Colorado, Connecticut, Utah & Virginia Addendum

Last updated:

November 13, 2024

This policy for Colorado, Connecticut, Utah & Virginia residents supplements the information contained in the Data Privacy Policy of WhiteCrow Research Private Limited (“WhiteCrow / We / Our”) displayed on the website ‘www.webbtree.com’ (“Website”). WhiteCrow has prepared this addendum (“Colorado, Connecticut, Utah & Virginia Addendum”) to the Data Privacy Policy to comply with the data privacy Acts of Colorado, Connecticut, Utah & Virginia and the regulations framed thereunder (“Privacy Acts”).

This Colorado, Connecticut, Utah & Virginia Addendum applies only: (i) to the PII submitted to, and collected by WhiteCrow / Web-site, through the use of the Services by the subscribers of the Website, i.e., the Employer or Employer Representative, who are residing in Colorado, Connecticut, Utah or Virginia; and (ii) to the PII collected by the Website about the Actual Candidates and Potential Candidates who are residing in Colorado, Connecticut, Utah or Virginia. The Employer, Employer Representatives, Actual Candidates and the Potential Candidates shall hereinafter collectively be referred to as “You”/ “Your”/ “Yourself”.

The Website has integrated with WhiteCrow’s talent portal talent.whitecrow.co’ (“Talent Portal”) for effectively providing the Services to the Actual Candidate, wherein We receive PII (defined below) about Actual Candidates who access or sign in on Talent Portal with the intent to seek job opportunities (“Actual Candidates”). If you are an Actual Candidate residing in Colorado, Connecticut, Utah or Virginia then you may exercise your rights including accessing/correcting or deleting your PII (defined below) as per the data privacy policy available on www.whitecrow.co.

It is to be noted that, as this Colorado, Connecticut, Utah & Virginia Addendum supplements the Data Privacy Policy / Agreement, the capitalized terms unless defined herein shall have the same meaning assigned to them in the Terms and Conditions and the Data Privacy Policy.

WHAT INFORMATION IS COLLECTED BY THE WEBSITE?
1. For the purpose of this Colorado, Connecticut, Utah & Virginia Addendum, Personal Information means information that, others can use to identify, locate or contact You, including but not limited to, Your name, email address, postal address and phone numbers, except to the extent such information is publicly available (“Personally Identifiable In-formation” or “PII”).
2. The Website has collected the following list of PII in the preceding 12 months in connection to the Employer and Employer Representative:
  - ‘Identity Data’ such as name of the employer entity, name of the Actual Candidate, employer entity’s website, social media profiles, username, alias, postal address, unique personal identifier, online identifier, ‘Internet Protocol’ address, email address, account name or other similar identifiers.
  - ‘Contact Data’ such as physical address, email address, social media address, telephone number and any other contact information provided to WhiteCrow / Website by the Employer and Employer Representative.
  - ‘Transaction Data’ such as details about payments to and from the Employer and Employer Representative, and details regarding the subscribed Services through the Website.
  - ‘Technical Data’ such as device IDs, the Employer or Employer Representative’s login data, access dates and times, browser type and version, device information, ‘Cookie data’, time zone setting, browser plug-in types and versions, platform and other technology on the devices which Employer and Employer Representative use to access the Website.
  - ‘Profile Data’ such as the Employer and Employer Representative’s username and password, searches made by the Employer and Employer Representative, preferences, user-generated content, feedback and survey responses.
  - ‘Usage Data’ such as information about how the Employer and Employer Representative use the Website and the Services.
  - Similar networking activities such as the Employer and Employer Representative’s browsing history, search history, information on the Employer and Employer Representative’s interaction with a website, application or advertisement.
3. The Website has collected the following list of PII in the preceding 12 months in connection to the Actual Candidates:
  - ‘Identity Data’ such as name of the Actual Candidates, social media profiles, postal address, email address, or other similar identifiers.
  - ‘Personal Data’, such as gender, nationality and place of residence.
  - ‘Contact Data’ such as physical address, email address, social media address, telephone number and any other contact information.
  - ‘Professional Data’, such as qualification, training and certifications, professional skills and experience, language skills.
  - ‘Employment Data’, such as current/recent role, including job title, department, reporting line, responsibilities, salary, benefits and notice periods.
4. The Website has collected the following list of PII in the preceding 12 months in connection to the Potential Candidates:
  - ‘Identity Data’ such as name of the Potential Candidate, social media profiles, postal address, email address, or other similar identifiers;
  - ‘Personal Data’, such as gender, nationality and place of residence.
  - ‘Contact Data’ such as physical address, email address, social media address, telephone number and any other contact information.
  - ‘Professional Data’, such as qualification, training and certifications, professional skills and experience, language skills.
  - ‘Employment Data’, such as current/recent role, including job title, department, reporting line, responsibilities, salary, benefits and notice periods.
5. As stated above, WhiteCrow / Website collects information that identifies, relates to, describes, references, is capable of being associated with or could reasonably be linked, directly or indirectly, with You or device used by the Employer and Employer Representative. WhiteCrow / Website do not collect PII as stated below:
  - Protected classification characteristics under State or federal law.
  - Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  - Biometric information such as genetic, physiological, behavioural, and biological characteristics or activity patterns used to extract a template or other identifiers or identifying information, such as, fingerprints, face-prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns and sleep, health, or exercise data.
  - Sensory data.
  - Geolocation data.
  - Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.
  - Publicly available information from government records.
  - De-identified or aggregated consumer information.
  - Information excluded from the scope of Privacy Acts.
FROM WHICH SOURCES DOES THE WEBSITE COLLECTS PII?

