Privacy Policy

1. Introduction

KIN + CO. (“Company”, “we”, “our”, or “us”) takes seriously its commitment to preserve the privacy of the Personal Information (or “Information”) that we collect. We will only collect information, which is reasonably necessary for the proper performance of our activities or functions as a recruitment agency.

The purpose of this Privacy Policy is to describe what Personal Information we may collect from you, how we use, collect and share that Information, and the choices and rights that are available to you in regards to that Information.

Our Privacy Policy complies with all Federal and State privacy laws in place at the time.

For residents of the State of California, please refer to our California Privacy Policy (CCPA Privacy Policy).

2. Personal Information we may collect from you

We will collect Personal Information from you directly when you register or apply via our website www.kinandco.co (or third party job sites where our jobs are listed), fill out and submit our Candidate documents, or contact us with regards to your application for work.

We collect information from the following groups:

A Candidate - i.e. someone who is looking for a placement or work through us; or whom we have identified as a person who might be receptive to an offer of a placement or work through us.
A Client – i.e. someone other than a Candidate who is looking to acquire our services as a recruitment agency or whom we have identified as someone who might be interested in acquiring our services.
A Referee – i.e. a person from whom we have sought facts or opinions regarding the suitability of one of our Candidates for work or positions through us; and who may be a Referee nominated by the Candidate, a Client or us.

2.1 For Candidates

The type of information that we typically collect and hold about Candidates, is information that is necessary to assess amenability to work offers and work availability; suitability for placements; or to manage the performance in work obtained through us. Data requested of you will include but is not limited to:

Your full name, phone number, email address, postal address, resume, position, educational background, qualifications, personality or character, professional experience, career path and preferences for work, desired salary expectations, ability to undertake specific types of work, references, willingness to travel and hyperlinks to social media networks.
We may also collect ‘Sensitive Personal Information.’ Sensitive Personal Information is only collected with consent and will need to be collected where it relates to a genuine occupational requirement, for the purposes of verifying the right to work in the United States of America or an inherent requirement of the job or work being considered. Our collection of some types of Sensitive Personal Information is governed by Equal Employment Opportunity and Anti-Discrimination laws.
Any and all communications with us, via email, including shared documentation, phone, via our website, via video link, in person or any other means will be recorded in our recruitment software system.
We may decline to collect unsolicited Personal Information from or about you and may take such measures as we think appropriate to purge it from our systems.

2.2 For Clients

The type of information that we typically collect and hold about Clients is information that is necessary to help us manage the presentation and delivery of our services and includes:

Client relationship information
Information about position, contracting and hiring authority
Information about team structures and roles
Information about incidents in the workplace
Client facility addresses, key personnel and contact details

2.3 For Referees

The type of information that we typically collect and hold about Referees is information that is necessary to help us make determinations about the suitability of our Candidates for particular jobs, or particular types of work and may include:

Information about work position, authority to give a reference and preferred contact details.
Opinions of the Referee regarding the Candidates work performance.
Facts or evidence in support of those opinions, sometimes involving the Referee’s own knowledge and experience of having worked with the Candidate.

3. How we use your information

The purposes for which we collect, hold, use and disclose your Personal Information are those purposes that are reasonably necessary for the proper performance of our functions and activities as a recruitment agency. How we use your information will differ depending on whether you are:

A Candidate
A Client
A Referee

3.1 For Candidates

Information that we collect, hold, use and disclose about Candidates is typically used for:

Work placement operations (such as sharing your resume with a Client for the purpose of finding you employment)
Recruitment functions
Staff management
Payment purposes
Visa purposes (if applicable)
Training needs assessments
Marketing services to you
Statistical purposes and where necessary, to comply with any legal obligations including but not limited to cooperating with investigations carried out by the police, government or regulators
Background checks, by approved third parties
To respond to your requests or questions when you contact us, including sending you emails and other communications including marketing

3.2 For Clients

Personal information that we collect, hold, use and disclose about Clients is typically used for:

