Privacy Policy

Introduction

Populus Group ("Populus Group", "we", “our” or “us”) is committed to safeguarding your privacy. “Personal Information” consists of information which may directly or indirectly identify you.   “Sensitive Personal Information” is a subset of Personal Information (the exact definition varies by applicable state privacy law) and includes data about children, financial account information with passwords, health information, Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, biometric data, genetic data and precise geolocation data.  This Privacy Notice ("Notice") is designed to assist you in understanding how we collect, use, disclose, share, and safeguard your Personal Information, and to explain the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below at ‘Contact Us’. 

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Accessibility

We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us at webmaster@populusgroup.com

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When this Notice Applies

This Notice applies to Personal Information we collect online and offline:

• through our website(s), email and related applications and content that link or refer to this Notice (including Populus Group websites and  computer or mobile software applications (“apps”) and content made available to you) (collectively, the “Sites”);
• over the phone; and
• in person.

In some cases, we may provide additional data privacy notices specific to certain services, practices, or regions. Those terms are to be read in conjunction with this Notice. This Notice also applies when we are receiving services you are providing to us. This Notice does not apply to the practices of third parties that Populus Group does not own or control.

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What Are Our Sources of Personal Information?

Our Sources of Personal Information Include:

• Information you submit to us: Where we request information from you (for example when you contact us to register with us on our Sites or request our Services), we will inform you prior to collection whether the provision of the Personal Information may be provided on a voluntary basis, and the consequences of not providing the information, which may include being unable to properly provide you with Services.
• Information we collect automatically: We automatically collect certain technical information from you when you visit our Site(s) (for example your IP address, browser and operating system details and actions you take on the Site(s)).
• Information we obtain from other parties: We may receive or acquire information about you from other parties such as: 

1. Websites and services like job boards and professional network sites (for example LinkedIn) and social media platforms and websites where you post information;
2. Clients (for example a client may provide us your Personal Information in order for us to perform Services );
3. Business intelligence sources, including data aggregators and list providers;
4. Your referrals (for example a referral who refers you to us for a potential job opportunity);
5. Trade journals and news sources (for example industry publications);
6. Public government filings (such as SEC filings); and

Any Personal Information you provide to a third party will be subject to that third party’s privacy notice and our use of the Personal Information we obtain from such third parties will be subject to this Privacy Notice. 

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What Types of Personal Information Do We Collect?

• Identifying Information and Contact Information like your email address, telephone number, postal address and contact information of any referrals, references or emergency contacts you provide.
• Educational and Professional Background Information: including your resume or C.V., employment history, education history, certifications, professional license information (for example bar registration number), languages proficiencies, security clearance information, professional association memberships, volunteer activities, client information where relevant (for example we may collect information from attorneys we place through our staffing and search business regarding clients the attorney has performed services for) and work-related skills, practice details and skills assessment information including personality characteristics / traits which you choose to provide on a voluntary basis.
• Career Planning Information: including your career interests, desired compensation and benefits, desired work location and willingness to relocate, family information as it relates to your career goals or plans, and hobbies and interests.
• Audio, Visual or Similar Information: including photos that you provide to us or that you make publicly available on the internet (for example LinkedIn or company/firm websites); and your image from a security camera if you visit one of our locations.
• Account Information: including your username and password when you choose to establish an account with us.
• Device Information: including your IP address, browser type and version, time zone setting, browser plug-in types and versions, location information on a city-regional basis and operating system and platform information when you are visiting our Site(s).
• Consents and Preferences:  including any consents (for example a consent to receive text messages) you have provided to us and any preferences for marketing communications or marketing channels (for example a preference to hear from us via email or text).
• Other Information You Provide: including any other Personal Information you may elect to provide to us.

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Who Do We Collect Personal Information From?

• Visitors: if you are visiting or using our Site(s) or office locations or any of our Services, so that we can provide you with the Site(s) or Services you require;
• Job seekers and Candidates: if you apply for or we contact you about job opportunities with Populus Group to fill our internal positions or positions through our staffing and recruiting services or search, workforce management, or talent advisory services (once you have been identified for a specific position with us to fill our internal roles or to fill staffing positions with our clients you should view our notices and policies for job applicants and employees mentioned in the Introduction section above);
• Customers, vendors, service providers, and other suppliers: if you are an employee, representative and/or agent of our customers, service providers, vendors, and other suppliers or individuals with whom we have a business relationship and/or manage on behalf of our customers (for example through our outsourcing, MSP and consulting services); and
• Referees and others who advise on the suitability of job seekers: if you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you confirm that you have the authority to do so and to permit us to use the information in accordance with this Notice.

