Kenexa BrassRing, Inc. Privacy Policy

The following sets forth Kenexa BrassRing, Inc.’s privacy policy, which contains four separate sections as follows:

This Introduction;
Kenexa BrassRing Online Privacy Policy, which addresses the privacy practices applicable to usage of the Kenexa BrassRing websites;
Kenexa BrassRing's ASP Privacy Policy, which addresses the privacy practices applicable to information processed by Kenexa BrassRing in its role as an ASP provider;
A General Section, which applies to all of our privacy policies

Kenexa BrassRing respects individual privacy. Kenexa BrassRing strives to collect and use personal information in a manner consistent with the laws of the countries in which it does business. Kenexa BrassRing abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission.

Kenexa BrassRing LLC is a licensee of the TRUSTe Privacy Program and the TRUSTe EU Safe Harbor Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. Because we want to demonstrate our commitment to our users' privacy, we have agreed to disclose our privacy practices and have them reviewed for compliance by TRUSTe.

II. KENEXA BRASSRING ONLINE PRIVACY POLICY

This Online Privacy Policy covers use of the site www.brassring.com and our on-line URC site available only to clients of Kenexa BrassRing. All information you disclose to us on this website or on our on-line URC site is subject to our Online Privacy Policy. With respect to data received through its websites, Kenexa BrassRing will, at its own discretion:

Use personal information it obtains relating to you, including but not limited to your name, mailing address, phone number and email address, for the purposes of contacting you, conducting internal business research, and carrying out other marketing activities. We may also disclose such information to third parties when they provide a service on our behalf. These third parties are not permitted to use such information for their own purposes. Kenexa BrassRing does not share, sell, trade, or rent your personal information to third parties for unknown reasons.
From time to time send our visitors and/or clients e-mail messages with new site feature announcements, enhancements, maintenance information and general updates. We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes, when we ask for this information. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or you may contact us at 402.434.2660, email us at webmaster@kenexa.com, or send written notification to the attention of Kenexa - Webmaster, 2930 Ridge Line Road, Suite 200, Lincoln, NE. 68516. You will be notified when your personal information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
Collect and store information generated through use of our on-line business services. We may use some of this information in the aggregate for marketing research, such as, for example, in compiling statistics on Kenexa BrassRing's website visitors, base, and in assessing clients' business needs. If we decide to mention a particular client on the site, we will take reasonable steps to gain that client's assent before posting.
Collect and store information provided directly or indirectly to us through participation in online contests and/or client satisfaction surveys and the like.
Create standard usage logs through our web server, such as IP address, browser type, and access times.
Collect prospective employee information through use of our own application for internal job placement. That information will be treated according to local regulations governing employment practices.
Tie standard usage logs and cookie (session ID and persistent) information to personally identifiable information. Cookies are information generated by our servers for use with your browser for site navigation and application delivery. Cookies are required to log into the services we provide on the site.
Use our web server to recognize your domain name and track your use of the website.
Request certain information from you (such as your name, address, telephone number, e-mail address or business requirements) to help us evaluate our site traffic and overall usage, improve our on-line services, and build better websites. We may add information from third parties to this collected information, for instance to research prospective clients
Provide access via a hyperlink in an email or a web page or through on-line support when you need to update or correct your contact information or, for clients, to report a bug or problem with your system.
Provide users who no longer wish to receive promotional communications the ability to an opt -out of receiving these communications.
Only use client data to provide the services or information that a client has requested. We take industry and reasonable steps to keep business information confidential
Communicate with users on a regular basis to provide requested services and in response to issues relating to your account via email or phone.
When you place an order online, your credit card information is protected through the use of encryption, such as the Secure Socket Layer ("SSL") protocol. SSL makes it difficult for your credit card information to be intercepted or stolen while being transmitted. Kenexa BrassRing uses a service company to process its credit card transactions. For further information on this company's privacy and security practices, please go to: http://www.verisign.com/truste/index.html.

Google Analytics
The Kenexa BrassRing websites use Google Analytics, a web analysis service of Google Inc. (“Google”) Google Analytics uses “cookies”, text files, which will be saved on your computer and which allow an analysis of your use of the website. The information provided by the cookie concerning your use of the website (including your IP-address) will be transferred to a Google server in USA and saved there. Google will use this information to analyze your use of the website, to compile reports about the website activities for the website operator and to provide additional services concerning the website and internet utilization. Google may transfer this information to third parties, if this is a legal requirement or if third parties are commissioned by Google to process the information. Google will in no event connect your IP-address with other Google data. You can prevent the installation of cookies with the relevant browser software setting; however we would like to point out that in this case you may not be able to use all the functions on this website to the full extent. Through use of the Kenexa BrassRing websites you agree to the processing of your data by Google in the way described above and for the purpose stated above. This Online Privacy Policy covers the use of cookies by the www.BrassRing.com and our on-line URC site only and does not cover the use of cookies by any advertisers.

