SuccessFinder Privacy Policy

Effective as of September 1, 2023

1. Introduction

SuccessFinder Inc. (“SuccessFinder”, “we”, “us”, “our”) provides a self-assessment platform for talent management across the employee lifecycle through a Software as a Service (SaaS) model, accessed via web browser (the “Platform”). The Platform is comprised of the client application which is used by Client Users (as defined below in paragraph 2.2) of SuccessFinder to manage the assessments and results of their participants and the participant application which is used by Participants (as defined below in paragraph 2.1 below) to complete their assessment. At SuccessFinder, we are committed to protecting your privacy and the data you share with us. This privacy policy explains how SuccessFinder processes information about any identified or identifiable individual or natural person (“Personal Data”) collected through its website at www.successfinder.com (the “Website”), through the Platform or through any other channel, in accordance with applicable laws and regulations (such as the Act respecting the protection of personal information in the private sector or the General Data Protection Regulation or “GDPR”, for example). This privacy policy also describes the rights individuals have with respect to Personal Data we hold about them. Information that is anonymized so that it cannot identify an individual directly or indirectly is not considered to be “Personal Data”.

Please note that SuccessFinder will never sell or rent your Personal Data for promotional use.

SuccessFinder maintains governance policies and practices which ensure the protection of your Personal Data. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your Personal Data, including:

  • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle;
  • Employee privacy and data security training;
  • Designating a Privacy Officer to monitor and manage SuccessFinder’s compliance with applicable data protection laws. The Privacy Officer’s role and responsibilities include approving internal policies and practices regarding the protection of Personal Data, assisting in conducting privacy impact assessments (when required by law), and responding to access and rectification requests or similar types of requests in accordance with this Privacy Policy and applicable laws, just to name a few;
  • Procedures for receiving, investigating and responding to complaints or inquiries regarding SuccessFinder’s information handling practices, including any confidentiality incident involving Personal Data and any request from individuals to exercise their data privacy rights (e.g. access to information). The “ 13. Contacting Us“ section below includes instructions you may use to communicate with us if you have any questions or concerns regarding our information handling practices;
  • Treating any information stored on our Platform as confidential and accessible by authorized personnel only;
  • Implementing and maintaining appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure;
  • Framework limiting our retention of Personal Data to what is necessary to achieve the purposes described in this Privacy Policy. This framework also governs the disposal of your Personal Data and is more fully described in the “Data Retention” section below.

2. Information we collect

2.1 PARTICIPANTS

A Participant is a person who has completed a SuccessFinder assessment on the SuccessFinder Platform. Personal Data submitted by Participants is referred to in this policy as “Participant Data”.

Generally, Participants access the SuccessFinder Platform on the request of a client of SuccessFinder, such as the Participant’s employer, potential employer or another type of third party (e.g.: an independent practitioner such as a coach, a consulting firm, etc.), for whom the client account was created (the “Client”). In such cases, SuccessFinder collects and processes Participant Data as a data processor on behalf of the Client, who is acting as the data controller. The Client provides us with instructions on what to do with Participant Data and a Client has many choices and control over such Participant Data. For example, Clients may provision or deprovision access to the Platform (including different features and data access) to Client Users, manage permissions (who else in an organization is authorized to view reports), retention and export settings. These choices and instructions may result in the access, use, disclosure, modification or deletion of certain or all Participant Data, over which SuccessFinder has no control.

However, in certain circumstances, an individual may submit Participant Data in the context of a free trial or demo of our Platform or as a job applicant at SuccessFinder. SuccessFinder may also conduct certain data analytics and research activities using aggregated and de-identified Participant Data as well as sociodemographic information voluntarily submitted by Participants. In all such circumstances, SuccessFinder acts as a data controller of the Participant Data.

2.1.1 Information we collect directly from Participants.

When you use the Platform as Participant, we collect the following categories of Personal Data directly from you:

  • Account information – We collect your name, email address and password you provide to create your Participant account.
  • Answers to the SuccessFinder assessment – We collect your forced-choice answers to the items in the SuccessFinder assessment. Based on your responses, we compute the scores on the different constructs measured by SuccessFinder. These scores can be visualized by Client Users in the form of analysis tools and/or reports. Your responses to the SuccessFinder assessment and the related results will be saved in your profile account on our system. Your results may be shared with you by our Client, at the Client’s discretion.
  • Sociodemographic survey responses – As a Participant you have the option (not the obligation) to respond to sociodemographic survey questions (age group, gender, ethnic background, etc.). Your answers to these questions will never be shared by us with the Client for who you are completing the assessment or with any other third parties, and are not used to compute your assessment results or in connection with any employment decision.

