lucemio LLC (also referred to as “lucemio,” “we,” “us”), and our affiliates, as a provider of outsourcing and recruitment services, including but not limited to business process outsourcing (BPO), recruitment process outsourcing (RPO), traditional recruitment services including but not limited to retained search, and consulting services including but not limited to analytics and reporting, share your concerns about the protection of your personal information.


lucemio LLC offers RPO and recruitment services to help companies recruit new personnel (“RPO and Recruitment Services”), as well as consulting and other services including BPO and analytics and reporting (“Consulting Services”). We may collect information about you in connection with either or both of these services.


lucemio LLC takes the security of your information seriously and wants you to be familiar with how we collect, use and disclose information about you. This Privacy Policy (the “Privacy Policy”) describes our privacy practices regarding the collection, use and worldwide transfer of personal information collected by lucemio LLC in connection with our RPO and Recruitment Services and Consulting Services (collectively, the “Services”), including information collected offline; through our web sites, including but not limited to www.lucemio.net, healthcare.lucemio.net, rpo.lucemio.net, search.lucemio.net and other websites located on www.lucemio.com (collectively, the “Site”); through the software applications made available by us for use on or through computers or mobile devices (the “Apps”); through our social media pages and apps to which the Site links (collectively, our “Social Media Pages”), as well as through HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, including the Site, Apps and our Social Media Page, the “Online Systems”).


By using the Online Systems, you signify your agreement with this Privacy Policy. If you do not agree to this Privacy Policy, do not use the Online Systems.


PERSONAL INFORMATION WE COLLECT.

lucemio LLC collects personal information from employers and clients seeking to use our Services, job seekers who also seek to use our Services, and experienced recruiters seeking to join our network of independent and paid recruitment or search consultants, and this information for employer clients may include but isn’t limited to industry, company name, company website, company size, agent full name, company title, department, office number, mobile number, fax number, email address and physical address, information related to job postings, and questionnaires or surveys or other assessments to establish organizational cultural fit between prospective employer and prospective candidate, release forms, and other needed information to verify the identity of the employer clients’ company and its authorized agents, and payment information, and for job seeker clients we may collect information that may include but that isn’t limited to cover letters, resumes, references, release forms, and questionnaires and surveys, and from experienced recruiters looking to join our network of independent recruitment or search consultants we may also collect information that may include but isn’t limited to cover letters, resumes, references, release forms, and questionnaires and surveys.


As such, when you provide us with information, the kind of which was previously outlined above, it will be captured through our Online System or through any other means including but not limited to, for example, when you register to use our Online Systems, submit or build a resume or submit or build a job posting, respond to potential employment opportunities, answer online assessment questionnaires or surveys, provide information about yourself to our recruitment or search consultants, or other lucemio LLC personnel or affiliates, or contact us via email or postal mail or phone or virtual call or meeting or in-person or relayed to us through some other means. We also collect personal information about you from third parties, including, for example, when other users of our Services provides information about you, when a colleague recommends that we consider you for a position or from other sources such as public databases, joint marketing partners and social media platforms.


In the course of our Services, we also may collect the following personal information about potential candidates: name, address, telephone number, email address, resume information (e.g., employment history, education, professional credentials, memberships in professional organizations, skills), citizenship, information from former employers and other references, and other information to the extent we have acquired or the individual has provided us with such information.


In certain cases, we may request sensitive information in connection with our Services. For example, our assessments may include demographic survey questions that our clients may choose to use for their participants, such as questions about gender, race, age, or country of origin.


In the course of our Services in certain regions, we may collect personal information related to gender, and we also may collect information related to race for diversity purposes. As permitted by applicable laws, we may obtain background verification information. We may also use photos or videos of you that you provide to us or that you make publicly available on the Internet (e.g., LinkedIn) for internal reference purposes only. We also with record initial screenings with prospective candidates to be released with the candidates consent to specific prospective employers and clients unless we’re given a blanket authority to share it with those prospective employers and clients would be a good match. Prospective employers and clients will not have any rights of ownership over your internally created videos and will not be allowed to download such videos. They will only have access to view prospective candidates and clients internally created screening videos for a period of seven (7) calendar days which may be extended with the candidates consent after which time the prospective employer and client will lose access to view these internally created recorded screenings. Job seekers, who are potential candidates for specific job opportunities, may opt out of having their initial screenings with lucemio LLC not recorded, however, this may potentially hurt their ability to secure a placement with a desired employer and client relative to other candidates who do opt in to have their initial screenings with us recorded and made available to those prospective employers they designate.


Except in these limited cases, we encourage you not to provide any other sensitive information to us, such as Social Security numbers, and in the case of employer clients disclosure of payment information until we formally request it using our security procedures and encrypted methods, information related to job seeker or recruiter’s racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership.