Privacy Officer
Kenexa BrassRing has a Privacy Officer who is responsible for Kenexa BrassRing's compliance with and enforcement of this Policy. Kenexa BrassRing's Privacy Officer, Ronald Poore, is available to any of its employees, customers, vendors, business partners, or others who may have questions concerning this Policy or data security practices. Kenexa BrassRing's Privacy Officer may be contacted by email at rpoore@brassring.com, by telephone at 781.530.5155 or by mail at Kenexa BrassRing, 343 Winter Street, Waltham, MA 02451. If users have questions or concerns regarding this statement, they should first contact Ronald Poore. Kenexa BrassRing requires a response to an access request by a user be provided within 30 days of submitting the request. If you do not receive acknowledgment of your inquiry or it is not satisfactorily addressed, you should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process at: http://www.truste.org/consumers/watchdog_complaint.php.

TRUSTe will serve as a liaison with Kenexa BrassRing to resolve users' concerns.

Please see Section IV. General, for additional provisions that related to www.brassring.com website and our on-line URC privacy practices.

III. Kenexa BrassRing's ASP Privacy Policy

This ASP Privacy Policy applies only to all transfers of personally identifiable information ("Personal Information") received by Kenexa BrassRing in any format through its hosted recruitment software, whether supplied directly by Kenexa BrassRing customers or by candidates for employment at Kenexa BrassRing customers anywhere in the world, including transfers from the European Economic Area (EEA) to the United States. Any other visitors to BrassRing.com should refer to the On-Line Privacy Policy which covers non-ASP BrassRing.com website use.

Kenexa BrassRing abides by the EU Safe Harbor framework as set forth by the Department of Commerce regarding collection, use, and retention of data from the European Union. As such we operate as a data processor for our hosted recruitment software customers. Our hosted recruitment software customers fill the role of data controller. Individual users involved in recruitment activities usually interact directly with Kenexa BrassRing's customers rather than with Kenexa BrassRing. Kenexa BrassRing provides its customers the option of disclosing their relationship with us by providing notice to individual employees and candidates of the customer about the Kenexa BrassRing technology that they use. Kenexa BrassRing maintains only that information related to the candidate recruitment process, which our customers' have asked us to process. This ASP Privacy Policy does not reflect the privacy practices of Kenexa BrassRing's customers and Kenexa BrassRing is not responsible for its customers' privacy policies or practices. Kenexa BrassRing does not review, comment upon or monitor its customers' compliance with their respective privacy policies, nor does Kenexa BrassRing review its customer instructions to determine whether they are in compliance with or conflict with the terms of a customer's published privacy policy.

Notice/Use of Information
Because it supplies a hosted system, Kenexa BrassRing operates as a data processor for our recruitment software customers. Our hosted recruitment software customers fill the role of data collector. Individual users involved in recruitment activities usually interact directly with Kenexa BrassRing's customers rather than with Kenexa BrassRing. Kenexa BrassRing provides its customers with the option of disclosing their relationship with us by providing notice to individual employees and candidates of the customer about the Kenexa BrassRing technology that they use. Kenexa BrassRing maintains only that information related to the candidate recruitment process, which our customers have asked us to process. It is the Kenexa BrassRing customer's responsibility to ensure that the data the customer collects can be legally collected in the country of origin. The Kenexa BrassRing customer is responsible to give its employees and candidates for employment the appropriate level of notification that Personal Information is being collected and maintained. Kenexa BrassRing does collect aggregate and demographic data, which is not associated with an individual candidate's Personal Information, and that may be used for statistical analysis and training purposes.
Notification of Changes/Choice
We will maintain information in accordance with this ASP Privacy Policy. If we decide to change this Policy, we will post the changes on this page so that our recruitment software customers or their candidates for employment are always aware of what information we process, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use Personal Information in a different manner, we will notify our recruitment process customers by way of email or by posting a notice on our website for at least 30 days prior to the change in use. Customers, in turn, are responsible for notifying candidates and providing them a choice as to whether or not we use their information in this different manner.
Onward Transfer
We employ other companies and individuals to perform functions on our behalf. Examples may include customer service, resume processing, and data storage. If we disclose information of our customers or job candidates to a third party that is acting as our agent or on our behalf, we will ensure that the third party has agreed to abide by the Safe Harbor principles or is subject to the Data Directive, or can otherwise assure adequate protection of such information. We may seek to assure adequate protection, for example, by entering into written agreements with third parties requiring such parties to provide at least the same level of privacy protection as is required by the Safe Harbor and/or the Data Directive.
Data Integrity
Kenexa BrassRing will use Personal Information only in ways compatible with the purpose for which it was collected or subsequently authorized by our customers. Kenexa BrassRing will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate and complete.
Security
Kenexa BrassRing is committed to ensuring the security of the information it processes. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. Kenexa BrassRing strives to protect the privacy of the information we process, and inadvertent disclosure is extremely unlikely. In the event of such an inadvertent disclosure, Kenexa BrassRing will take all commercially reasonable steps to limit and remedy the disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those procedures or use your personal information for improper purposes.
Access/Correction

