Last Updated: 01.2017
DHI and its subsidiaries such as www.eFinancialCareers.co.uk, participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework. DHI is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
DHI is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. DHI complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, DHI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, DHI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
DHI complies with the U.S.-Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. DHI has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view DHI’s certification, please visit https://www.export.gov/safeharbor/.
A. The information we gather
B. How we use the information we gather
C. How we share information we gather
D. Tracking Technologies
F. Survey & Sweepstakes
G. Social Media Features
H. Connecting via Sign-in Services
I. Choice and Correction of personally Identifiable Information
A. The information we gather
We gather two (2) types of information about users:
1. Non-personally identifiable information (information that does not identify a specific individual): When visitors use the Services, we collect and aggregate information indicating, among other things, which pages were visited, the order in which they were visited, and which links were “clicked.” Collecting such information involves the collection and logging of IP addresses, operating system, and browser software used by each user of the Services. Although such information is not personally identifiable, we can determine from the IP address a visitor’s Internet Service Provider and the geographic location of his or her point of connectivity. The non-personally identifiable information we collect helps us identify the most popular areas of the Sites and determine the effectiveness of our promotional activities. In addition, we may disclose some of this information to advertisers to inform them of the number of people who have seen and/or clicked through their advertisements. We collect non-personally identifiable information in part through the use of “cookies.” For more information, read the information under “Cookies” in section D below.
On mobile applications, we use mobile analytics software to allow us to better understand the functionality of our Services on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregate usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit.
On mobile applications, we may send push notifications to your device. You may opt-out of these at the device level.
2. Personally identifiable information: In certain areas of the Sites, such as those in which you complete a profile, submit your resume, create a new account, or enter DHI-sponsored contests or promotions, we may request that you provide us with certain personally identifiable information, such as your e-mail address, name, zip code, mobile number, profession, or work experience. We will, in such situations, seek to identify which informational items are required and which are optional. In some instances, we may collect geo-location based information for the purpose of helping identify jobs in your area. We may share this information for the sole purpose of providing you this feature. You may opt-out of location based services by editing the setting at the device level.
If you post profiles and resumes on our Sites, such information can be viewed by our customers. At any time, job seekers may elect that their profile and resume not be searchable by our customers by logging into their account and changing the status of their profile or, if that is not possible, they may contact us at firstname.lastname@example.org and we will make the change for them.
In addition, job seekers may elect to make their profile searchable by our customers on a confidential basis only. In this case, the user’s name and contact information will not be displayed to customers performing searches on the Site. If the customer desires to contact the confidential job seeker regarding an employment opportunity, they will send an email to the job seeker through our system. We will forward the email to the seeker’s email address. The seekers email address will not be provided directly to the customer. When posting a resume confidentially, it is the job seeker’s responsibility to ensure that their contact information is not included within their resume attachment.
DHI Services are not available to children under 13 years of age. We do not knowingly collect personally identifiable information from children under 13 years of age.
Please note that we cannot control the acts of users of the Services. All members and visitors should be aware that, when they disclose personally identifiable information in a resume or profile or other medium, the information may be collected and used by others to send that person unsolicited email from other parties outside DHI. In the event that you encounter any DHI user who is improperly collecting or using information about you or other users, please contact email@example.com.
B. How we use the information we gather
Please take some time to familiarize yourself with the different ways we use the information we gather. DHI encourages all third parties involved, including but not limited to its advertisers, to adhere to our policies regarding the privacy of our visitors and users and to otherwise handle personally identifiable information in a responsible manner. Nevertheless, in the event you encounter any third party associated with, or who claims association with, DHI who you feel is improperly collecting or using information about you, please contact firstname.lastname@example.org
1. How we use non-personally identifiable information: We use non-personally identifiable information in aggregate form to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our visitors and users, and by measuring demographics and interests regarding specific areas of the Services. We may provide statistical information based on this data to advertisers, users, and other current and potential business partners. We may also use the aggregate data to inform these third parties as to the number of people who have seen and clicked through links to their sites.
