1.0 Overview

This Privacy Policy supports our privacy principles and informs you about our practices for gathering, storing, and using the Personal Information (as defined below) of individuals who use our website (the “Poulpa Website”) and apply for or use our Services (as defined below).
Poulpa assists temporary and permanent worker candidates (the “Candidates”) to find and fulfill temporary and permanent jobs for our clients (the “Clients”). If a Candidate chooses to create an account and profile on the Poulpa Website, we collect Candidate’s login information to provide the Candidate with access to his or her profile. We use the Personal Information the Candidate provides to us for the purposes of matching the Candidate with positions on behalf of our Clients. The Personal Information will be shared with our Client’s for that purpose. We collect additional information when the Candidate applies to jobs, interviews with us, when we check Candidate references and when the Candidate works on assignments with our Clients. The Client may retain such information and use it for the purpose of matching Candidates to permanent and temporary work assignments until such time as the Candidate withdraws his or her consent to the Personal Information being used as such.
This Privacy Policy describes how Poulpa will collect, use, disclose, retain and protect Personal Information from you. Poulpa collects, stores and uses Personal Information to provide our recruiting, employment, outsourcing and consulting services (the “Services”). We collect Personal Information about individuals who use the Poulpa Website, apply for employment or engagement with us, or placement by us through our recruitment services.
This Privacy Policy should be read in conjunction with Poulpa’s “Terms of Use” and where applicable, any other agreement you have with Poulpa.
As used herein, “Personal Information” means any information recorded in any form about an identifiable individual, or an individual whose identity may be determined from the information and may include information such as a person’s name, IP address, email address, residential address, telephone number, and in some cases, more sensitive information such as but not limited to gender, demographic information, educational history, employment history, social security or social insurance numbers, background checks and reference checks.

2.0 Scope
For the purposes of this Privacy Policy, the Poulpa Website includes Poulpatechnical.com and Poulpatechnical.ca and any other website operated by Poulpa and includes all related webpages, and all related websites operated by Poulpa and its affiliates but does not include any third-party websites which are linked to or may link from the website.

3.0 Accountability
Poulpa’s Privacy Officer is responsible for the oversight and implementation of this Privacy Policy and procedures to protect Personal Information, for receiving your privacy-related questions, and for providing you with information about Poulpa’s privacy practices, by posting updated information on the Poulpa Website.
You may send your privacy-related questions or challenge Poulpa’s compliance with this Privacy Policy by submitting your concern to p‎r‎i‎v‎a‎c‎y‎@‎p‎o‎u‎l‎p‎a‎.‎c‎o‎m.

4.0 Consent
Poulpa collects Personal Information directly from you when you use and access the Poulpa Website. Poulpa may obtain Personal Information about you from third parties. However, Poulpa only obtains such Personal Information from other organizations (e.g. your bank, credit scoring agencies, or other third-party service providers) when you provide Poulpa with the account numbers, social security or social insurance numbers, passwords or other credentials required to retrieve such Personal Information and for the purpose of providing you with Poulpa’s Services. Poulpa uses and discloses the Personal Information only as described in this Privacy Policy and Poulpa’s Terms of Use.
Poulpa may share Personal Information amongst its affiliates for the purposes set out in this Privacy Policy.
To the extent you provide Personal Information about others (including any Personal Information of your clients’, third parties or third-party job candidates), you represent and warrant that you have obtained all necessary consents to disclose such Personal Information to Poulpa, and to allow Poulpa to process such Personal Information in accordance with this Privacy Policy.
You can opt out of any e-mail communication sent by Poulpa and its affiliates. Poulpa’s e-mails will contain clear and obvious instructions describing how you can be removed from any mailing list. Poulpa will remove you at your request within a reasonable amount of time.

5.0 Identifying Purposes
Poulpa collects, uses and discloses Personal Information only for the purposes of providing you the Services, and in improving its Services and infrastructure and for such other ancillary purposes consented to by you as a user of the Poulpa Website, or as required by law.

6.0 Limiting Collection
Poulpa may collect Personal Information directly from you when you:
• register to use the Poulpa Website;
• use the Poulpa Website;
• input data (including Personal Information) into the Poulpa Website;
• contact Poulpa for support; and
• visit the Poulpa Website.
You can always choose not to provide Personal Information to Poulpa, but it may mean that Poulpa is unable to provide you with its Services.