We may use one or more third-party vendor(s) (“Vendor”) to handle webinars, assessments and other services that you may encounter in the course of using our Services. In such cases, you may be directed to a webpage that is hosted by the Vendor (or its service providers) and not by lucemio LLC (such page, the “Vendor Page”). Any personal information that you provide through the Vendor Page will be collected by the Vendor and not by lucemio LLC, and will be subject to the Vendor’s privacy policy, rather than this Privacy Policy. lucemio LLC has no control over, and shall not be responsible for, the Vendor’s use of information collected through the Vendor Page. Please note that this Privacy Policy does not address the collection and use of information through the Vendor Page or the privacy or information practices of the Vendor.


If you submit any personal information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.


HOW WE USE THE INFORMATION WE COLLECT.

We use the information we collect in support of our Services. The following paragraphs describe some of the ways in which we may use personal and other information:


Fulfilling your requests. We may use personal information to respond to your inquiries and fulfill your requests. If you contact us, we may keep a record of your contact information and correspondence, and we may use any information you provide in your message to respond to your inquiry.


Business purposes. We may use personal information for our business purposes, such as audits, internal communication regarding candidates and clients, determining the effectiveness of our promotional activities, administering our products and services, maintaining and securing our infrastructure, and for procurement and financial transactions.


Informational communications. lucemio LLC may from time to time send informational emails, articles, white papers, proposals, engagement letters, and other information regarding the Services. Occasionally, and with your consent, we may use your personal information in direct marketing materials. We also may use personal information such as email postal addresses to conduct surveys.


Administrative information. We may from time to time use personal information to send you important information regarding the Online Systems, changes to our terms, conditions, and policies and/or other administrative information. We may also contact you from time to time to verify that the personal information we have collected about you is accurate and current.


Other activities. In addition, we may use and disclose personal information in other ways to perform our Services, as described below:


Additional activities for RPO and Recruitment Services. In the course of our RPO and Recruitment Services, we use personal information that we have collected concerning candidates to identify professional opportunities that we think may be of interest. We may contact potential candidates from time to time regarding such opportunities. We also may contact individuals from time to time to solicit names of, or other personal information regarding, potential candidates in connection with a search that we are conducting and for purposes of market intelligence.


We also use personal information to confirm references and conduct education and background checks, as appropriate. We may further use personal information that we collect for purposes of aggregating and disclosing diversity statistics and other statistical information regarding our candidates and placement activities.


Additional activities for Consulting Services. In the course of our Consulting Services, we may use personal information collected about you through our assessments to render Services to our clients.


Analytics. We may retain and use information about you, which may include, for example, your personal information, for research, publication, development, benchmarking and norms, validation, longitudinal studies, trend analysis and to improve and enhance our Services or develop and market new services. For these purposes we may also use your name and other personal identifiers to associate and combine information about you that is collected from one Service with information about you collected through other Services. Any published end product will refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you.


Key-coded data. We may key-code your personal information, or use a pseudonym, meaning that such information is stripped of all information that may identify you (direct identifiers) and replaced by a key-code to minimize unwanted or unintended identification. Such key-coded or pseudonym information can be de-coded by the use of the key, or by an authorized agent privy to your information, so that it identifies you again. We may use such information for the purposes described in the paragraph above entitled “Analytics,” as well as through the normal course of rendering our Services, and as permitted by applicable law. Any published end product will refer only to larger aggregations of individuals and will not identify you personally or include any results attributable to you.


De-identified data. Additionally, we may aggregate (anonymize) or de-identify personal information in such a manner that the end-product does not personally identify you or any other individual, for example, to generate norms by industry, geography, level, etc., enable us to conduct ongoing validation studies, compile reports, and publish journal articles to further the knowledge base of organizational and leadership science. Such aggregate or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.


DISCLOSURE TO CLIENTS, AFFILIATES, SERVICE PROVIDERS AND OTHERS.
Disclosure to clients.
In the course of our Services, we may disclose your personal information to clients who have engaged our services:


In the course of our Consulting Services, lucemio LLC discloses assessment and other information to the employer/client that has engaged lucemio LLC and to designated client personnel. Assessment and other personal information collected by our consultants or provided by our client may be maintained in a lucemio LLC database, to which our client, and certain personnel designated by our client, will have access both during and after the conclusion of our assignment. If you take assessments through our Consulting Services, we will not use your assessment reports in the performance of our RPO and Recruitment Services without your consent.


In the course of our RPO and Recruitment Services, we may provide personal information regarding candidates, including the results of assessments such a questionnaires and results of screenings and other related data, to prospective employers that have engaged lucemio LLC to fulfill search requests, or to reference sources.


