Privacy Policy

Updated on October 14, 2024

This Privacy Policy explains how and why Cognity Life Inc. (United States) together with its affiliates, Cognity Life India Private Limited (India), doing business as “WisdomCircle”, collects, uses, and shares personal information when you interact with or use our Site or Service. It also includes any information Cognity Life Inc. (WisdomCircle) collects offline in connection with the Service, which we may combine with information from the Site and Service.

When we say “WisdomCircle”, we mean Cognity Life Inc., and any of its affiliates. When we say “Site”, we mean https://wisdomcircle.com/ and https://app.wisdomcircle.com/ and when we say “Service”, we mean the Site plus any websites, features, applications, widgets, or online services owned or controlled by Cognity Life Inc.

As part of the Service, Cognity Life Inc. provides a marketplace which results in platform collecting information pertaining to different parties to facilitate an interaction. Users of the Service may be WisGen or Recruiters (as each is defined in the Terms of Service). This Privacy Policy applies to Cognity Life Inc’s processing of personal information of Users where Cognity Life Inc. determines the purposes and means of processing. It does not apply to processing of information by Users themselves, who may be controllers of the personal information they access through the Service. This Privacy Policy is incorporated into and is to be read as part of the Terms of Service – https://wisdomcircle.com/terms-of-service/.

1. INFORMATION COLLECTION

a. Information You Provide to Us

When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the WisdomCircle platform, or information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate this with information about other users. This helps us improve our Services for you. You may also provide us with information about your contacts or friends if, for example, you’d like to share or refer them to a role posted on WisdomCircle. Depending upon our relationship with you, we may collect the following categories and types of personal information from and about you :
Categories of Personal Information We Collect Examples of Personal Information Collected Categories of Sources of Personal Information Business Purpose for Collection of Personal Information
Identifiers
Name, Date of Birth, Social Media Account Information, Profile Data, IP Address
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Contact / Account Profile Information
Email Address, Phone Number
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communicating with You, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Commercial Information
Transaction Data including services offered, considered, or purchased
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Internet or Other Network or Device Activities Including Information from Cookies
Unique device and app identifiers, browsing history or other usage data, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Approximate Geolocation Information
Your approximate location
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Sensory Information
Audio recordings if you call our customer service, video recordings of video introductions
Directly from You or Your use of the Service; Service Providers; Third Parties (such as affiliates)
Providing and Improving the Service, Identification, Communications, Marketing, Security, Legal, Compliance and Regulatory Obligations.
Platform Communications
Communication Information (e.g., your name, contact information, and the contents of any messages you send)
Directly from You, Your use of the Service, and Users with whom you communicate
Providing the Service, Security, Legal, Compliance and Regulatory Obligations. With your consent, the contents of any messages you send may be used to Develop and Improve the Service.
Professional Information
Previous place(s) of employment, position(s), work history, earnings, resume
Directly from You or Your use of the Service; Service Providers; Third Parties (such as other users)
Developing, Improving, and Providing the Service, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Other information that identifies or can be reasonably associated with you
User-generated content, (e.g., community posts, feedback, ratings and job postings), photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, hourly pay rates and earnings information.
Directly from You or Your use of the Service; Service Providers; Third Parties (such as affiliates, agents, and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.

b. Non-Identifying Information and De-Identified Information

  • Non-Identifying Information/Usernames: We also may collect other information that does not identify you directly, such as zip codes, demographic data, information about your use of the Service, and general project-related data (“Non-Identifying Information”). We may combine information collected from WisdomCircle users, whether they are registered or not (“WisdomCircle Users”). In some cases, we may render Personal Information (generally, email address) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. While the code does not identify you directly, it may be used by WisdomCircle’s partners to connect your activity and interests.
  • Combination of Personal and Non-Identifying Information: We may combine your Personal Information with Non-Identifying Information, but WisdomCircle will treat the combined information as Personal Information.
  • De-Identified Information: We may also de-identify or aggregate information and convert it into non-personal information so that it can no longer reasonably be used to identify you (“De-Identified Information”). We may use De-Identified Information for any of the purposes described in the “We Use Information We Collect” section below. We will maintain and use De-Identified Information in de-identified form and will not attempt to reidentify the information, except to confirm our de-identification processes or unless required by law.

c. Information Collected Automatically

WisdomCircle may collect non-personally identifiable information regarding your usage of the Services, including the pages and articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed, and other information that does not identify you. Like most online services, we also use cookies, log files, clear GIFs, tracking pixels, web beacons, and other technologies that may collect Personal Data.
Type of cookie Purpose

Essential (Necessary Cookies)

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality (Necessary Cookies)
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance (Analytics Cookies)
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not "directly" identify any individual visitor. However, it may render such visitors "indirectly identifiable". This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use a number of different tools including Google Analytics, Sentry, and FullStory for this purpose.
Targeted and advertising (Marketing Cookies)
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. Third party advertisers may also use other technologies in addition to cookies placed on the Site (such as JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content.
Social Media (Marketing Cookies)
These cookies are used when you share information using a social media sharing button or "like" button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site to help track conversions from ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—users who have already taken certain action on the Site.