7.0 Limiting Use, Disclosure and Retention of Personal Information
Poulpa collects, uses and discloses information (which may include Personal Information) for the following purposes:
• To verify your identity.
• To provide you with its Services. Poulpa may ask you to provide Personal Information including:
o Name
o Email address
o Telephone number
o Location
o Desired job title(s)
o Professional skill(s)
o Education
o Location
o Desired rate of pay
o Resume / CV
o LinkedIn profile URL
o Facebook profile URL
o Twitter handle
o Documented previous experience at Client
o Profile Picture / Headshot
o Work format preferences
o Availability
o Tax classification
This Personal Information will form part of a Candidate’s user profile and will be shared with the Client in order to provide the Services. The Client will handle the Personal Information forming part of the Candidate’s user profile. If Poulpa’s business relationship with the Client is terminated, the Client may retain the Candidate’s Personal Information for the purpose of fulfilling temporary and permanent work assignments.
• Poulpa may also, for example, require financial, accounting and employment data related to you in order to the provide Services, or to promote or offer you products, services and offers (including new and other services which are offered by Poulpa and its affiliates) that may be relevant to you.
• To contact you for the purposes of product information, Service updates and notifications relating to the Poulpa Website. In particular, Poulpa requires you to give us necessary contact information such as name and email address. We also ask for unique identifiers (log-in password names). Poulpa uses such contact information to send information about Poulpa’s or its affiliates’ products and services.
• To monitor and/or improve system usage, server and software performance. Poulpa may use login information, and IP addresses of computers which access its infrastructure to help diagnose any problems with the infrastructure, and to administer the Poulpa Website to help identify you and to gather broad demographic information. Poulpa may use cookies or other tracking technologies to monitor access to the Poulpa Website, to save your password, or otherwise allow offering of the Poulpa Website.
• To assist you with technical support issues.
• To comply with any laws, regulations, court orders, subpoenas or other legal process or investigation and to protect Poulpa, its affiliates, suppliers, and other individuals from harm.
• To improve and enhance Poulpa offerings. Poulpa may use Personal Information provided by its users in an anonymous, and/or aggregated fashion to improve or enhance the Poulpa Website and other service offerings.
Poulpa allows certain authorized third-party providers to track and store certain information about visitors to the Poulpa Website (including domain names, IP addresses and page views as described below). Poulpa may also disclose Personal Information to organizations that perform services for it. Personal Information will only be provided to such organizations if they agree by way of contract to provide appropriate protection for such information.
By using the Poulpa Website, you consent to your Personal Information being collected, held and used in this way and for any other use you authorize. Poulpa will only use your Personal Information for the purposes described in this Privacy Policy or with your express permission.
It is your responsibility to keep your credentials to access the Poulpa Website safe. You agree to notify us as soon as possible if you become aware of any misuse of your password, and immediately change your password.

8.0 Accuracy
Poulpa relies on you to ensure that the Personal Information you provide to us while using the Poulpa Website is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Upon request, Poulpa will provide you with Personal Information Poulpa holds about you. You are welcome to make changes, request deletions or corrections to this Personal Information at any time by contacting us at the contact information listed in this Privacy Policy. Poulpa will respond to your request within a reasonable timeframe.
You are responsible for ensuring that the information you have provided is truthful, accurate, reliable and complete, and does not infringe the rights of others.
Poulpa will retain data provided by you as long as you (or your organization) remain(s) a subscriber of the Poulpa Website in good standing, in accordance with the Poulpa Terms of Use. Poulpa will retain and use your Personal Information as necessary to comply with Poulpa’s legal obligations, resolve disputes, and enforce agreements with Poulpa.

9.0 Where Your Personal Information is Stored
Poulpa uses third-party data hosting providers to host the Poulpa Website and associated data on servers located throughout the world.
Personal Information may also be stored outside of the jurisdiction in which you live, if a third-party provider or other entity to whom Poulpa shares personal information in accordance with this Privacy Policy is located outside of that jurisdiction.
At present, Poulpa uses servers in the United States and Canada.
Personal Information may also be subject to transfer to another organization in the event of corporate transaction by Poulpa or its providers. Such transfer will only occur if the parties have entered into an agreement under which the collection, use and disclosure of the Personal Information is restricted to those purposes that relate to the business transaction, including a determination of whether or not to proceed with the business transaction, and is used by the parties to carry out and complete the business transaction.
Notwithstanding the foregoing, Personal Information may be subject to the local laws of the jurisdictions within which it is collected, used, disclosed and/or stored, and may be accessed by governmental authorities in those jurisdictions.
By entering Personal Information into the Poulpa Website, you consent to the Personal Information being hosted on servers where allocated. Each data hosting provider’s role is limited to providing a hosting and storage service to Poulpa, and Poulpa has taken reasonable measure to ensure that our data hosting providers will not access the data and will use the necessary level of protection for Personal Information. They do not control and are not permitted to access or use your Personal Information, except for the limited purpose of storing the information.
If you do not want your Personal Information to be transferred to a server as described above, you should not provide Poulpa with Personal Information or use the Poulpa Website.

10.0 Safeguards
Poulpa is committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unauthorized access, modification and disclosure. Your Personal Information is stored on secure servers that is encrypted, and all data transferred between you and the Poulpa Website is encrypted.
Poulpa limits access to Personal Information to its employees, contractors and agents who need to know that information in order to process it to allow Poulpa to provide its Services. The recipients of Personal Information are subject to strict contractual confidentiality obligations. Employees may be disciplined or terminated if they fail to meet these obligations.
Notwithstanding any of the foregoing, the Internet is not in itself a secure environment and Poulpa cannot give an absolute assurance that your Personal Information will be secure at all times. Transmission of Personal Information over the Internet is at your own risk and you should only enter, or instruct the entering of, Personal Information to the Poulpa Website within a secure environment.
Poulpa will advise you at the first reasonable opportunity upon discovering or being advised of an incident where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by unauthorized persons or in an unauthorized manner.

11.0 Individual Access
Poulpa makes no claim to your Personal Information. Upon request, Poulpa will provide you with a list of the third-party service providers used to host your Personal Information, and the countries in which our servers are located.

12.0 Openness
Poulpa makes clear and transparent notice of its privacy practices publicly available through this Privacy Policy. Poulpa reserves the right to change this Privacy Policy at any time, and any amended Privacy Policy is effective upon posting to the Poulpa Website.
Poulpa will make every effort to communicate any significant changes to you via email or notification via the Poulpa Website. Your continued use of the Poulpa Website will be deemed acceptance of this and any amended Privacy Policy.

13.0 Challenging Compliance
You may send us your privacy-related questions or challenge our compliance with our Privacy Policy by submitting your concern to p‎r‎i‎v‎a‎c‎y‎@‎p‎o‎u‎l‎p‎a‎.‎c‎o‎m