Disclosure to affiliates. We may jointly use personal information with our affiliates. lucemio LLC is responsible for managing such jointly-used personal information. From time to time we also may disclose personal information to our network of independent recruiting consultants who provide Services on behalf of lucemio LLC for the purposes stated above.


Disclosure to service providers. lucemio LLC works with third parties who provide services that may include, but are not necessarily limited to, assessment services, including assessment validation services; website hosting and IT consulting services; data analysis; resume verification; background checking; payroll services; public relations services; attorneys, accountants, and other administrative and back-up and security services. As part of providing those services, such third parties will be provided with access to personal information. In addition, our software development partners may use personal information for purposes of modifying, improving, refining and validating their technology and research and development.


Business transfers. lucemio LLC reserves the right to disclose or transfer any and all personal information that we collect from visitors, or that we otherwise collect in connection with our Services, to a third party in connection with a strategic alliance with such third party, or in the event of a sale of our company or one of our affiliates, or a merger or consolidation involving our company or one of our affiliates, or a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.


Other disclosures. lucemio LLC may also use or disclose personal information in order to: (i) comply with applicable laws; (ii) respond to inquiries or requests from public or government authorities, including those outside of your country of residence; (iii) comply with valid legal process; (iv) protect the rights, privacy, safety or property of lucemio LLC, users of the Online Systems or the public; (v) permit us to pursue available remedies or limit the damages that we may sustain; (vi) enforce our Terms of Service; or (vii) respond to an emergency. We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, including the manner in which they use personal information received either from lucemio LLC or from other independent sources.


OTHER INFORMATION WE COLLECT.
lucemio LLC collects other information that does not reveal your specific identity (“Other Information”), such as:

  • Information collected through cookies, pixel tags and other technologies;
  • App usage data;
  • Demographic information and other information provided by you; and
  • Aggregated information.

Since Other Information does not reveal your specific identity, we may use it for any purpose. If we combine any Other Information with personal information (such as combining your name with your location), we will treat the combined information as personal information as long as it is combined. We and our third-party service providers may collect Other Information in a variety of ways, including:


Using cookies. We use “cookies” — that is, small text files placed on a visitor’s computer hard drive — and other technologies to help us determine information such as the type of content to which a visitor to the Site links, and the length of time each visitor spends at any particular area of the Site. lucemio LLC cookies are only read by lucemio PPS’s third-party servers and are unlikely to be able to execute any code or virus. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Online Systems, as well as for tracking purposes. We also gather statistical information about the usage of the Online Systems in order to continually improve the design and functionality, understand how the Online Systems are used and to assist us with resolving questions regarding the Online Systems.


You can configure your browser settings to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Online Systems. For example, we may not be able to recognize your computer and you may need to log in every time you visit the applicable Online Systems. You also may not receive advertising or other offers from us that are relevant to your interests and needs.


Using pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, measure the success of our communications and compile statistics about Site usage and response rates. Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies. We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Online Systems. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs, how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Online Systems.


Tracking data. lucemio LLC monitors visitor traffic patterns throughout the Site by logging “Tracking Data,” which is collected automatically from each Site visitor. Tracking Data may include your “IP Address” which is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP), as well as your browser type and operating system, the referring website, which pages of the Site were visited, the order in which they were visited and which hyperlinks were “clicked.”


lucemio LLC may use Tracking Data in aggregate form to perform statistical analyses of the collective characteristics and behavior of our visitors, and by measuring demographics and interests regarding specific areas of the Site.


Physical location. We may collect the physical location of your device by, for example, using satellite, cellphone tower or WiFi signals. We may use your device’s physical location to provide you with location-based services and content. In some instances, you may be able to allow or deny collection of your device’s location, but if you choose to deny such collection, we may not be able to provide you with the applicable location-based services and content.


Remarketing/Retargeting. “Remarketing or retargeting” is a remarketing and behavioral targeting service provided by but not limited to Google’s AdWords/DoubleClick and the Bing Yahoo Network (collectively herein referred to as our “third- party advertising companies”). A remarketing service connects the activity of the Site with the third-party advertising companies. Personal data collected includes Cookie and Usage Data in the United States. The information is statistical, and cannot be tracked back to individuals, protecting your privacy.


lucemio LLC uses this information to advertise to previous visitors who haven’t completed a task on our site (for example, making an inquiry through our contact form). This could be in the form of an advertisement on the third-party advertising companies search results pages, or a site in the third-party advertising companies’ Display Networks. Third-party vendors, including our third-party advertising companies, use cookies to serve ads based on a person’s past visits to lucemio LLC’s website and third-party owned landing webpages to provide better targeted advertising in the future. Any data collected will be used in accordance with our own privacy policy, as well as our third-party advertising companies’ respective privacy policies.