2. How we use personally identifiable information: We may use the personally identifiable information a user submits for any purposes related to DHI business, including, but not limited:
- To understand a user’s needs and create content that is relevant to the user;
- To generate statistical studies;
- To conduct market research and planning by sending user surveys;
- To notify user referrals of DHI services, information, or products when a user requests that DHI send such information to referrals;
- To improve services, information, and products;
- To help a user complete a transaction, or provide services or customer support to users and to recipients of DHI products;
- To communicate with the user and with recipients of DHI products and services;
- To email users about services, information, products and offers from our business partners (and as set forth in section C, How we share information we gather);
- To personalize the Sites for the user;
- To notify the user of any changes with the Sites which may affect the user;
- To allow the user to purchase products, access services, or otherwise engage in activities the user selects; and
- To allow us to contact you by phone and/or email. In some cases, this includes text messaging of alerts, and carrier charges may apply.
User names, identifications (“IDs”), and email addresses (as well as any additional information that a user may choose to post) may be publicly available on the Sites when a user voluntarily and publicly discloses personally identifiable information, such as when a user uses features to send a message to another user, or as part of a message posted to a public forum or a publicly-released software application. Users may not be able to change or remove public postings once posted. Such personally identifiable information may be used by visitors of these pages to send unsolicited messages. DHI is not responsible for any consequences which may occur from the use of personally identifiable information that a user chooses to submit to public pages.
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. DHI will disclose only aggregate information regarding its users, i.e., anonymous information that does not identify any specific individual. Circumstances under which DHI would publicly disclose such aggregate information include, but are not limited to, sharing survey results with the Sites’ users, providing data to DHI advertisers on user preferences and/or demographics, and publicizing overall usage data in press communications. Where surveys allow users to submit written comments, and where DHI advises users of the possibility of such disclosure at the time they take the survey, DHI reserves the right to disclose any information provided by users, provided that no personally identifiable information identifying a specific user is disclosed. Participation in surveys is at a user’s option; DHI does not conduct mandatory surveys.
C. How we share information we gather
Subject to the foregoing, DHI uses your personally identifiable information in several ways. DHI may share your personally identifiable information with service providers to help us with our business activities such as processing credit cards, email and digital marketing activities (including social media and display marketing), offering customer service, or operating a community forum. These service providers are authorized to use your personally identifiable information only as necessary to provide these services to us. With respect to job applications, DHI will not disclose your profile or resume on our Sites to prospective employers without your consent or to carry out your instructions.
If you “opt in” to receive promotional materials from third parties, information you have made available to us may be made available to third parties who provide goods or services that we believe may be of interest to you. You may “opt out” of receiving such materials at any time in a variety of ways: by using the “opt-out” link included in each email, by changing your subscriptions preferences on the “user settings” page in your DHI account or by contacting us at email@example.com If you have provided more than one email address to our service, you may continue to be contacted, unless you request to unsubscribe each email address you have provided. If you opted in to receive information directly from third parties, then you must contact those third parties directly to opt-out.
In addition, DHI reserves the right to share aggregate information collected from users of the Sites, without prior notice, with entities that are part of the DHI corporate family and unrelated third parties. Aggregate information is used in a collective manner and no single person can be identified by such compiled information.
When you submit any personally identifiable information on this Site, we will obtain your consent authorizing the Sites to sell to Third Party Contractors any and all personally identifiable information that is necessary to enable additional service offerings.
To provide services to our customers, DHI collects indexed content from a variety of publicly available websites. Indexed content may include personally information such as post on blogs. In general, such indexed content is available through standard search engines or by visiting the websites themselves. DHI may append this information to your profile or use this content to create a profile, whether or not an individual has an account with us. If you would like to remove the information we collect, see section I to submit your request. DHI has no ownership rights to the indexed content sourced from third party sites and cannot guarantee that we will not collect information from a publicly available source at a later point in time.
If DHI is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information. DHI reserves the right to assign, sell, license, or otherwise transfer to a third party your personally identifiable information in connection with an assignment, sale, joint venture, or other transfer or disposition of any portion or all of DHI’s or its affiliated entities’ assets or stock.
D. Tracking Technologies
Technologies such as cookies, beacons, tags and scripts are used by DHI and our partners, analytics, and service providers. These technologies are used generally for analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole.