Please click here.
HOW DOES THE WEBSITE USE PERSONAL INFORMATION?
1. In relation to the Employer Representatives:
  
  WhiteCrow / Website may use or disclose the PII that it collects from the Employer and Employer Representative for one or more of the following business purposes:
  - To carry out Our obligations and enforce Our rights arising from the Agreement/agreement(s) entered into between the Employer and Employer Representative and WhiteCrow, upon subscription to the Services provided on the Website, including Services, billing, and collections;
  - To fulfil or meet the reason for which the information is provided;
  - To provide the Employer and Employer Representative with information or Services that they request from WhiteCrow.
  - To provide the Employer and Employer Representative with alerts and other notifications/notices concerning Our Services or events or news, that may be of interest to the Employer and Employer Representative.
  - To improve the Website and present its contents to the Employer and Employer Representative.
  - For testing, research, analysis and product/Service development.
  - As necessary or appropriate to protect the rights, property or safety of WhiteCrow / Website, the Employer and Employer Representative.
  - To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  - As described to the Employer and Employer Representative when collecting PII or as otherwise set forth in the Privacy Acts.
  - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by WhiteCrow / Website is among the assets transferred.
  WhiteCrow / Website may use or disclose the Employer and Employer Representative’s PII for the purposes mentioned in the Data Privacy Policy in addition to the above list of use or disclosure of Your PII, which is not inconsistent with the Colorado, Connecticut, Utah & Virginia Addendum.
  
  WhiteCrow / Website will not use the PII, WhiteCrow / Website collected for materially different, unrelated, or incompatible purposes, without providing notice to the Employer and Employer Representative.
2. In case of Actual Candidates and Potential Candidates:
  
  Please click here.
DOES THE WEBSITE SELL OR SHARE THE PII TO THIRD PARTIES? IF YES, WHY AND TO WHOM?

WhiteCrow/Website does not sell the PII of the Employer and Employer Representative. However, WhiteCrow/Website may disclose the Employer and Employer Representative’s PII for business purposes. WhiteCrow/Website does not sell/share/disclose the Employer and Employer Representative’s Sensitive Personal Data to third parties for any other purpose that to perform the Services. The Website may sell/share the PII of the Actual Candidates or the Potential Candidates with the Employer and Employer Representative, and third party service providers. Please click here for more details.
WHAT CATEGORIES OF PII HAS THE WEBSITE SOLD/SHARED /DISCLOSED?
1. WhiteCrow/Website does not sell the Employer and Employer Representative’s PII to anyone.
2. WhiteCrow/Website shares/discloses the following list of PII, for business purposes, in connection with the Employer and Employer Representative:
  
  To Service Providers: Identity Data, Personal Data, Contact Data, Professional Data, Employment Data, Transaction Data, Technical Data, Profile Data, Usage Data, and Sensitive Personal Data. WhiteCrow/Website does not sell/share/disclose Sensitive Personal Data to third parties for any other purpose that to perform the Services.
  
