1. Introduction
InfoPeople (“we,” “us,” “our,” or the “Company”) is committed to protecting the privacy and security of the personal data we process. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website, engage our services, apply for employment, or otherwise interact with us, whether as a client, prospective client, candidate, supplier, or website visitor.
This Policy applies to InfoPeople and its global affiliates and delivery locations. Where local law requires additional or different disclosures, a jurisdiction-specific notice will supplement this Policy and will control to the extent of any conflict.
2. Information We Collect
We collect personal data in the following categories, depending on your interaction with us:
- Identity and contact data: name, job title, company name, email address, phone number, and mailing address.
- Professional and candidate data: resume or curriculum vitae content, work history, skills, certifications, education, references, and background screening results, where permitted by law and consented to by the candidate.
- Client and engagement data: information provided in connection with a statement of work, master services agreement, or staffing engagement, including data processed on a client’s behalf as part of delivering IT Solutions, Data, AI, or IT Staffing services.
- Technical and usage data: IP address, browser type, device identifiers, pages visited, referring URLs, and interaction data collected through cookies and similar technologies, as described in our Cookie Policy.
- Communications data: the content of inquiries, support requests, and other correspondence you send to us.
- Special category data: in limited circumstances, such as disability accommodation requests or diversity monitoring conducted on a voluntary and anonymized basis, we may process special category or sensitive data, and we do so only with an appropriate legal basis and heightened safeguards.
3. How We Use Your Information
We use personal data for the following purposes:
- To provide, operate, and improve our IT Solutions, Data, AI, and IT Staffing services.
- To evaluate and process employment and staffing applications, including matching candidates to open roles.
- To communicate with you, including responding to inquiries and sending service-related notices.
- To manage and administer client relationships, contracts, and billing.
- To maintain the security, integrity, and proper functioning of our systems and website.
- To comply with legal, regulatory, and contractual obligations, including those applicable to public sector and regulated-industry engagements.
- To conduct analytics, reporting, and research to improve our services, subject to the choices described in our Cookie Policy.
- For marketing communications, where you have consented or where permitted by applicable law, and always with the ability to opt out.
4. Legal Basis for Processing
Where the General Data Protection Regulation (GDPR) or an equivalent framework applies, we rely on one or more of the following legal bases to process personal data:
- Performance of a contract, such as processing candidate or client data necessary to deliver services.
- Compliance with a legal obligation, such as regulatory, tax, or employment-related recordkeeping.
- Legitimate interests, such as securing our systems, improving our services, and conducting business development, balanced against your rights and interests.
- Consent, such as for optional marketing communications or non-essential cookies, which you may withdraw at any time.
5. How We Share Information
We do not sell personal data. We may share personal data with:
- Affiliates and global delivery centers within the InfoPeople group, to provide services consistently across locations.
- Service providers and subprocessors who perform functions on our behalf, such as hosting, analytics, applicant tracking, and payroll, under contractual confidentiality and data protection obligations.
- Clients, where staffing or project delivery requires sharing candidate or personnel information as part of an engagement.
- Government authorities and regulators, where required by law, legal process, or to satisfy obligations under government contracts, including public sector engagements.
- Professional advisors, such as auditors, insurers, and legal counsel, as necessary to support our business.
- A successor entity, in the event of a merger, acquisition, financing, or sale of assets, subject to continued protection of personal data.
6. International Data Transfers
Because InfoPeople operates global delivery locations, personal data may be transferred to, stored in, and processed in countries other than the country in which it was originally collected, including countries that may not provide the same level of data protection as your home jurisdiction. Where we transfer personal data out of the European Economic Area, the United Kingdom, or Switzerland, we rely on recognized transfer mechanisms, including the European Commission’s Standard Contractual Clauses or equivalent safeguards, and we take steps to ensure that recipients of personal data provide an adequate level of protection.
7. Data Retention
We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including to satisfy legal, accounting, contractual, or reporting requirements. Retention periods vary by data category; for example, candidate data submitted through our career channels is generally retained for 2–3 years, depending on recruiting practices and applicable legal requirements, to allow consideration for future roles, unless you request earlier deletion and no legal basis requires continued retention. Client and contractual records are retained in line with applicable statutes of limitation and contractual terms.
8. Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, and destruction, consistent with industry standards for a global IT services organization. These safeguards include access controls, encryption in transit and at rest where appropriate, network security monitoring, and regular security assessments. No system is completely secure, and we encourage you to take appropriate precautions when transmitting sensitive information online.
9. Your Privacy Rights
Depending on your location, you may have the following rights regarding your personal data:
- Access: the right to request confirmation of whether we process your personal data and to obtain a copy of it.
- Correction: the right to request that inaccurate or incomplete personal data be corrected.
- Deletion: the right to request erasure of personal data, subject to certain exceptions.
- Restriction and objection: the right to request that we restrict or stop certain processing activities, including direct marketing.
- Portability: the right to receive certain personal data in a structured, machine-readable format.
- Withdrawal of consent: where processing is based on consent, the right to withdraw that consent at any time.
Residents of California and certain other US states may have additional rights under applicable state privacy laws, including the right to know what personal data is collected, the right to request deletion, the right to opt out of the sale or sharing of personal data (we do not sell personal data), and the right to be free from discrimination for exercising these rights. To exercise any of these rights, please contact us using the information in Section 13.
10. Children’s Privacy
Our website and services are directed at businesses and professionals and are not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete it.
11. Job Applicant and Candidate Data
As part of our IT Staffing practice, we maintain a database of candidate profiles to match professionals with relevant opportunities. Candidate data is collected directly from candidates, from professional networking platforms with appropriate permissions, and from referrals. Candidates may request access to, correction of, or deletion of their profile at any time by contacting us. We conduct reference and background verification only where the candidate has consented and where permitted by applicable law.
12. Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those third-party sites, and we encourage you to review the privacy policies of any third-party site you visit.
13. Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact our Data Protection Officer or Privacy Office at:
InfoPeople
450 Seventh Avenue, Suite 1106, New York, NY 10123, USA
Email: info@infopeoplecorp.com
For data subjects in the European Economic Area or United Kingdom, you also have the right to lodge a complaint with your local data protection authority.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the updated Policy on our website with a revised “Last Updated” date, and where required by law, we will provide additional notice or obtain consent.