Saville Assessment Privacy Policy

In this section, we provide information for California residents, as required under California privacy laws, including the CCPA, which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of:

• publicly available information made lawfully available by state or federal governments;
• personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA (such as information that is subject to HIPAA, the California Medical Information Act, the Gramm-Leach Bliley Act or the California Financial Information Privacy Act); or
• personal information that we may share with government entities, including law enforcement, in circumstances that include: (1) when required to do so as a matter of law; (2) to assist in the investigation of a potential crime impacting us, our employees, our clients, or the communities we serve; or (3) when required in response to legal process (e.g., subpoena, warrant).

Purposes for Using Personal Information: While the purposes for which we may process personal information concerning Clients and Participates will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

• Providing support and services: including to provide our Services, operate our Website, applications and online services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, process your payments and provide technical support; and for other customer service and support purposes.
• Analysing and improving our business: including to better understand how users access and use our Services and Website; to evaluate and improve our Website, Services and business operations, and to develop new features, offerings and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to develop and select employees, and for other research and analytical purposes (such as identify your Assessment and responses, assess your aptitudes and preferred working styles, produce Assessment reports for our Client who has made this Assessment available to you, help identify you as the person participating in an Assessment).
• Personalising content and experiences: including to tailor content we send or display on our Website and other Services, and to otherwise personalise your experiences.
• Advertising, marketing and promotional purposes: including to reach you with more relevant ads; to evaluate, measure and improve the effectiveness of our promotional campaigns; and to administer promotions. Note: we do not send marketing communications to those only registered as Participants; but we may contact them if we have their contact details and they are a Client or prospective Client of our Services.
• Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorised access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorised activities or misconduct.
• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, exercise, defend our rights or interests.
• Auditing, reporting, corporate governance, and internal operations: including using and refining our Assessment tools, analysis, accounting, billing and audit, security; general operational administration including testing, maintenance, product development, customer relations, employment or human resources; performing our obligations to Participants and Clients whether under contract or otherwise; and to help us in future dealings with you.
• Complying with legal obligations: including to comply with the law, our legal obligations, or our legal processes.

Categories of personal information that we collect and disclose. In general, we collect and disclose for a business purpose the following categories of personal information (as defined by the CCPA):

• Identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.
• Customer records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, bank account number, credit card number, debit card number, or any other financial or payment information, or medical information.
• Protected classifications: characteristics of protected classifications under California or federal law such as: race, colour, sex, age, national origin, disability and citizenship status.
• Commercial information: including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Internet or other electronic network activity information: including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
• Audio, video and other electronic data: visual information such as photographs.
• Employment history: professional or employment-related information.
• Education information: education information and records.
• Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, or aptitudes.

We do not process personal data belonging to individuals who we know are younger than 16 years old.

We may share aggregated or anonymised information (i.e., that which does not identify and is not linked or linkable to a particular individual), with third parties for research, marketing, analytics and other purposes. When we de-identify personal information, we have implemented reasonable measures as required by law to ensure that the de-identified data cannot be associated with any individual or client. We will only maintain and use such data in a de-identified manner and do not attempt to re-identify the data, except as permitted by law.

Categories of Sources of Personal Information. We may collect personal information directly from you, automatically related to your use of our Website and Services, and from third parties as described below. The actual personal information we collect and process about you will vary depending upon the circumstances. The sources for the personal information we may collect include:

• from you, either directly (i.e., through information you submit to us, including via forms that you may complete and submit through our Website) or indirectly (i.e., by observing your actions on our Website);
• from our Clients in connection with us providing professional services to them;
• from our service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business, such as to perform mailings or to provide customer assistance);
• from the content of information you provide when you enter a competition, promotion or survey;
• from “cookies” and other similar tools deployed on parts of our Website; and
• other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected with on social media), and from other third parties.