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Do We Collect Sensitive Personal Information?

We do not collect any information from you that would be considered Sensitive Personal Information. 

Why Do We Collect Your Personal Information?

We collect and use your Personal Information for our business and commercial purposes, which include:

• Contacting you for the purposes listed below. We may contact you by telephone, email, text messaging, or otherwise.
• Recruiting and Hiring for current and future job opportunities with us or with our customers, including determining your eligibility and suitability for such opportunities. This may include for example sending Educational and Professional Background Information, such as your CV, to prospective employers for their consideration and keeping you informed of future work opportunities by email, telephone, mail, text message, and/or other communication methods (note that messaging and data rates may apply for any SMS, MMS, and other electronic communications (typically, this is based on your carrier and service plan)).
• Providing our Services, including our staffing and recruiting services as well as our various consulting, advisory, transformation and workforce management services. 
• Receiving Services, including receiving services from various vendors, suppliers, service providers and contractors.
• Operating and Improving our Site(s), for example we use your device and information you provide to establish and maintain an account for you on our Site(s) and to improve the navigation and usage of our Site(s).
• Business Sales Development, for example using your contact information to call or email you as a talent candidate, customer or prospect as part of providing our Services.
• Marketing and Promotions, including sending you promotional communications such as newsletters, surveys, articles of interest, press releases and job fair or other event announcements and personalizing and delivering content about our Services to you, including through advertisements on our Site(s) and other websites.
• Improving Our Services through business analytics, internal audits, troubleshooting, quality control, internal user acceptance testing and use of machine learning to improve our search and match capabilities in matching job seekers to suitable jobs efficiently and effectively.
• Research and Thought Leadership, including articles regarding customers and candidates, and white papers, podcasts and other thought leadership regarding workforce, talent and industry trends and analysis.
• Aggregation and Anonymization, including the process of using Personal Information to create aggregated or anonymized data sets for the purpose of internal business analysis or thought leadership with the end product of such data sets not being Personal Information since it is not identifiable to an individual.
• Security and Fraud Prevention to ensure the security of our Site(s) and Services, to protect against fraud, and to comply with legal requirements.
• Compliance with Laws, Legal Action and Professional Advice, including compliance with all laws and regulations and addressing legal action or taking professional advice, for example from attorneys, security, accountants, tax or other similar professionals.

Populus Group does not sell your Personal Information, except where you agree to cross-context behavioral advertising cookies.  For additional information, please see the section on Cookies. Populus Group may disclose certain categories of Personal Information about you for the business purposes mentioned in this Notice to the following categories of third parties:

• Customers– We may disclose your contact information, professional and work eligibility information, career planning information, demographic information, and/or other information you ask us to disclose to a customer for the purpose of providing our Services (for example, for opportunities we believe are of interest to you for our recruitment business). Customers of Populus Group will process such Personal Information in accordance with their own policies and procedures.
• Vendors, Contractors, and other Service Providers – We use vendors, contractors, and other service providers to assist us in providing our Services, and it may be necessary for us to provide access to some of the categories of your Personal Information (for example, IT operating system and platform vendors who support our systems, SaaS vendors such as applicant tracking systems, customer relationship management systems and back office systems, assessment services, marketing services vendors, attorneys and accountants as well as premises and other security management vendors, including video security at our office locations). These companies will have access to your Personal Information as necessary to perform their functions, but they may only use that information for the purpose of providing the services and are obligated to protect the Personal Information.
• Courts, Regulators, Law Enforcement and Government Authorities – We may disclose your Personal Information where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process, or government requests, including in response to public authorities to meet national security or law enforcement requirements. We also may disclose your Personal Information when we choose to establish or exercise our legal rights or defend against legal claims or to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Populus Group’s terms of use, its policies or this Notice.