Any other information you provide to us – We collect any information you share with us in connection with your use of the Platform. This may include administrative and support communications with us.

2.1.2 Information we collect automatically about Participants.

We also automatically collect access logs from Participants using the Platform, such as Internet Protocol (IP) address from which the Participant completed the assessment and test and metrics data, such as location (based on IP address). Please refer to the Cookies and Related Technologies section for details about information we collect about all visitors of our Website.

2.2 CLIENT USERS

Client Users are individuals who have been given access to the Client application on the Platform by a Client (as defined at section 2.1).

2.2.1 Information we collect directly from Client Users.

When you use the Platform as Client Users, we collect account information directly from you, namely: your name, email address, and password you provide to create your account. If you are requested by the Client to complete our certification/training program, we also collect information regarding your progress and status on completion of training modules and final results/score, certificates).

2.2.2 Information we collect from our Clients.

We may receive your Personal Data from the Client with which you are affiliated (e.g., your employer). This allows us to grant you the appropriate permissions to access our Platform.

2.2.3 Information we collect automatically.

Please refer to the Cookies and Related Technologies section for details about information we collect automatically about all visitors of our Website.

2.3 WEBSITE VISITORS

If you are a visitor to our Website only, and not a Participant or Client User of our Platform, then this section is relevant for you.

2.3.1 Information we collect directly from you.

We collect any Personal Data that you volunteer to us in our Website’s forms, such as when you register for events or sign up for information, Platform demo and newsletters.

2.3.2 Information we collect automatically.

Please refer to the Cookies and Related Technologies section for details about information we collect automatically about all visitors of our Website.

2.4 OTHER CATEGORIES OF INDIVIDUALS

We collect Personal Data about other categories of individuals when these individuals interact with us, including:

  • Clients and suppliers. We collect Personal Data about our Clients and suppliers (or potential Clients and suppliers), or their representatives when the Client or supplier is an organization. This may include information such as name, business email address, business address and business phone number and payment information. Certain clients may choose to use PayPal pay for our services, in that case they will be directed to the PayPal website and provide their payment information directly to PayPal. PayPal’s privacy policy applies to the information such Clients provide on the PayPal website.
  • Job applicants. We collect professional or employment-related information and other information you submit to us when applying for an employment opportunity, which may include your contact information, demographic information as well as letters of motivation, your resume, references and any additional information provided by you in the application form, including without limitation Participant Data.

3. How we use your information

SuccessFinder may use Personal Data for the following purposes, or otherwise with your consent or as permitted by law:

  • To deliver our services. We use Participant Data to provide our services to our Clients (as required under our service agreement with our Clients) and to Participants who access the Platform as part of a free trial or demo. This includes using Participant’s assessments answers to create scores and generate reports. Certain Personal Data are necessary in order for a Participant to complete the assessment on our Platform. If a Participant does not provide such Personal Data, SuccessFinder will not be able to provide the services to its Client.
  • To communicate with you. SuccessFinder may communicate with you by email. For instance: we send direct emails to Participants in relation to the assessment process (e.g., when Participants are invited or reminded to complete the assessment); we send direct emails to Client Users related to accessing and using their account (e.g., when they have been given access to a new client account, as well as other notifications about Participant activity in their account); we contact Client Users to inform them about changes in our Platform and important Platform-related notices, such as security or update notices (these emails are necessary to provide our services you may not opt-out of them). We also send emails to you about our services if we believe that they may be of interest to you or if you have subscribed to receive our newsletter. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages.
  • To enable you to access and use our Website and Platform, for instance by allowing Participants and Client Users to create an account to use our Platform, to customize content for visitors, and to improve its website by analyzing how visitors navigate its website.
  • To support Client Users’ on-boarding, product adoption and assess user engagement.
  • To provide and administer Client Users’ training and certification programs.
  • To manage our business operations. This includes: preventing or addressing service, security or technical issues; processing your employment application; and addressing a Client User or Participant’s request (for instance, if you contact

    su*****@su***********.com











     with a problem or question, we will use your information to respond); administering accounts and keeping track of billing and payments.
  • For research and analytics purposes in order to improve our services. We use aggregated de-identified data (such as de-identified assessment responses and sociodemographic survey responses) for research purposes, to maintain and improve the psychometric qualities (reliability and accuracy) of the assessment we offer, to ensure the assessment is fair and objective, and generally to develop and improve the services we offer.

4. Sharing of Personal Data

SuccessFinder may share Personal Data as described below, or otherwise with your consent or as permitted or required by law. Note that Clients determine their own policies for the sharing and disclosure of any Participant Data or reports, which SuccessFinder does not control.

