Portfolio Talent Management Company
Last modified: May 26, 2020
Portfolio Talent Management Company (“Company” or “We”), respects your privacy and is committed to protecting it through compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website (“Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Company is the data controller for information processed through the Website.
This policy applies to information we collect:
On this Website.
In email, text, and other electronic messages between you and this Website.
It does not apply to information collected by:
us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates); or
any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Our Website is not intended for nor targeted towards children as defined by applicable law. We do not knowingly collect personal information from children. If you are younger than the age of consent in your jurisdiction, do not use or provide any information on this Website or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If you believe we might have any information from or about a child under the applicable age of consent, please contact us at email@example.com and we will delete it.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
that is about you but individually does not identify you, such as organization, company or comments you may provide; and/or
about your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.
Information You Provide to Us. The information we collect on or through our Website may include:
Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
Records and copies of your correspondence with us (including email addresses).
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically can be associated with other personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection include:
Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
When you use the Website and provide information to Company through the Website, your information may be transferred to a destination outside your jurisdiction, including to the United States. The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Company relies on derogations for specific situations set forth in Article 49 of the GDPR in order to transfer personal information across international borders outside of Company, its affiliates, and subsidiaries. In particular, Company transfers personal information across international borders only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Company in a manner that does not outweigh your rights and freedoms.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
In any other way we may describe when you provide the information.
For any other purpose to fulfil our legitimate interests or with your consent.
Disclosure of Your Information
We may disclose aggregated anonymized information about our users without restriction.
To our affiliates.
To contractors, service providers, and other third parties we use to support our business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
To the extent required by law, Company provides you with (i) reasonable access to the personal information collected through the Website, and (ii) the ability to review, correct, export, and delete such personal information. Please contact us using any of the methods identified in the “Contact Information” section if you would like to exercise your individual rights and for information on any fee required to obtain copies of your personal information. We may need to obtain or confirm certain personal information in order to accommodate your request. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at: 222 Grand Street, Jersey City, NJ 07302.
We use commercially reasonable measures to secure information collected through the Website. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Last Updated: May 26, 2020
Categories of Personal Information Collected
Personal identifiers including name, alias, email address, or any other personal identifier.
Internet and other network activity information, including online identifiers, such as your Internet Protocol address or device identifier.
Sources of Collection
Any other individual you have authorized to provide us with your personal information.
Directly and indirectly from activity on our website (www.portfoliotm.com). For example, from submissions through our website portal or website usage details collected automatically.
Business/Commercial Purpose for Collection
To communicate with you.
To provide you with information or services that you request from us.
To improve our website and present its contents to you.
To prevent, detect, and investigate fraud or other security incidents.
Categories of Third Parties Receiving Personal Information
Website analytics providers
In the past twelve months, we have not disclosed personal information collected through our website for business or commercial purposes to our affiliates technology service providers and web analytics providers.
The categories of personal information we may disclose to third parties in the future for business or commercial purposes are:
Personal identifiers, including name, alias, and email address Internet activity information, including online identifiers such as Internet Protocol address or device identifier.
In the past twelve months, we have not sold personal information to third parties and we will not sell your personal information to third parties.
Right to Know
California residents have the right to request that we disclose to them: (1) the specific pieces of personal information we have collected about them; (2) the categories of personal information collected or shared; (3) the purposes for which we collected or shared their personal information; (4) the categories of third parties to whom we have disclosed personal information about them.
If the categories of personal information, sources and third parties for a particular individual would be the same as those disclosed in the table above, we will respond to a request to disclose such categories by referring the individual to this notice. Prior to disclosing information, we are required to verify that the individual making the request is indeed the individual to whom the information relates. Once we receive a verifiable request, we must disclose the information requested for the twelve months preceding that individual’s request. The law gives us 45 days to provide the information.
You can submit a request by calling by emailing email@example.com. The personal information that we use to verify your identity and residency will not be used for any other purpose. Please note that if the information being requested reveals details, directly or indirectly, about another person, we will need to seek consent of that person before we can disclose that information. In certain circumstances, where disclosure of part or all of the information requested would adversely affect the rights of others, we may not be able to disclose the information. Please further note that information covered by an evidentiary privilege recognized under California Law (including trade secrets, attorney-client privilege and work-product privilege) cannot be disclosed.
Right to Opt-out of Sales (opt-in for minors):
California residents have the right to direct a business not to sell personal information about them. For minors under sixteen years of age, businesses are legally prohibited from selling their information without opt-in consent. Because we do not sell personal information of California residents, there is no need for you to request to opt-out of sales.
Right to Delete:
California residents have the right to request deletion of the personal information we have received from them. Prior to deleting the information, we are required to verify that the individual making the request is indeed the individual to whom the information relates. Once we receive a verifiable request, the law gives us 45 days to respond to it. As a general rule, we must delete the information at your request and require our vendors to do so as well. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions we must inform you of that fact and of any rights you may have to appeal our decision. You can submit a deletion request by emailing firstname.lastname@example.org. The personal information that we use to verify your identity and residency will not be used for any other purpose.
Right against Discrimination:
California residents have the right to not be discriminated against because they have exercised any of their rights under the CCPA. Discrimination includes, but is not limited to, denying goods or services, charging different prices or rates for goods or services, providing a different level or quality of goods or services. However, businesses are allowed to charge you a different price or rate, provide a different level or quality of goods or services, or offer financial incentives, if the difference is reasonably related to the value provided to the business by your data, and the businesses’ financial incentive practices are not unjust, unreasonable, coercive, or usurious in nature.
222 Grand Street, Jersey City, NJ 07302.
European Union: You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal data in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern.