Privacy Policy

January 1, 2024

1. INTRODUCTION
2. PROCESSING OF PERSONAL INFORMATION
3. CATEGORIES OF PERSONAL INFORMATION
4. PURPOSES OF THE PROCESSING AND LEGAL BASIS
5. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
6. SECURITY
7. RETENTION OF PERSONAL INFORMATION 
8. COOKIES AND INTERNET ANALYTICS
9. SOCIAL MEDIA ACCESS AND PLUG-INS
10. PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF EEA RESIDENTS
11. PERSONAL INFORMATION OF MINORS
12. PROVISIONS APPLICABLE TO CALIFORNIA RESIDENTS
13. HOW TO CONTACT US
14. CHANGES TO THIS PRIVACY POLICY

2. PROCESSING OF PERSONAL INFORMATION

Candidate Information.  VRG assists companies and organizations (each a “client”) in recruiting qualified individuals to meet the client’s specific employment needs. In performing this service, VRG collects and processes personal information on behalf of the client from candidates and prospective candidates (each a “candidate”) for specific job opportunities identified by the client, including:

• Individuals who communicate with VRG about a specific job opportunity posted by VRG on internet job and recruitment websites or respond to a communication from VRG about possible interest in a job opportunity;
• Individuals who, in their public-facing online and social media postings, indicate an interest in learning about, or demonstrate possible suitability for, job opportunities in certain careers, businesses, professions, or areas of experience; and
• Individuals who a client identifies and engages VRG to contact regarding a job opportunity.

Other Individuals’ Information.  In the course of its business, VRG also collects and processes certain personal information of:

• Employees of our clients with whom we communicate in the course of performing our services, including those who are authorized by the client to access the online portal to candidate data established by VRG for each client (each a “Client Portal”);
• Information pertaining to employees of potential clients who we may contact for marketing purposes about VRG’s services.
• Visitors to our Website, including visitors who submit a request for information and visitors whose personal information is collected via Website cookies and other internet tracking technologies; and

3. CATEGORIES OF PERSONAL INFORMATION

The following categories and sources of personal information collected and used by VRG are summarized below. 

• Candidates—We obtain candidates’ personal information from social media networking sites (such as LinkedIn and Facebook) and other online postings, job recruitment websites, and commercial marketing research sources; and, once a candidate expresses interest in a job opportunity, we collect personal information from direct communications with the candidate. This information may include: contact information including first and last name, e- mail address, postal address, telephone number, and communications preferences; resumés and categories of personal information generally presented on a resumé or voluntarily provided in a job interview including, but not limited to, current and past employment experience, functions, and employers, education, skills, professional or other licensure, employment and career interests and preferences including location and compensation objectives, and similar information.
• Client personnel—We obtain employee information directly from our clients, including contact information, communications preferences, job title, company address and similar information necessary for the establishment and performance of the contractual relationship with a client, including establishment of access credentials to the VRG portal for the client’s authorized users (“Client Portal”). Client Portal usage data is logged for security and performance purposes including IP address, and date, time, and duration of visits.
• Prospective clients—We obtain business contact information of human resource managers and others for VRG marketing purposes from social media and marketing research sources.
• Website users—Website usage data including but not limited to the IP address and other identification (e.g. user name of social media, MAC address of smartphones or computers, cookies), date and time of Website visits, visited sites and contents, referring websites.

VRG does not collect or process confidential personally identifying information (such as social security numbers, other government-issued identification numbers, or financial account information); nor do we collect medical, health, origin, beliefs, or other personally sensitive information. 

4. PURPOSES OF THE PROCESSING AND LEGAL BASIS

In accordance with applicable law, VRG may collect and process personal information for the following purposes:

• Recruitment of candidates—research, identification, location, communications, screening by telephone or online, and presenting candidate information to clients via VRG’s online portal;
• Providing services to VRG clients—performance and fulfillment of client contracts, client communications, client service and support, maintenance and building of client relations, marketing and business development;
• Management, operation, and development of systems—including the Client Portal, the Website, and other IT systems (including the provision of functions which require identifiers or other personal information), identity verifications, and statistical analysis regarding usage of the Client Portal and the Website;
• Internal business purposes—VRG retains personal information for possible future communications with candidates and clients and for performance and other business analysis purposes;
• Safety and Security—including protection of the information of candidates, clients, employees, and others; protection of data and assets of and entrusted to VRG; protection of systems and premises of VRG; compliance with legal and regulatory requirements, client obligations, and internal rules of VRG;
• Legal matters—enforcement of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings, and responding to inquiries of government authorities; and
• Related purposes—including further processing indicated at the time of the collection or that was evident from the circumstances.

VRG processes personal information based on the following legal grounds:

• Consent of the candidate either (i) directly by responding to a job posting or other communication from VRG or the client, or (ii) indirectly from relevant information made available by the candidate on social media and other public resources; 
• Performance of contracts and compliance with legal obligations;
• Legitimate interests of VRG, including but not limited to achieving the purposes for collecting and processing personal information listed above; or
• Determination, exercise, defense, or enforcement of legal claims, or to protect individuals, VRG or our clients.

5. DISCLOSURE OF PERSONAL INFORMATON TO THIRD PARTIES

Our clients determine the job position, scope of search, screening questions, and qualifications for each candidate search we conduct on behalf of that client. We share with the client any useful information about a candidate we collect from online and other research sources. However, only with the candidate’s consent will we disclose the personal information that a candidate provides directly to VRG. Clients are able to review the information collected about a candidate using their Client Portal and the client may add comments, download, or copy a candidate’s information. The handling of a candidate’s personal information by the client is covered by the privacy practices of the client. Candidates should review the privacy policy or privacy statement of the prospective employer (identified in advance by VRG), which is generally available on that company’s website.

In addition, VRG may disclose personal information to the following categories of third parties that process personal information on behalf of VRG for the purposes identified under the section titled “Purposes of the Processing and Legal Basis.”

• Service Providers.  We share information with third-party service providers who provide support for our business operations.  These may technology services such as network management and data storage, and cloud-based business management software such as email marketing services and e-commerce contact management services.  We use commercially reasonable measures to select service providers who demonstrate their commitment to protecting the personal information we entrust to them and who maintain privacy guidelines that are consistent with our Privacy Policy. 
• Website analytics. We use cookie-based tracking such as Google Analytics and other third party services to generate statistics about website activity.  Information about how Google Analytics collects and uses this information is available at: https://support.google.com/analytics/answer/6004245?hl=en . These tools help us better understand the ways in which visitors use our Website and identify users who may be interested in receiving marketing communications about our products and services.  For more information, see the section titled, “Cookies and Analytics Tools.”
• Direct Marketing.  We use third-party e-mail marketing services to assist us in sending e-mail marketing messages to prospective clients. These services will have business contact information. A recipient may unsubscribe from these marketing communications at any time.
• Legal Compliance, Safety and Security.  We may disclose personal information to law enforcement, legal authorities, and other third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect or defend our rights and property or the rights or safety of candidates and others, to enforce this Privacy Policy or agreements with third parties, or for crime-prevention purposes.
• Business Transactions.  If VRG were to undertake a sale or transfer of business assets or another kind of business transaction, we may disclose or transfer personal information subject to appropriate confidentiality and use restrictions, and we may retain a copy of the information following such sale or transfer.

6. SECURITY

VRG has implemented organizational and technical measures to protect personal information from unauthorized access, disclosure, alteration or destruction, and to keep personal information accurate and up-to-date as appropriate. Personal information is stored by VRG on our servicers, and on the servers of the cloud-based database management services we engage. Our service providers are expected to implement reasonable measures to protect the personal information they process in providing support services to VRG. We use reasonable technical measures to protect the personal information that is accessible through our Client Portal and the online response link we make available to candidates to facilitate communications with VRG. However, no security system or system of transmitting data over the internet can be guaranteed to be entirely secure and individuals need to be careful about the information they transmit electronically or share online. VRG does not collect or process sensitive, special categories, or directly identifying personal information (such as social security numbers, other government-issued identification numbers, or financial account information). 