Client and business relationship management
Work placement operations
Recruitment functions
Training needs assessments
Marketing services to you
Statistical purposes and where necessary, to comply with any legal obligations including but not limited to cooperating with investigations carried out by the police, government or regulators
To respond to your requests or questions when you contact us, including sending you emails and other communications including marketing

3.3 For Referees

Personal information that we collect, hold, use and disclose about Referees is typically used:

To confirm identity and authority to provide references
For Candidate suitability assessment
For Recruitment functions

3.4 Our Direct Marketing Policy

We may use your Personal Information for the purposes of direct marketing, except where you have specifically requested we don’t. We market to Candidates and Clients using a variety of methods including email, social media (including Facebook, Twitter and LinkedIn), phone and print.

Upon receipt of your request to opt out of marketing, your preferences are updated in our systems and you will no longer receive any communications from us.

4. Do you have to provide to us, the Personal Information we request?

The provision of your Personal Information via our various forms is not a statutory or contractual requirement.
You are not obliged to provide your Personal and Sensitive Personal Information to us. However it is more or less impossible for us to work with you and provide our services to you, if you do not.
If you do not agree to our processing of your data as per this Privacy Policy, please do not submit any personal data to us.

5. How we collect your Personal Information

5.1 For Candidates

We will collect Personal Information from you directly when you register or apply via our website www.kinandco.co (or third party job sites where our jobs are listed), fill out and submit our Candidate documents or contact us with regards to your application for work.

Personal Information is also collected when:

We receive or give any reference about you
We receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body
We receive performance feedback (whether positive or negative)
We receive any complaint from or about you in the workplace
We receive any information about a workplace accident in which you are involved
We receive information from publicly available sites such as LinkedIn
You provide us with any additional information about you either by phone, email, in person or other means

We may also collect Personal Information about you from a range of publicly available sources including from the Internet, social media sites, newspapers, journals and directories. We collect Personal Information about you from publicly available sources, for inclusion in our records only as is reasonably necessary for the performance of our activities or functions as a recruitment agency.

5.2 For Clients

Personal Information about you may be collected:

When you provide it to us for business or business related social purposes
We receive information from publicly available sites such as LinkedIn
Electronically through our telecommunications and technology systems

5.3 For Referees

Personal Information about you may be collected when you provide it to us:

In the course of our checking Candidate references with you and when we are checking information that we obtain from you about Candidates
For business or business related social purposes
We receive information from publicly available sites such as LinkedIn
Electronically through our telecommunications and technology systems

We may also collect Personal Information about you from a range of publicly available sources including from the Internet, social media sites, newspapers, journals and directories. We collect Personal Information about you from publicly available sources for inclusion in our records only as is reasonably necessary for the performance of our activities or functions as a recruitment agency.

5.4 Electronic Transactions & Data Security

This section explains how we handle Personal Information collected from our website www.kinandco.co, social media, recruitment database and by any other technology in the course of our business operations.

Although we will do our best to protect your Personal Information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your Personal Information transmitted to the Website or any third party; for this reason, any transmission is at your own risk. We will use strict operational procedures and adequate, technical and organizational security measures to prevent any unauthorized access, change, deletion or transmission of this Personal Information. You should take all appropriate steps to protect your Personal Information.

Sometimes, we collect Personal Information that individuals choose to give us via online forms or by email. For example, when individuals:

Ask to be on an email list such as a job notification list
Register as a site user to access facilities on our site such as a job notification board
Make a written online enquiry or email us through our website
Submit a resume by email or through our website
Make a job application to us through an external job board or website
Follow and communicate with us via social media such as LinkedIn, Facebook and Twitter

5.4.1 Web Browsing

When you look at our website, our website host makes a record of the visit and logs (in server logs) the following information for statistical purposes:

Your server address
Your top level domain name
The pages you accessed and documents downloaded
The previous site you visited; and
The type of browser being used

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet service providers server logs.

We do not accept responsibility for the Privacy Policy of any other site to which our site has a hyperlink, and it is advisable to look at the Privacy Policy of other sites before disclosing Personal Information.