We use pixels, or transparent GIF files, to help manage online advertising. These pixels are provided by our ad management partner, DoubleClick. These files enable our ad management partner to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our Sites. The information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. For more information about DoubleClick, including information about how to opt out of these technologies, go to https://www.google.com/privacy/ads/ or you may also opt out by clicking Here.
The Sites may utilize framing and masking techniques to make it appear that the user is still on the Site when the user is actually on a third party website. We also have co-branding relationships with certain partners. In these relationships, you will notice our service platform on our partner’s page. In this situation, both parties are collecting your data and both privacy policies govern the data collected. We will not share your data with third parties without your consent in these and other relationships. We encourage you to be aware when you leave our Sites and to read the privacy policies of each and every website that collects personally identifiable information.
We use web beacons from time to time. A web beacon is a string of code that provides a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data, or determining how many times a specific web page has been viewed. Web beacons enable DHI to recognize a browser’s cookie when a browser visits a Site, and to learn which banner ads bring users to each Site. For example, when a user visits a web page, the code for the page may include instructions to go to another server to gather a single pixel graphic image. Web beacons are not placed on a user’s computer. Such web beacons may be provided by DHI’s third party advertising companies to help manage and optimize any online advertising.
We also may use local shared objects, also known as “Flash cookies” to store your preferences or display content based upon what you view on our website to personalize your visit. Flash cookies are different from “browser” cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, including how to delete Flash cookies, click here for additional information: click here.
DHI web servers may automatically log aggregate information, such as a user’s IP address, domain name, browser type, date and time of access, and other log file data.
Links to third party web sites
Links to third party web sites or widgets to enable sharing of information through social networks on the Sites are provided solely as a convenience to the user. When a user uses these links, the user leaves the Sites. DHI has not reviewed all of these third party sites, does not control, and is not responsible for, any of the third party sites, their content or privacy practices. DHI does not endorse or make any representations about the third party sites, or any information, services, or products found on the sites. If a user decides to access any of the linked sites, DHI encourages the user to read their privacy statements. The user accesses such sites at user’s own risk.
The security of your personally identifiable information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information.
We follow generally accepted standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please help keep your account safe by using a strong password. Accordingly, we advise that you do not communicate any confidential information through our Services.
If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org
F. Surveys and Sweepstakes
Occasionally, DHI may conduct surveys in order to better deliver advertisements and content and to better understand your needs relating to the Services. We will not share your survey information with any third party, except in aggregate form.
From time-to-time we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). That information, to the extent it conflicts with this policy, will govern that particular promotion or sweepstakes – please remember to read it carefully. We may use this information to notify contest winners and award prizes, to monitor the Sites use, to personalize the Sites, to send participants an email, and to measure participants’ demographics, interests and opinions. We may use a third party service provider to conduct these surveys or contests; that company will be prohibited from using our users’ personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with other third parties unless we give you prior notice and choice.
If you choose to use our referral service to tell another person about a job, we will ask you for that person’s email address. We will automatically send that person a one-time email inviting him or her to visit the site. We use this information for the sole purpose of sending this one-time email, and do not store these email addresses.
G. Social Media Features
H. Connecting via Sign-in services
You may be able to log in to our Sites using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on the Sites to your profile page to share with others within your network.
I. Choice and Correction of personally identifiable information
If you would like to have your personally identifiable information removed from DHI’s database, or would like to correct an error in such information, please contact us at email@example.com and we will use reasonable efforts to comply with your request. Keep in mind, however, that there will be residual information that will remain within DHI databases, access logs, and other records, which may or may not contain such personally identifiable information. If you have provided more than one email address to our service, you may continue to be contacted, unless you request to unsubscribe each email address you have provided.
- Choice and Access: Upon request DHI will provide you with information about whether we hold any of your personal information. If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove or deactivate it by making the change on your account page or by emailing our Customer Support at firstname.lastname@example.org or by contacting us by telephone or postal mail at the contact information listed below. We will respond to all access requests within 30 days.
- Data Retention: We will retain your information for as long as your account is active or as needed to provide you Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Blogs: The Sites may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personally identifiable information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why.
- Testimonials: We post testimonials on the Sites which may contain personally identifiable information. We do obtain consent by email or a release agreement prior to posting the testimonial to post their name along with their testimonial.