7. RETENTION OF PERSONAL INFORMATION

VRG retains personal information for the duration of the candidate’s business relationship with VRG and for a period of time thereafter to allow clients to recover candidate data for their internal review purposes and in furtherance of VRG’s own operations including possible future communications with the candidate, analysis and improvement of business performance, and for backup, archival, and/or audit purposes. A shorter retention period will apply if required either by law or by the client who originated the search in which the candidate was identified. Where VRG retains personal information provided directly by a candidate for a specific job opportunity, that information will not be disclosed to any other client unless the candidate gives consent to such other disclosure. Where required by law, VRG will not retain a candidate’s personal information for future communications purposes unless the candidate gives prior consent.

VRG retains client records and employee contact and other information for the duration of the contractual relationship and so long as permitted by applicable law and VRG retains a legitimate interest in the information (particularly for reasons of ongoing business relationships, future marketing, business analytics, as needed for legal claims, and documentation of compliance with legal or other requirements).

8. COOKIES AND INTERNET ANALYTICS

VRG uses sessions and persistent cookies on its Website and Client Portal. Cookies and similar tracking and identification files are stored on a user’s computer or mobile device. These technologies allow VRG (and third parties we authorize) to obtain information about a user’s browser and visits to our Website and Client Portal, which can be used to identify credentialed users and to analyze individual and aggregated visiting patterns.

Session cookies support the functionality of the Website and track which pages and links the user visits and for how long. Session cookies are automatically erased when the user closes the Website. However, any access to the Website is logged automatically during use and connection data (such as the IP address) cannot be deactivated for individual users. 

Persistent cookies, which are erased after two years, enable saving certain settings for future sessions and allow for an automated log-in. The user consents to the application of persistent cookies by using the Website and selecting the specific functions that allow persistent cookies (e.g. automated log-in). The user may block the placement of some persistent cookies on the browser or may delete cookies already there; however, deactivation may impair the use of the Website.

Persistent cookies and other internet technologies also enable VRG to measure and analyze the visits to the Website and collect data on the activities of users of the Website and the Client Portal. For data analytics involving the Client Portal, a VRG affiliated company located in Bangkok, Thailand controls the use of cookies and other internet technologies. For Website analytics, VRG uses Google Analytics and/or other third-party data analytics providers to place the cookies, record usage data, and provide reports to VRG.  These third-party services may be located in any country worldwide. Google Analytics, which is operated by Google Inc., is located in the U.S. and Google states that it complies with the data protection rules of the EU-US Privacy Shields and the Swiss-US Privacy Shields. 

VRG does not disclose any directly identifying personal information to a third-party data analytics provider. However, the provider may monitor a user’s visits to the Website and combine this data with data from other websites monitored by the same service provider and then use these findings for its own commercial purposes. The provider may have means of correlating data from our Website to an identifiable individual, in which case the processing of personal information will be the responsibility of the service provider. 

By using the VRG Website, the user consents to the processing of personal information by both VRG and the Website analytics services provider, including Google Analytics. Information about how Google Analytics processes information is available at the following link (https://google.com/analytics/answer/3450482? hl=en). Website visitors can prevent their data from being used by Google Analytics, by installing a Google Analytics opt-out browser add-on. Information on how to opt-out, download and install the add-on may be found under the link: https://tools.google.com/dlpage/gaoptout/.

Most web browsers automatically accept cookies; but, a user can usually modify the browser settings to decline or delete cookies. If the user declines or deletes cookies, some features of the Website may not work or may not work as designed. 

VRG does not publish third-party personalized advertisements on the Website nor do we publish personalized advertisements on other companies’ websites. 

9. SOCIAL MEDIA ACCESS AND PLUG-INS

This Privacy Policy applies only to personal information collected by VRG. We view and collect information and resumes available on LinkedIn, LinkedIn Recruiter, and other third-party networking, career, and job sites, and we receive and send messages and emails using those sites. We collect personal information from these sites on the understanding that it has been voluntarily posted by the individual and the individual understands that parties, such as VRG, may view and respond to the posted information. All personal information that originates from a third-party website is covered by the privacy practices of the particular website. VRG has no control over the privacy practices, content, or method of collecting information by those services. Once VRG collects the posted personal information, it is covered by this Privacy Policy. 