Categories of Third Parties to Whom We Have Disclosed Personal Information

In the past twelve months, we have disclosed certain categories of personal information to the following categories of third parties:

• our business clients;
• advertising networks;
• internet service providers;
• data analytics providers; and
• service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business).

Information Concerning the Sharing or Selling of Personal Information. While we do not disclose personal information to third parties in exchange for monetary compensation from such third parties, we do disclose or make available personal information we may have collected, through the use of targeting cookies, to third parties in order to receive certain services or benefits from them, such as when we allow third party tags to collect information such as browsing history on our Website, in order to improve and measure our ad campaigns, to facilitate navigation, to personalise and improve your experience while using the Website to better reach users with relevant advertising both on our Website and on third party websites, and to report aggregate information to our advisors.

The CCPA defines a “sale” as disclosing or making available to a third party Personal Information in exchange for monetary or other valuable consideration and it defines “share” in pertinent part as disclosing personal information to a third party for cross-context behavioural advertising.

Pursuant to the CCPA, the categories of personal information that we may “sell” as defined under the CCPA includes:

• Identifiers including, but not limited to, a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.
• Electronic usage data, including, but not limited to, browsing history, search history, and information regarding your interaction with our Website.

We have “sold” the categories of personal information listed above to data analytics providers in the preceding twelve months for the purposes outlined above.

We do not “share” personal information with third parties for cross-context behavioural advertising.

Use and Disclosure of Sensitive Personal Information. We only use and disclose sensitive personal information collected about consumers for the purposes of providing secure access for participants to complete assessments, for research purposes to monitor our assessments for fairness in use, and where participants inform us about a health issue or disability which may impact the way in which they undertake an assessment and not for any other purpose. For more information about the collection and use of personal information generally, please see section 5 and section 6 above.

Rights of California residents. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

• Do-Not-Sell: California residents have the right to opt out of our sale of their personal information. Opt-out rights can be exercised by clicking the Do Not Sell My Information link in the footer of our website homepage or by contacting us in the “Submitting Requests” section below. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.
• Initial notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
• Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. The instructions for submitting a verifiable Request to Delete are described in the “Submitting Requests” section below. We will respond to verifiable requests received from California residents as required by law.
• Request to Correct: California residents have the right to request that we correct inaccurate personal information that we maintain.
• Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, disclosed, and sold about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
  • categories of personal information collected;
  • categories of sources of personal information;
  • business and/or commercial purposes for collecting and selling their personal information;
  • categories of third parties with whom we have shared their personal information;
  • categories of personal information that we have sold in the preceding 12 months and for each category identified, the categories of third parties to which we sold that particular category of information; and
  • categories of personal information disclosed for a business purpose in the preceding 12 months and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.

California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Know are described in the “Submitting Requests” section below.

• Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
• Financial incentives: A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offered and their material terms, the right to opt out of such incentives at any time and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

Submitting requests. Do-Not-Sell (Opt-out) Requests, Requests to Know and Requests to Delete may be submitted by:

• following this link; or
• calling us at 1-833-214-2992. Note that this number is only available in the USA. If you are contacting us from outside the USA please follow this link.

We will use the following process to verify Requests to Know, Requests to Delete, and Requests to Correct: We will acknowledge receipt of you Consumer Request, verify it using processes required by law, then process and respond to your request as required by law. To verify such requests, we may ask you to provide the following information:

• For a Request to Know categories of personal information which we collect, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you against information in our systems which are considered reasonably reliable for the purposes of verifying a consumer’s identity.
• For a Request to Know specific pieces of personal information, Requests to Delete, or Requests to Correct, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you to personal information maintained in our systems and also by obtaining a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.

An authorised agent can make a request on a California resident’s behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorised the agent to do so; (2) verification of their own identity with respect to a right to know categories, right to know specific pieces of personal information, or requests to delete which are outlined above; and (3) direct confirmation that the consumer provided the authorised agent permission to submit the request.

For more information about our privacy practices, you may contact us as set forth in section 18. Contact Information above.