You can opt out of Google's use of cookies by visiting Google's Ads Settings, or Bing’s Ads Settings, or Yahoo’s Ads Settings. You may also opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.


From you. Information such as your preferred means of communication is collected when you voluntarily provide this information. Unless combined with personal information, this information does not personally identify you or any other user of the Online Systems.


By aggregating information. Aggregated personal information does not personally identify you or any other user of the Online Systems. For example, we may aggregate information to calculate the geographic distribution of participants in our Services.


ADDITIONAL GUIDELINES.
lucemio LLC may from time to time sponsor special features or promotions on the Online Systems and additional privacy information may be posted. That privacy information, to the extent it conflicts with this Privacy Policy, will govern that particular feature or promotion.


CHOICE AND ACCESS.
Your provision of personal information to us is voluntary, although if you do not provide certain personal information you may not be able to participate in our RPO and Recruitment Services and/or Consulting Services.


You may contact us at support@lucemio.com if you wish to receive certain information as to whether or not personal information relating to you is held by us and to obtain a copy of such information. If you would like to: (i) ask questions about how we handle personal information; (ii) review, correct or update your personal information; or (iii) request that your personal information be removed from lucemio LLC’s database, please contact us at support@lucemio.com. Please note that we are only able to provide you with a non-confidential summary of our final assessment report, since such report contains confidential client information that we are not allowed to disclose. You may request to be removed from lucemio LLC’s database by putting “Remove User” in the subject line of the email, and including your full name, your lucemio LLC issued identification number, and telephone number in the body of the email message.


We will aim to comply with your request as soon as reasonably practical, and may need to contact you in order to be sure that we are deleting the appropriate information. Please note that we cannot be responsible for removing your information from our database if that information is part of a Consulting Services assignment for your company. In that case, your request may need to be directed to your company’s management. We will, however, forward your request to the appropriate person at your company.


We also may need to retain certain information about you, such as your email address, in order to honor opt-out or similar requests. Please keep in mind that this residual information will remain within lucemio LLC databases, access logs and other records, which may or may not contain personal information about you. The residual information will not be used for commercial purposes. However, lucemio LLC reserves the right, from time to time, to recontact former users of its Services.


LOCATION OF PERSONAL INFORMATION COLLECTED AND MAINTAINED.
Your personal information may be collected, used, processed, disclosed and transferred to and within the United States and other countries where we have facilities or in which we engage service providers. By using our Services or Online Systems, you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than in your country.


SECURITY.
lucemio LLC has reasonable organizational, technical and administrative measures in place to protect against the loss, misuse and alteration of personal information about users of the Online Systems which is under our control. Unfortunately, however, no security system, or system of transmitting personal information over the Internet can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Questions” section below.


RETENTION PERIOD.
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.


LINKS TO OTHER WEBSITES.
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of our Vendors or of any other third parties. On the Online Systems, you may have the opportunity to follow a link from or to other websites maintained by lucemio LLC affiliates, Vendors, or other third parties. The inclusion of a link on our Online Systems does not imply our endorsement of the linked site. Because these other websites may not be hosted or controlled by lucemio LLC, this Privacy Policy does not address the privacy practices of those websites. We encourage you to review the privacy policies of each of those websites.


Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.


UPDATES TO THIS PRIVACY POLICY.

lucemio LLC reviews its privacy practices from time to time, and those practices are subject to change. We ask that you bookmark and periodically review this page to ensure continuing familiarity with the most current version of this Privacy Policy. You can determine when this Privacy Policy was last revised by checking the “Revised Date” legend at the bottom of the Privacy Policy. Any changes to the Privacy Policy will become effective upon posting of the revised Privacy Policy on the Internet, accessible through the Site. Use of the Online Systems following such changes constitutes your acceptance of the revised Privacy Policy then in effect.


USE OF ONLINE SYSTEMS BY MINORS.
The Online Systems are not directed to individuals under the age of fourteen (14), and we request that these individuals do not provide personal information through the Online Systems.


SUMMARIES OF PRIVACY POLICY.
This Privacy Policy is the sole authorized statement of lucemio LLC’s practices with respect to the online collection of personal information through the Online Systems and the usage of such personal information. Any summaries of this Privacy Policy generated by third party software or otherwise shall have no legal effect, are in no way binding upon lucemio LLC, shall not be relied upon in substitute for this Privacy Policy, and neither supersede nor modify this Privacy Policy.


QUESTIONS.
Questions regarding this Privacy Policy should be directed to lucemio LLC at support@lucemio.com or, if by postal mail, at lucemio LLC; 176 Amity Road, No. 154; Woodbridge, CT 06525, RE: Privacy Policy.