Our Website may display or provide links to social media networks, applications, or services. VRG maintains an online presence on various social media networks. If you choose to interact with our pages on these social media networks, including “Liking” our pages, sending us direct messages, or submitting other information, the information you provide to VRG using those platforms is subject to the privacy practices of these services.  

VRG may use plug-ins on our Website from social media networks such as Facebook, Twitter, Youtube, LinkedIn, and Zoom. The default settings of the Website plug-ins are deactivated so that the user can choose when to activate them. Should the user do so, the social media provider is able to establish a direct connection to the user during the user’s visit on the Website and allows the social media platform to monitor and analyze the user’s visit to the Website. Personal information submitted from a social media network is the responsibility of the social media platform and covered by its data protection policies. 

To the extent VRG.com receives any personal information from any social media platform, we process that information with the protections outlined in this Privacy Policy.

10. PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF EEA RESIDENTS

Cross-border Transfer of Personal Information.  VRG transfers and processes the personal information we collect from and about you for the purposes described in this Privacy Policy to the United States and to our affiliated company in Thailand. These countries that have not been found by the European Commission to provide adequate data protection. To transfer your personal data to these countries, we rely on your consent or specific derogations set forth in the General Data Protection Regulation and related national legislation (“GDPR”).

Data Protection Rights.  This section contains a brief and partial summary of certain additional rights set forth in the GDPR that candidates and other individuals who reside in the European Economic Area may have under with respect to the processing of personal data for the purposes and on the legal bases described in this Privacy Policy. The following summary is for general guidance only. Detailed information about your data protection rights is available at:  https://www.eugdpr.org/

You have the right to withdraw your consent at any time to any processing that VRG conducts based solely on the consent you give to us (such as providing your responses to job screening questions to the prospective employer or providing your personal information to a possible future, unspecified employer). To withdraw your previously given consent, see the section titled “How to Contact Us.”

To withdraw consent to VRG sending direct marketing materials to your personal email account, please follow the “unsubscribe” instructions on any marketing emails, or see the section titled “How to Contact Us.”

You may have the right, among others and subject to the conditions set forth in the GDPR, to the following: to know whether we are processing your personal data and what personal information we have collected; to have your personal information corrected; to object to our processing under certain circumstances; to ask us to delete your personal information under certain circumstances, for example, when your personal information is no longer necessary for the purposes for which it was collected; and to receive copies of the personal information that you provided directly in a commonly used and machine-readable format. The exercise of these rights may require a proof of the identity of the requesting person.

Questions and Concerns.  We encourage you to contact us directly if you have questions or concerns regarding our processing of your personal information or this Privacy Policy. See the section titled “How to Contact Us.” You may also have the right to lodge a complaint with a competent data protection authority.   

11. PERSONAL INFORMATION OF MINORS

VRG does not knowingly obtain from children under 18 years of age.  If we learn that we have obtained personal information from individuals under 18 years of age, we will take reasonable measures to promptly delete such information from our records.  If you become aware of any data we have collected from children under age 18, please contact us as explained in the section titled “How to Contact Us.” 

12. PROVISIONS APPLICABLE TO CALIFORNIA RESIDENTS

VRG does not disclose personal information to third parties for their direct marketing purposes.  If you are a resident of California, you have the right under Civil Code Section 1798.83 to request and obtain from us, once a year and free of charge, information about personal information (if any) we disclosed to third parties for direct marketing purposes in the immediately preceding calendar year.  You may make this request in writing as provided under “How to Contact Us.”

13. HOW TO CONTACT US

To ask questions or express concerns about how we process personal information or this Privacy Policy, or would like to exercise legal rights regarding personal information processed by VRG, please contact us using the information below:

By email: privacy@velocityresourcegroup.com 

By postal mail:  3111 W Dr. Martin Luther King Jr. Blvd, Suite 750, Tampa, FL 33607

To unsubscribe from marketing emails from us, please click the “Unsubscribe” link in any marketing email received from us or contact us at marketing@velocityresourcegroup.com  and include “Unsubscribe” in the subject line.

14. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy amends and supersedes any privacy policy previously posted by VRG. VRG may amend this Privacy Policy at any time and without prior notice or announcement. The latest version posted on the Website will be applicable.