5.4.2 Cookies

Cookies are uniquely numbered identification numbers like tags, which are placed on your browser. By themselves cookies do not identify you personally, but they may link back to a database record about you. If you register on our site, we will then link your cookie back to your Personal Information details.

This website uses cookies to ensure your next visit to the site is easier, enhancing your user experience. We use them, for example, to remember your search preferences, to make the information you see more relevant to you, to help you sign up for our services and to protect your data. It also allows us to effectively analyze how our visitors use our website and to monitor its performance.

If you do not wish us to retain any information about your visit to our site, you might consider deleting the cookies on your browser and changing the settings on your web browser program.

5.4.3 Social Networks and Web Searches

In order to assess your suitability for positions and to assist you to find work, we conduct Internet searches using social media sites such as LinkedIn, search engines and regulatory or government agency sites by entering your name and relevant identifying details.

5.4.4 Emails

Our technology systems log emails received and sent and may include voting, and read and receipt notifications to enable tracking.

When we receive your email address because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and will not be used or disclosed for any other purpose without your consent, other than as may be permitted or required by law. Exception to this rule: Your email address, details, information and records as provided by email will be added to our information record system for the purposes of recruitment services.

5.4.5 Call & Message Logs

Our telephone technology (systems and mobile phones) logs telephone calls, messages received and sent and enables call number display. They also allow text messaging (SMS).

When your call number is received by us because you phone us or send us a message, the number will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent, other than as may be permitted or required by law.

5.4.6 Teleconferences, Video Conferences and Video Chats such as Google Hangouts

Teleconferences, videoconferences and video chats may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.

5.4.7 Mobile Access

Our staff uses laptops, tablets, phones and other portable electronic devices that allow them to access, retrieve and store your Personal Information.

5.4.8 Cloud Computing Services including our Recruitment Database

As we use recruitment & accounting cloud-computing services, we will take reasonable steps to ensure that:

Disclosure of your Personal Information to the cloud service provider is consistent with relevant laws. This may include ensuring that we have obtained your consent, or that the disclosure is for purposes within your reasonable expectations.
Our Cloud computing services providers terms of service, recognize that we are bound by obligations to protect the privacy of your Personal Information and that they will not do anything that would cause us to breach those obligations.

The recruitment database contains the information and documentation you have provided us. This database operates from servers that permit disclosure to cross-border recipients. Your information will only be used or disclosed as reasonably necessary for the performance of our activities or functions as a recruitment agency. Information you provide to us is stored in our secure cloud-based recruitment database, document management system and document storage system, which are restricted and accessible by staff through the use of individual login credentials.

5.4.9 Paperless Office

Recognizing the environmental advantages and efficiencies it provides, we operate a partially paperless office as a result of which your paper-based communications with us may be digitized and retained in digital format. The paper-based communications may be culled. Your information may also be securely stored in hard copy in a lockable filing system, until such time as it is digitized and that information filed in our cloud-based recruitment system. When this occurs, the hard copy document/s are subsequently destroyed.

It is therefore important that, except where specifically requested, you do not send us originals of any paper based document and that you retain copies for your own records.

Where we do request original paper based documents, we will return them to you once they are no longer required by us for the purpose for which they may be used or disclosed.

5.4.10 Information Security

We will take all reasonable steps to ensure the information you provide us remains secure and confidential and is only used for the performance of our functions or activities as a recruitment agency.

We take a range of measures to protect your Personal Information from misuse, interference and loss, unauthorized access, modification or disclosure. These measures include:

Staff training
Password-protection of cloud-based database, document management and document storage system;
“Clean desk” procedures
Secure office premises with restricted access
Need-to-know and authorization policies
Policies on laptop, mobile phone and portable storage device security
Document culling procedures including shredding and secure disposal

6. Disclosures

This section deals with our disclosure policies. Personal Information that we hold about you is only disclosed for the primary and related purposes for which it was collected. In this section you will find out about our policies dealing with:

General disclosures
Related purpose disclosures
Cross border disclosures

6.1 General Disclosures

We may disclose your Personal Information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted. We may disclose your Personal Information where we are under a legal duty to do so, including circumstances where we are under a contractual duty to disclose information.