  • SuccessFinder Clients and third-party integrations. SuccessFinder may share Participant Data with the Client that requested that you complete an assessment on our Platform, in accordance with our agreement with the Client and the Client’s instructions. Acting on our Client’s behalf, SuccessFinder may also share Participant Data with the provider of an integration added by the Client (e.g., human resources management platforms or applicant tracking system). The third-party provider of the integration may share certain information about your account with SuccessFinder. However, we do not receive or store your passwords for any of these third-party services. SuccessFinder is not responsible for how the provider of an integration service may collect, use, and share Participant Data. Also, should you contact SuccessFinder to help resolve a technical issue, we may need to share this information with the Client to help resolve the issue.
  • Service providers: We hire service providers to perform services on our behalf. This may include a person or an organization retained by SuccessFinder to perform work on its behalf, including cloud service providers, technology service providers, email platform providers, learning management system providers, human resources and recruitment management platforms, business analytics providers, customer relationship management platforms, marketing and advertising service providers and payment processing providers. We provide them with a limited amount of information necessary in order for them to provide the services required. They may not use the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers may not to disclose this information to others. SuccessFinder will strive to protect personal information disclosed to third parties by contractual agreements.
  • Business transaction.We may share Personal Data to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
  • As permitted or required by law. We may be compelled to share Personal Data to comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal processes. We may also share Personal Data to protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

5. Cookies and Related Technologies

As is true of most digital platforms, we and our third-party providers may also collect Personal Data from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Website and Platform. We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect such information, which may include:

  • Log data – When you use the Website and Platform, our servers automatically record information, including information that your browser sends whenever you visit a website. This log data includes your Internet Protocol (IP) address, your browser type and settings, the date and time of your use of the Website and Platform and the time spent on our Website and Platform, and language preferences.
  • Device information – We collect information about the device you are using to access the Website or Platform, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data (depending on what type of device you are using and its settings).

Geo-location information – Precise GPS location from devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine your approximate location.

Google Analytics. We use Google Analytics, a web analytics service provided by Google, to collect and view reports about the traffic on our Website and Platform. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.

Advertising services. Third party vendors, including Google and LinkedIn, may use cookies to inform, optimize and display ads based on your past visits to our Website. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, by visiting NAI’s online resources at http://www.networkadvertising.org/choices, or by visiting the Digital Advertising Alliance of Canada’s (DAAC) opt-out tool.

Tools to protect against inappropriate uses. We use tools that help protect against inappropriate uses, such as Google Invisible reCAPTCHA, which collects hardware and software information, such as device and application data and the results of integrity checks, as well as unique online identifications such as IP address, and sends that data to Google for analysis.

The cookies on the Website and Platform will be stored in your browser only with your consent. You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the pop-up cookie consent manager banner that appears when visiting the Website or Platform. This cookie consent manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.

If you choose to reject cookies, you may still use our Website and Platform though your access to some functionalities may be restricted.

You may also set or amend your web browser controls to accept or refuse cookies. Most browsers provide guidelines on cookie management. You can choose to authorize or reject cookies. You can even erase cookies. Management settings and features may vary from one browser or device to the next and are subject to change at any time. Check out the support sections of the browsers and devices you use to learn more. For more information on managing cookies, please visit www.allaboutcookies.org which has further information about cookies and online privacy.

6. Data Security

SuccessFinder takes security of your Personal Data very seriously. We use a variety of industry-standard administrative, organizational, technical and physical security measures to help protect Personal Data from unauthorized or unlawful processing and use and against accidental loss, destruction, damage, theft or disclosure.

7. Data Retention

As a general principle, we keep Personal Data for as long as necessary to achieve the purposes for which they are being processed, after which we will anonymize or destroy such data in accordance with applicable laws. If you have been asked to take an assessment by one of our Clients, such Client, as data controller, will decide how long Personal Data should be retained and is able to manage the retention and deletion process within the Platform accordingly.

When an individual submits Personal Data as part of a free trial or a demo of our services that or as a job applicant at SuccessFinder, we keep their Personal Data for a period of five (5) years.

8. Minors

Our Platform is not directed to minors under the age of 16 and you should not use our Platform if you are under 16 without parental consent.

9. GDPR

9.1 SUCCESSFINDER CLIENT AS CONTROLLER

In the course of our Clients’ use of the SuccessFinder platform, Client will dictate and control which Personal Data are to be processed by SuccessFinder. As a result, Clients will be responsible for their obligations as controller of Personal Data as defined in the GDPR.

9.2 SUCCESFINDER AS A CONTROLLER

In certain instances, SuccessFinder is acting as a controller for the processing of Personal Data, such as when an individual submits Participant Data in case of a free trial or a demo of our Platform, when an individual has subscribed to SuccessFinder’s newsletter, when SuccessFinder conducts certain data analytics and research activities using de-identified Participant Data, when SuccessFinder processes Personal Data about a job applicant, or when SuccessFinder processes Personal Data about its clients or suppliers’ business representatives.