Please note that if you post any Personal Information in a public area of our Site(s), the information that you share will be visible to others and can be read, used, or collected by others. Populus Group is not responsible for the way others may use Personal Information you post to public areas of the Site(s).

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Your Privacy Rights

We respect your privacy rights related to the Personal Information we collect, use and disclose about you and we will comply with applicable data protection laws and regulations in the handling of your Personal Information. Depending on the state in which you reside, you may have certain privacy rights regarding your Personal Information. When Populus Group acts as a Controller, you may exercise those rights directly with us. When Populus Group acts as a Processor, you may exercise those rights with the relevant controller directly or if you provide it to us, we will provide the controller with your request and in either case we will assist the controller as required by our contract with the controller and as appropriate under the circumstances. If you are a California resident, please see our California Consumer Rights information below as well as the Notice to California Residents section below. For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your Personal Information and to access such Personal Information;
• The right to obtain a copy of your Personal Information that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete Personal Information that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your Personal Information for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we are required by applicable law to obtain your consent to process Sensitive Personal Information, the right to withdraw your consent; and\The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

Depending on how the applicable privacy law defines a “sale” we may sell Personal Information to third parties, through our use of cookies and tracking technologies. We may use cookies and other tracking technologies to display advertisements about our services to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. We only process your Personal Information for purposes of targeted advertising through targeted advertising cookies if you consent for us to do so when you visit our Sites.  If you want to opt out of the processing of your Personal Information for purposes of targeted advertising, you can manage your cookie preferences by clicking the Cookie Settings link at the bottom of this page. We do not use Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. 
In all jurisdictions, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. This will not affect any processing of your Personal Information done before you withdrew your consent.

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California Consumer Rights

For California residents, you are given rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (“CCPA”) to request that Populus Group disclose the following about the Personal Information we collect, use and disclose about you:

• The right to know what Personal Information we collected about you, including the:categories of Personal Information; 
  • categories of sources where we obtained Personal Information about you;
  • the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable);
  • the categories of third parties to whom we disclose Personal Information; and
  • the specific pieces of Personal Information we collected about you.
• The right to delete Personal Information we collected from you, subject to certain exceptions (for example, we may refuse your deletion request if we are permitted by law to keep the information);
• The right to correct inaccurate Personal Information that we maintain about you;
• The right to opt out of the sale or sharing; and
• If we use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA, the right to limit our use or disclosure.

Additionally, you have the right to be free of discrimination for exercising your consumer privacy rights.

If we deny your privacy rights request, we will explain why.

We do not sell Personal Information, and we do not knowingly collect or sell the Personal Information of minors under 16 years of age.  

We do not offer any financial incentives in exchange for your Personal Information.  

We also do not collect Sensitive Personal Information from you.

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How to Exercise Your Privacy Rights

If you would like to exercise any of your privacy rights, please inquire here. 

OR

Call 248-712-7900 to submit your request.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. 

For all requests, after submitting the request, we will require additional information to reasonably verify your identity depending on the nature of your request, including for those acting as a representative for a California resident your authority to act on behalf of the California resident.

We will abide by all applicable legal requirements for deadlines for responding to your request and will collect the minimum Personal Information necessary to verify your identity.

If you experience any issues with the web form or phone number, please contact webmaster@populusgroup.com

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Your Right to Opt-Out From Marketing Communications

Where it is in accordance with your marketing preferences and applicable data protection laws, we may periodically send you updates via e-mail about promotional opportunities or services we think may interest you, such as jobs in our database that match your selection criteria, newsletters, white papers, surveys and event information.

You can opt-out of receiving marketing emails from us by clicking the unsubscribe link contained in such emails.  If you continue to have issues in unsubscribing from marketing emails from us, you may submit the form mentioned above or call the toll-free number and request to opt-out.

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Universal Opt-Out Mechanisms

The Sites recognize the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. 

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

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Cookies and Online Tracking

Populus Group websites use cookies, tracking pixels, web beacons and similar technologies (collectively “cookies”) to help personalize your online experience and for analytics purposes. For more information about our tracking technologies, cookies, the types of cookies we use, how we use them and how to change your cookie settings, please see our Cookie Notice. 