  To Government, including law enforcement agencies: Identity Data, Personal Data, Contact Data, Professional Data, Employment Data, Transaction Data, Technical Data, Profile Data, Usage Data, and Sensitive Personal Data. WhiteCrow/Website does not sell/share/disclose Sensitive Personal Data to third parties for any other purpose that to perform the Services.
3. WhiteCrow/Website sells/shares/discloses the following list of PII in connection with the Actual Candidates and Potential Candidates:
  
  To Employer and Employer Representative: Identity Data, Personal Data, Contact Data, Professional Data, and Employment Data.
  
  To Government, including law enforcement agencies: Identity Data, Personal Data, Contact Data, Professional Data, and Employment Data.
WHAT ARE YOUR RIGHTS AND CHOICES?

The Privacy Acts provides You (Colorado, Connecticut, Utah & Virginia residents) with specific rights regarding Your PII. This Section describes Your rights and choices under the Privacy Acts. The Individual Candidates may exercise their rights as per the data privacy policy available on www.whitecrow.co.
1. Right to Know/Access/ Data Portability:
  
  You have a right to know
  - what the specific pieces of personal information that We have collected about You;
  - categories of PII We have collected about You;
  - categories of sources from which the PII is collected;
  - business or commercial purpose for collecting, selling, or sharing Your PII; and
  - the categories of third parties to whom We disclose Your PII.
  For knowing what categories of knowing (ii) to (v), above, please refer to Sections 1, 2, 3 and 4, above.
  
  As stated above, You have the right to request WhiteCrow / Website to disclose specific pieces of PII that WhiteCrow / Website has collected about You over the past 12 months. Provided that, You shall be entitled to make the aforesaid request only twice in a 12-month period.
  
  Once WhiteCrow / Website receives and confirms Your verifiable consumer request for disclosure of the specific pieces of PII that WhiteCrow / Website has collected about You, WhiteCrow / Website will disclose to You, the specific pieces of PII that WhiteCrow / Website has collected about You.
  
  WhiteCrow / Website shall also disclose, if it has actual knowledge that it sells the personal information of consumers under 13 (thirteen) years of age, upon receiving a verifiable consumer request.
2. Right to Delete:
  
  You have the right to request that, WhiteCrow / Website should delete any of Your PII that WhiteCrow / Website has collected about You, subject to certain exceptions. Once WhiteCrow / Website receives and confirms Your verifiable consumer request, WhiteCrow / Website will delete Your PII from its records, unless an exception applies, and shall notify the third parties to whom Your PII has been shared by WhiteCrow / Website to delete Your PII available with them.
3. Right to Correct:
  
  You have the right to request that, WhiteCrow / Website should correct any of Your PII that WhiteCrow / Website has collected about You. Once WhiteCrow / Website receives and confirms Your verifiable consumer request, WhiteCrow / Website will correct Your PII existing in its records and shall notify the third parties to whom Your PII has been shared by WhiteCrow / Website to correct Your PII available with them. Provided that, in the event the PII sought to be corrected by you appears to be accurate to WhiteCrow / Website, WhiteCrow / Website may, considering the totality of the circumstances relating to the contested PII, request You to provide documentation that supports the correction sought by You.
4. Right to Opt-Out of Sharing of PII:
  - We do not share the PII of the Employer and Employer Representative with third parties, other than the service providers engaged by WhiteCrow / Website to perform the Services. It is necessary for us to share the PII of the Employer and Employer Representative with the service providers engaged by WhiteCrow / Website to provide the Services to the Employer and Employer Representative.
  - A Potential Candidate shall have the right to request that, WhiteCrow / Website should not share its PII that WhiteCrow / Website has collected about the Potential Candidate with the Employer and Employer Representative and WhiteCrow group entities (“Opt-out Request”).
  - A Potential Candidate may issue the Opt-out Request by clicking here or by using opt-out preference signals. Once WhiteCrow / Website receives and confirms the Potential Candidate’s Opt-out request, WhiteCrow / Website shall stop sharing the PII of the Potential Candidate existing in its records as soon as possible, and shall notify the Employer and Employer Representative and WhiteCrow group entities, to whom Your PII has been shared by WhiteCrow / Website, about Your Opt-out Request.
  - A Potential Candidate may use an authorized agent to submit an opt-out request for or on its behalf if, You provide the authorized agent, written and signed permission on Your behalf.
5. Right to Non-Discrimination:
  