9.3 SUCCESSFINDER AS A PROCESSOR

SuccessFinder shall process Personal Data in its role as processor in accordance and as defined in the GDPR, UK GDPR, and Swiss Federal Data Protection Act; and as described in this Privacy Policy.

All processing of Personal Data is performed in accordance with privacy rights and regulations, such as the GDPR, the UK GDPR, the UK Data Protection Act 2018, the Swiss Federal Data Protection Act.

Should Clients require SuccessFinder’s help in responding to a participant request as it relates to GDPR, UK GDPR and Swiss Federal Data Protection Act, they should contact our Data Protection Officer (DPO) at

dp*@su***********.com











.

9.4 LAWFUL BASIS FOR PROCESSING

SuccessFinder may process Personal Data on the following lawful basis:

  • Consent, when a Participant decides to complete a SuccessFinder assessment on the SuccessFinder Platform and respond to the optional socio demographic survey;
  • Contractual obligation with our Clients, suppliers or job applicants;
  • Legitimate interest. when SuccessFinder used deidentified and aggregated Participant Data for research purposes or improving the services.

In the case that SuccessFinder processes special categories of Personal Data as defined in GDPR, UK GDPR, the Participant has given explicit consent to the processing of those Personal Data for the specified purpose indicated at the time the consent is obtained.

10. Your rights

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws where you reside, these rights may include the right to:

  • Access your Personal Data held by us;
  • Know more about how we process your Personal Data;
  • Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
  • Erase or delete your Personal Data;
  • Object to any processing of your Personal Data;
  • Opt out of certain disclosures of your Personal Data to third parties;
  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”);
  • Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and
  • Not be discriminated against for exercising your rights as described above.
  • To lodge a complaint with your local data protection authority.

To exercise any of the rights described above or to complain, please contact us as set out in the “13. Contacting Us” section.

If you are a Client User, note that you can access and update certain Personal Data directly in your account settings at any time.

If your Personal Data has been submitted to us in our role as a processor by or on behalf of a Client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we can only access a Client’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the Client who submitted your data to us. We will refer your request to that Client, and will support them as needed in responding to your request within a reasonable timeframe.

11. International Transfers of Your Personal Data

SuccessFinder is based in the province of Quebec (Canada) and our Platform (including responses to the assessment, Participants’ scores and reports) are stored in Canada. If you are located outside of Canada and access our website or Platform, your Personal Data will be stored in Canada. Some of our service providers may access, process or store your personal information outside of the province of Quebec, including the other provinces of Canada and the United States. As a result, when your Personal Data is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

By submitting your Personal Data, you agree that we will process and store your Personal Data in Canada. If you are located in the EEA, UK or Switzerland, your Personal Data may be processed outside of the EEA, UK, Switzerland, these international transfers of your Personal Data are made pursuant to appropriate safeguards (namely the standard contractual clauses), and we will take suitable steps to ensure that your personal data is treated just as safely and securely as it would be within the EEA, UK or Switzerland and under GDPR, UK GDPR, and Swiss Federal Data Protection Act. Such measures shall include, but are not limited to, having data processing agreements with applicable sub-processors and ensuring that such sub-processors have adequate security and data protection procedures in place aligned with the GDPR or any other applicable data protection law. If you wish to inquire further about these safeguards used, please contact us as set out in the “13. Contacting Us” section.

12 Changes to this Privacy Policy

This policy is subject to change from time to time. Should that be the case, we will post any changes directly on this page and you can become aware of this by revising the “Effective Starting” date. We therefore encourage you to review our Privacy Policy whenever you use our Platform to stay informed about our information practices and the ways you can help protect your privacy. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws.

13 Contacting Us

Please also feel free to contact us if you have any questions about our Privacy Policy or practices, using the following contact information:

You may also reach us at our mailing address below:

SuccessFinder Inc.
1010 Sherbrooke Street West, #1900A
Montréal, Quebec
H3A 2R7, Canada
Tel.: 1-844-932-3231

We have appointed a representative in the EEA. You can contact them as follows:

Ametros Ltd
Unit 3D, North Point House
North Point Business Park
New Mallow Road
Cork
Ireland

Tel: +353 0330 223 2246
Email:

gd**@am**********.com











We have also appointed a representative in the UK. You can contact them as follows:

Ametros Group Ltd
Lakeside Offices, Thorn Business Park
Hereford, England, HR2 6JT

Tel: +44 (0) 330 223 2246
Email:

gd**@am**********.com











 

© 2023 SuccessFinder Inc.