Effective Date: 4/1/2022

Highland Talent Payments, Inc. (“Highland Talent”) takes the privacy and security of personal information very seriously. As such, we have prepared the following Privacy Policy to provide you with information about how your data is collected, used, shared, transferred, and protected as a result of your interaction with https://www.highlandtalent.com/ (the “Site” or the “Services”). By using the Services, you agree to the following Privacy Policy. If you disagree with any of the provisions described below, your remedy is to stop using the Site immediately.

Visitors to the Site can browse without providing personal information. When you interact with the Site, and in order to take advantage of certain features on the Site, we may ask you to provide:

• Identifiers such as your name and
• Contact information such as your email address, physical address, phone number(s).

If you are a client, you may register for an online account to review information relating to the Services. If you request online access, Highland Talent will provide you with a username and password. At your first log-in, you will be asked to update the password and identify security questions in order to access the account if you misplace or forget your password. We will retain your username and password, as well as the responses to the security questions, for purposes of authenticating you to the online account.
It is your decision to use the Services, and, as such, any provision of this personal information is completely voluntary.

We also collect certain Internet and other electronic network activity information such as your browsing history on the Services, the length of time spent on certain pages, the website Uniform Resource Locator (“URL”) from the website you were visiting before coming to this Site, which URL you next visit, device type, what browser you are using, Internet service provider, date/time of visit information, operating system, and your Internet Protocol (“IP”) address.

Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Cookies may be stored only for the time you are in a given site or they may remain stored in your browser for a defined period of time beyond your current session. Cookies work in combination with content within the website itself, to capture and remember information. To learn more about these technologies and how they work, please see www.allaboutcookies.org. We use cookies and other similar technologies (such as web beacons and pixels) to collect and process Internet and other electronic network activity information. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can review the options available to manage cookies in your browser. One option is to disable, or turn-off, all cookies. If you turn cookies off, you may not be able to browse the Sites. If you disable certain kinds of cookies, some aspects of our Sites may not function properly or as well.

We will use the information collected in the following ways. Specifically, we will use your:

• Identifiers and Contact Information to:

You may have choices when it comes to the collection, use, and sharing of your personal information. As noted, it is often your choice whether you provide information to us through the Site or Services. You may opt-out of receiving promotional email communications from Highland Talent by following the unsubscribe link or instructions provided in any email we send or by contacting us directly.

Our Site may provide you with links to third party websites so that you can browse those sites for items that may be of interest. Highland Talent is not responsible for the collection, use, or sharing of your personal information once you leave our Site and follow a link to one of these third-party websites. Please consult each linked website’s privacy policy for a description of how the website collects, uses, and shares your information.

The Site is not directed at nor intended for children under the age of 13 years old. We do not knowingly collect information from children under the age of 13 through the Site. If you believe that a child under the age of 13 may have provided his or her information to us, please contact us using the contact information below.

We do not track personal information about your online activities over time and across third-party Web sites or online services, and do not allow third parties to conduct such activity, and therefore we do not respond to Web browser “do not track” signals.

We are located in the United States. If you are not a resident of the United States, your country’s laws governing data collection and use may differ from those in the United States; in particular, the United States may not provide the same level of protections as those in your own country. Data collected in jurisdictions outside of the United States may be transferred to servers in the United States for processing. We will transfer that data:

• Where we have received your consent for processing such information for one or more specific purposes;
• When we are legally required to complete such transfer;
• Pursuant to Standard Contractual Clauses; and/or

Depending on your state or country of residence, you may have the following rights.

Right of Access. You may have the right to access your personal information maintained by us. Upon receipt of a verifiable request to access personal information, we will disclose and deliver, free of charge, the personal information requested.

Right of Deletion. You may have the right to request that we delete any personal information about you which we have collected from you. Upon receipt of a verifiable request for deletion, we will delete your personal information from our records and direct any service providers to delete your personal information from our records, within 45 days.

We will comply with your request to delete personal information unless it is necessary for us to maintain your personal information in order to:

• Complete a transaction, provide requested-for goods/services, and/or perform a contract between you and us;
• Detect security incidents;
• Comply with a legal obligation;
• Enable our internal uses that are aligned with your expectations and your relationship with us.

Right of Portability. You may have the right to receive your personal information, in a structured, commonly used and machine-readable format, and may have the right to have us transmit your information to another entity, if relevant.

Submission of Requests for Information. In order to make a request to access, delete, or transmit your personal information, please send an email to privacy@highlandtalent.com

Verification. After you submit a request, we will promptly take steps to determine whether your request is a verifiable request. We will take steps to verify that you are who you say you are before honoring your request.

We will disclose and deliver the required information to you free of charge within 45 days of receiving your verifiable request. If necessary, we will extend the time period to provide the required information once by an additional 45 days, and will provide you with notice of the extension within the first 45-day period. The disclosure shall cover the 12-month period preceding our receipt of the verifiable request.

As noted below, we do not knowingly collect information from or about children, including children aged 16 and under. We do not sell information of minors under 16 years of age.

Authorized Agent. You have the right to designate an authorized agent to submit an access or deletion request on your behalf. If you use an authorized agent to submit such a request, we will require that you:

• Provide the authorized agent written permission to act on your behalf; and
• Verify your own identity with us before we can honor the request.

We have not sold personal information to third parties for a business or commercial purpose in the last 12 months. We do not intend to sell personal information to third parties.

No Discrimination. We will not discriminate against an individual because the individual exercised any of the rights described here.

We understand the importance of information security and will take reasonable measures to protect the security and confidentiality of your information. Please understand that no measures can guarantee 100% security. You are responsible for the security of your log-on information. Please do not share you log-on password with anyone. If you believe your log-on password has been compromised, please contact us immediately.
We reserve the right to make changes to this Privacy Policy. We will post changes directly to this Privacy Policy, so it is your responsibility to check back here from time to time to review this Privacy Policy. If we make a material change in the type of information we collect or its use, we will provide advance notice of such change, and obtain your consent for the new collection or use, as required by law.
If you have any questions or concerns about this Privacy Policy, please contact us using the information below.