How can I disable cookies?

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Services.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

Log Files:

Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

Clear GIFs Information (Web Beacons):

When you use the Services, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your WisdomCircle account is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make WisdomCircle better for our users.

Third Party Services:

 WisdomCircle may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You can also prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: [http://tools.google.com/dlpage/gaoptout?hl=en-GB.](http://tools.google.com/dlpage/gaoptout?hl=en-GB)

d. Analytics Providers, Ad Servers and Similar Third Parties

We receive information from third party vendors and/or other commercially and/or publicly available sources, such as:
  • Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, advertising and marketing partners in order to manage and measure our campaigns.
  • If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, LinkedIn), we receive certain information, such as your registration and profile information from that service. This information includes, for example, your email address, name and profile picture, but may vary and is controlled by that service or as authorized by you via your privacy settings at that service.
  • If any other third party submits a report and/or complaint about you or your activity on WisdomCircle we may receive information relating to the specific report and/or complaint, review and address it.
  • If you choose to refer or share links with your contacts, we will have the ability to view details of contacts.
  • If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties.
  • We also receive certain information about you, if you are referred to WisdomCircle by another user (for example, as part of our referral program), in such case we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with this Policy.
We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy.

e. Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. Currently, we do not respond to web browsers’ “do not track” signals that provide a method to opt out of the collection of information about users’ activities on the Services and on other websites. If we do so in the future, we will provide relevant information in this Privacy & Cookies Policy.

f. Special Category data

Special Category Personal Data refers to Personal Data that is more sensitive, and therefore requires more protection and additional reasons for its Processing. Examples of Special Category Personal Data include Personal Data revealing:

  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • genetic data
  • biometric data
  • data concerning health, among others

We will rarely collect Special Category Personal Data and will process it only if there is a lawful basis and condition for us to do so in accordance with Applicable Data Protection Law, such as, without limitation, your explicit consent, or if the information is made public by you or for employment, social security and social protection (if authorised by law).

g. Children

The Service is general audience and intended for users 18 and older. We do not intend to collect and process the Personal Data of anyone under the age of 18 (eighteen) years old (‘Child’/’Children’).

If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us at the earliest. Unless contacted by a parent or legal guardian, we have no way of knowing that Personal Data was submitted by a Child. As a parent/legal guardian you understand that the onus of controlling your Child’s Personal Data lies on you. If we become aware, after notification by a parent/legal guardian or by the Child itself, that Personal Data from the Child was submitted to us, we will take steps to remove that Personal Data from our servers. Should you believe that we have collected your Child’s Personal Data, you can notify us via details provided in the Contact us section.

We will not share a Child’s Personal Data with a third-party unless we have a compelling reason to do so, where a Child’s best interests are our primary consideration. For example, where it is in the best interests of a Child’s health, safety, and/or security for their Personal Data to be shared. In particular, we will follow the ICO’s guidance on sharing information to safeguard children.

2. USE OF INFORMATION

We Use Information We Collect:

  • To develop, provide, and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes.
  • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.
  • To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.
  • To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of WisdomCircle or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify WisdomCircle Users.
  • For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.
  • To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at Users’ request in anticipation of entering into a contract with them.
  • For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
    • Providing our Site and Service.
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
    • Measuring interest and engagement in our Services.
    • Short-term, transient use, such as contextual customization of ads.
    • Improving, upgrading or enhancing our Services.
    • Developing new products and services.
    • Ensuring internal quality control and safety.
    • Authenticating and verifying individual identities.
    • Debugging to identify and repair errors with our Services.
    • Auditing relating to interactions, transactions and other compliance activities.
    • Enforcing our agreements and policies.
    • Analyzing and improving our business.
    • Communications, including marketing and responding to your inquiries about our services.
    • Addressing information security needs and protecting our Users, WisdomCircle, and others.
    • Managing legal issues.
  • To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
  • To contact you with administrative communications and WisdomCircle newsletters, marketing or promotional materials (on behalf of WisdomCircle or third parties) and other information that may be of interest to you.
    • We use your personal information to send you direct marketing communications about our products, services or promotions from WisdomCircle that may be of interest to you or our related services. This may be via email, SMS, WhatsApp message, telephone or targeted online advertisements.
    • Our processing of your personal information for marketing purposes is based on our legitimate interest, on your consent, or on other legal basis permitted by applicable laws. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out link attached to each communication or by sending an email to our Grievance Officer.
    • We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
  • To carry out research, including market research, statistical research on site traffic, sales, and other commercial information to assist us in improving the services we provide to you and improving our Website.
  • For internal use such as governance, quality control, and monitoring purposes.
  • This Site is also protected by reCAPTCHA. Google Privacy Policy and Terms of Service apply with respect to data collected by reCAPTCHA. The use of Google reCAPTCHA is required in order to prevent fraud and misuse of the Site by use of automated machines. To learn more, please see Google’s privacy policy.

