentioned in the Access and Correction section of the Privacy Notice, you may, subject to applicable law:

• have the right to restrict or limit the ways in which we process your personal information for instance where you believe your data is inaccurate;
• have the right to object to the processing of your personal information by us in certain circumstances, such as the those described in the ‘legitimate interests’ section above we may continue to do so unless your interests, rights and freedoms override such interests;
• request that we delete your personal information, in which case we will carry out this request unless certain exceptional reasons arise permitting us to keep certain information about you; and
• obtain a copy of your personal information in a machine-readable format. In certain circumstances, you can also request that we transfer some of your information to third parties.