  WhiteCrow / Website will not discriminate against You for exercising any of Your above-mentioned rights. Unless permitted by the Privacy Acts, WhiteCrow / Website will not:
  - Subject to the terms as stipulated in the Terms and Conditions, deny Services to the Employer and Employer Representative.
  - Charge the Employer and Employer Representative different prices or rates for Services, other than as mentioned in the Employer and Employer Representative Form or on the Website.
  - Subject to the provisions of the Service Level Agreement, provide the Employer and Employer Representative a different level or quality of Services.
  - Subject to the provisions of the Service Level Agreement, suggest that the Employer and Employer Representative may receive a different price or rate for Services or a different level or quality of Services.
HOW CAN YOU EXERCISE YOUR RIGHTS TO ACCESS, DELETION AND CORRECT YOUR PII?
1. To exercise Your rights to access, delete and correct Your PII, described above, please submit a verifiable consumer request to WhiteCrow in the following manner:
  - Email: support@webbtree.com
2. Only You or Your authorized agent, may make a verifiable consumer request related to the PII.
3. The verifiable consumer request must:
  - provide sufficient information that allows WhiteCrow / Website to reasonably verify that, You are the person about whom WhiteCrow / Website collected personal information or an authorized representative thereof.
  - describe Your request with sufficient details that allows WhiteCrow/ Website to properly understand, evaluate and respond to it.
4. We may need to request additional information from You, such as Your name and email address, in order to verify your identity and protect against fraudulent requests. If You maintain a password-protected account with the Website, We may verify Your identity through Our existing authentication practices for Your account and require You to re-authenticate Yourself before disclosing or deleting Your Personal Data. If You make a request to delete, We may ask You to confirm Your request before We delete Your Personal Data.
5. WhiteCrow / Website cannot respond to Your request or provide You with PII if WhiteCrow / Website cannot verify Your identity or authority to make the request and confirm that the PII relates to You. WhiteCrow / Website will use the PII provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
6. You may use an authorized agent to submit a verifiable consumer request for exercising the right to access, delete and correct Your PII on your behalf if, You provide the authorized agent written and signed permission on Your behalf.
7. WhiteCrow reserves the right to deny a request from an authorized agent if the agent cannot provide Us with Your signed permission demonstrating that they have been authorized by You to act on Your behalf.
8. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Agents may be asked to provide proof of their status as an authorized agent. Once a request has been submitted by an authorized agent, we may require additional information from You to verify Your identity as described in the section entitled “How to Submit a Rights Request” or confirm that You provided the agent, permission to submit the request. Authorized agents click here to submit a request.
9. For the purpose of verifiable consumer request, through an authorised agent, WhiteCrow shall not require You to provide a notarized affidavit to verify their identity.
10. User-enabled global privacy controls, such as a browser plug-in or privacy setting, device setting, or other mechanism shall be considered a request directly from You and not through an authorized agent.
APPEAL PROCESS

If We refuse to take action on Your request, You may appeal Our refusal within a reasonable period after You have received notice of the refusal. You may file an appeal by contacting Us. If You are not satisfied by the outcome of the appeal you may contact the Attorney General of the concerned jurisdiction.
CHANGES TO OUR PRIVACY NOTICE

WhiteCrow through the Website reserves the right to amend this Colorado, Connecticut, Utah & Virginia Addendum at Our discretion and at any time. When WhiteCrow through the Website makes changes to this Colorado, Connecticut, Utah & Virginia Addendum, We will notify You of such change by posting it on the Website and shall indicate the date of the last revision.
CONTACT INFORMATION

If You have any questions or comments about this Colorado, Connecticut, Utah & Virginia Addendum, the ways in which WhiteCrow / Website collects and uses Your PII, Your choices and rights regarding such use, or wish to exercise Your rights under the Privacy Acts, please do not hesitate to contact WhiteCrow at:

Email: support@webbtree.com