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Notice to California Residents - Additional Privacy Information

If you are a California resident who is an employee or job applicant of Populus Group, please see the following additional notice:

• California Privacy Policy for Employees and Job Applicants

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Notice at Collection of Personal Information

You can also find our California Notice at Collection for each of the following individuals at the links below:

• California Notice at Collection for Employees and Job Applicants
• California Notice at Collection for Non-Employees and Job Applicants (e.g., website visitors, customers, suppliers and candidates). 

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the categories of Personal Information outlined in the What Types of Personal Information Do We Collect? section above. We collect Personal Information directly from California residents and as described in the What Are Our Sources of Personal Information? section above. 

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Categories of Information Collected and Disclosed

The following identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Notice and, for each category, categories of recipients to whom we disclosed Personal Information.  For all of the Personal Information categories below, we may disclose, as appropriate under the circumstances, to government or law enforcement entities and lawyers.

• Identifying Information and Contact Information:  Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers); Populus Group affiliates; auditors, consultants and other professional advisors
• Educational and Professional Background Information:  Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers); Populus Group affiliates; auditors, consultants and other professional advisors
• Career Planning Information:  Clients and potential clients; vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, SaaS vendors such as applicant tracking, back-office solutions, security vendors, data analytics providers); Populus Group affiliates; auditors, consultants and other professional advisors
• Audio, Visual or Similar Information:  Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, security vendors; video conferencing vendors); Populus Group affiliates; auditors, consultants and other professional advisors
• Account Information:  Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
• Consents and Preferences:  Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, security vendors); Populus Group affiliates; auditors, consultants and other professional advisors
• Device Information:  Vendors, contractors and other service providers who assist us in providing our Services (e.g., IT operating system and platform vendors, security vendors); Populus Group affiliates; auditors, consultants and other professional advisor

We disclosed Personal Information to the above categories of recipients for all of the business or commercial purposes identified in the above “Why Do We Collect Your Personal Information” section.

 

Sales and Sharing of Personal Information

This section will explain to you the instances in which we sell or share your Personal Information.  

We sell or share your Personal Information for cross-context behavioral advertising (or targeted advertising), which includes our use of third-party analytics services and online advertising services. These are described in detail in our Cookie Notice and may result in the disclosure of your online identifiers (e.g., cookie data, IP address, device identifier and usage information).  

We collect your consent prior to using your Personal Information for cross-context behavioral advertising (or targeted advertising), and at any time you have the right to opt out of the sale or sharing of your Personal Information by managing your cookie settings and opting out of all targeted advertising cookies or by enabling Global Privacy Control settings within your browser.  We respect Global Privacy Control browser settings as set forth in more detail in the Universal Opt-Out Mechanism section.  To opt out of the sale or sharing of your personal information, click the Cookie Settings link at the bottom of this page.

 

Other CCPA Rights

We do not offer any financial incentives in exchange for your Personal Information.

Please see Your Privacy Rights section of this Notice for the rights you have as a California Resident and how to exercise them.

Please see information under Data Retention section of our Privacy Notice for information regarding how long we retain your Personal Information.

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California "Shine the Light" Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure.  We do not currently disclosure your Personal Information to third parties for their own direct marketing purposes.

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Security of Your Personal Information

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Data Retention

We retain Personal Information we collect from you where we have an ongoing business need to do so (for example, to provide you with the Service you have requested to maintain you in our talent pool to be potentially contacted about other employment opportunities or to comply with applicable legal, tax or accounting requirements). 

When we have no ongoing business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. 

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International Data Transfers

As a global company, we may transfer Personal Information within Populus Group and third parties located in the United States and in other countries that may be outside your country of residence for storage and processing in order to provide the Services. These countries may not necessarily have data protection laws as comprehensive as those in your country of residence. In addition, we will have taken appropriate safeguards to protect your Personal Information in accordance with this Notice and applicable law wherever it is processed. These safeguards include conducting appropriate vetting of third party business partners and implementing data protection language in our contracts with any business partners with whom we are disclosing your Personal Information.

 

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Contact Us

If you have any questions, please contact:

Populus Group, Troy Headquarters
3001 Big Beaver Road, Suite 400
Troy MI 48084
ATTN: Privacy Officer
webmaster@populusgroup.com

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Changes to this Notice and Last Updated Date of Notice

 

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