In most cases, when BrassRing collects Personal Information we do so on behalf of another company (as an agent or data processor). To request access to, correction, amendment or deletion of this information, please contact the company to which you provided it. BrassRing technology allows its recruitment software customers access to all of the information processed on their behalf and allows for the processing of any requested corrections to, amendments or deletion of such information.

Oversight/Enforcement
Kenexa BrassRing has a Privacy Officer who is responsible for Kenexa BrassRing's compliance with and enforcement of this Policy. Kenexa BrassRing's Privacy Officer, Ronald Poore, is available to any of its employees, customers, vendors, business partners, or others who may have questions concerning this Policy or data security practices. Kenexa BrassRing's Privacy Officer may be contacted by email at ron.poore@kenexa.com, by telephone at 781.530.5155 or by mail at Kenexa BrassRing, 343 Winter Street, Waltham, MA 02451. If users have questions or concerns regarding this statement, they should first contact Ronald Poore.

We participate in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.org/consumers/watchdog_complaint.php, fax at 415-520-3420, or mail at Watchdog Complaints, TRUSTe, 685 Market Street, Suite 270, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.org/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

For human resources data we have agreed to cooperate with Data Protection Authorities. Any questions, comments or complaints about the data practices (including without limitation compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement) of a hosted recruitment software customer for whom Kenexa BrassRing processes data should be addressed to that customer.

IV. General

Security
Kenexa BrassRing has implemented reasonable technical and organizational measures designed to secure personal information collected on our website as well as Personal Data processed on behalf of its customers from accidental loss and from unauthorized access, use, alteration or disclosure including, in appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes.
Notification of Changes
If we decide to make material changes to our privacy policy, we will post those changes here, on the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify our hosted recruitment software customers and/or our website users as appropriate via email and/or by posting a notice on our website for 30 days.
Legal Disclaimer
We may disclose personal information when required by law or in the good faith belief that such action is necessary in order to conform to the edicts of the law, comply with legal mandates, enforce the TOS of our websites, or to protect the rights, property, or personal safety of Kenexa BrassRing, its users and the public.
Children's privacy
Kenexa BrassRing committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Kenexa BrassRing does not knowingly collect information from children under the age of 13 and Kenexa BrassRing does not target its website or its products to children under 13.
Cookies
We may use both per-session and persistent cookies to enhance your experience while visiting our websites or using our hosted recruitment software. Cookies are a small piece of data stored locally by your browser that saves information and helps identify you to web sites upon subsequent visits. Cookies are uniquely assigned to your computer, and can only be read by a Web server in the domain that issued the cookie to you. Cookies generally assist users by performing certain functions such as saving passwords and personal preferences regarding the sites. Persistent cookies are stored for a length of time that is set by the Web server when it passes the cookie to the browser. These cookies are used to store information between visits to a site. Per-session cookies are used to store information only within a session. These cookies are cached only while a user is visiting the Web server issuing the per-session cookie and are deleted from the cache when the user closes the session.
You may have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline all cookies if you prefer. Alternatively, you may be able to modify your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. If you choose to decline cookies, however, that may hinder performance and negatively impact your experience on our websites and your use of the hosted recruitment software.
The Kenexa BrassRing websites and our hosted recruitment software may contain links to other sites. Please be aware that we are not responsible for the privacy practices or content of such other sites.
We may post customer testimonials on our web site which may contain personally identifiable information such as the customer's name. We do obtain the customer's consent prior to posting the testimonial to post their name along with their testimonial.

Last updated on: 19 January 2007