Disclosure will usually be:

Internally and to our related entities
To our Clients
To Referees for suitability and screening purposes

In addition to disclosures for general purposes, we may also disclose your Personal Information for a range of related purposes.

6.2 Related Purpose Disclosures

We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSPs may see some of your Personal Information. Typically our CSPs would include:

Software providers
IT contractors
Financial service providers
Database designers and Internet service suppliers
Legal and other professional advisors
Insurance brokers, loss assessors and underwriters
Travel-booking agents
Government bodies as required by law
Background checking and screening agents

We take reasonable steps to ensure that terms of service with our CSPs recognize that we are bound by obligations to protect the privacy of your Personal Information and that they will not do anything that would cause us to breach those obligations.

6.3 Cross-Border Disclosures

Some of your Personal Information may be disclosed to overseas recipients. At present, your data is stored as follows:

Country	Type of Information	Likely Recipients
United States of America	Any information held on our recruitment system	Our recruitment database provider holds data on their servers in the United States of America
United States of America	Any information held in our financial software system	Our financial software provider holds data on their servers in the United States of America
United States of America	Any information held in our form management software system	Our form management software provider holds data on their servers in the United States of America

7. How you can access, correct and delete your Personal Information

Privacy rights enable an individual to make specific requests to an organization, regarding the processing of their personal data. Under applicable data protection laws, you have the following rights:

Right to access and obtain a copy of your Personal Information: You are entitled to request confirmation on how your Personal Information was processed. In some cases you can ask us to provide you with an electronic copy of your information. You should also anticipate that it might take a little time to process your application for access, as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within five (5) working days.
Right to correct your Personal Information: If you can demonstrate that the Personal Information we hold about you is incorrect, you can ask that this information is updated or otherwise corrected.
Right to restrict the processing of or delete your Personal Information: Should you wish to be removed from our recruitment software system, we will duly make you inactive and no longer contact you. As a Candidate, your resume will remain on our database as it is linked to our record keeping processes and the manner by which our recruitment software operates. We are required by law to keep your information for as long as is necessary in order to comply with legal or regulatory responsibilities. The retention periods of your Personal Information depend on the respective purpose the data are processed for and the respective tool such Personal Information are processed in. It is not possible to outline the various retention periods in a reasonably intelligible format under this Policy. The criteria used to determine the applicable retention period are that we will retain the Personal Information set out in this policy for as long as (i) necessary for the respective purpose, (ii) necessary to carry out our business relationship with you, (iii) you have consented to, and/or (iv) required by applicable statutory retention laws.

8. Complaints

You have a right to complain about our handling of your Personal Information if you believe that we have interfered with your privacy.

8.1 How to complain

If you are making a complaint about our handling of your Personal Information, it should first be made to us in writing.

You can make complaints about our handling of your Personal Information via hello@kinandco.co

8.2 How your Complaint will be Handled

When we receive your complaint:

We will take steps to confirm the authenticity of the complaint and the contact details provided to us, to ensure that we are responding to you or to a person whom you have authorised to receive information about your complaint.
Upon confirmation we will write to you to acknowledge receipt and to confirm that we are handling your complaint in accordance with our policy.
We may ask for clarification of certain aspects of the complaint and for further detail.
We will consider the complaint and may make inquiries of people who can assist us to established what has happened and why.
We will require a reasonable time (usually 30 days) to respond.
If the complaint can be resolved by procedures for access and correction, we will suggest these to you as possible solutions.
If we believe that your complaint may be capable of some other solution, we will suggest that solution to you, on a confidential and without prejudice basis in our response.

You can also lodge a complaint about our processing of your Personal Information with your local data protection authority.

9. Changes to this Policy

The terms of this Policy may change from time to time. We shall publish any material changes to this Policy through appropriate notices either on our website www.kinandco.co or contacting you using other communication channels.

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