3. DATA RETENTION

Unless you request that we delete certain information, we will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, as well as ongoing fraud prevention, backup, and business continuity purposes.

4. INFORMATION SHARING AND DISCLOSURE

  • With other users and Site visitors. Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Site. This information includes but is not limited to photos you upload, your profile, and additional information you may choose to add to your profile. We also offer you the opportunity to participate and post content publicly in forums, blogs and on other similar features. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with them. When you publish your information and/or share your data with other WisdomCircle users, you do so at your own risk.
  • With users with whom you interact. We share personal information to help facilitate interactions between users. For example, if you are a WisGen we may share certain information about you with the Recruiter to ensure the services they receive from the WisGen will fit their needs; such sharing of information is limited in scope, and is intended to improve the services provided and your user experience.
  • With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, fraud detection and prevention services, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors and technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard personal information and only process it in accordance with our instructions.
  • When you submit a report or complaint about a user. We may share personal information about you when you submit reports or complaints about other users to allow them to protect their rights or as required by applicable laws.
  • For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Fiverr, our customers, or the public.
  • For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site, securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors, whose use of your Personal Data is governed by their respective privacy policies. These payment processors adhere to the standards set by PCI-DSS, as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
  • With social media partners. Our Site includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as Facebook and Google, to promote our services. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies.
  • With our corporate affiliates. We share personal information with WisdomCircle’s corporate affiliates for business and operational purposes, including for the purpose of operating our and our affiliates’ business, providing supplemental services to you, preventing fraud and maintaining safe and secure services, promoting our and our affiliates’ services and for other purposes listed herein; and
  • In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of WisdomCircle’s assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.
  • We do not sell your Personal Information for monetary consideration, and we do not share your Personal Information with third parties for those third parties’ marketing purposes.

5. YOUR CHOICES AND RIGHTS

You may have certain choices and rights associated with your personal information. Residents of certain locations may have the right to have an authorized agent submit requests on your behalf. You or your authorized agent may request that WisdomCircle honor these rights by contacting us as outlined in the “Contact Us” section below. Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights. Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded. You may withdraw your consent given for collection and use of your Personal Information by contacting us as outlined in the “Contact Us” section below. Once you withdraw your consent, you will lose access to all WisdomCircle Platforms. To remove your data or your account from our database, please contact us as outlined in the “Contact Us” section below.

Marketing Communications Preferences

You can ask us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:
  • by following the opt-out links on any marketing message sent to you; or
  • through your account settings
  • by contacting us at any time using the information in the “Contact Us” section below.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails.

Notice for UK-based and UK-resident data subjects:

We are dedicated to safeguarding and preserving your privacy when visiting our Website, using our Web application, communicating electronically with us, and/or otherwise dealing with us.

This section of the privacy notice (‘Notice’) applies to UK-based and UK-resident data subjects (as defined below) (‘you’, ‘your(s)’, ‘yourself’) in the United Kingdom, and provides an explanation about what happens to any Personal Data that you provide to us, or that we collect from you.

By continuing to use our Website (as defined below), web application, and/or other platforms, you agree to us, as well as our affiliates, collecting and Processing your Personal Data in accordance with this Notice. ‘Processing’, as defined in the UK General Data Protection Regulations (UK GDPR), means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

This Notice sets out our use of any and all Personal Data collected by us in relation to your use of our Website, [https://wisdomcircle.com](https://wisdomcircle.com/) (‘Website’), web application, and/or any other platforms, widgets, or online services owned or controlled by Cognity Life Inc. The Website is operated by Cognity Life Inc. (United States) together with its affiliates, Cognity Life India Private Limited (India), doing business as “WisdomCircle” (‘WisdomCircle’, ‘we’, ‘us’, ‘our’, ‘ourselves’).

For the purposes of Processing your Personal Data, we are the Data Controller (as defined under Article 4(7) of the EU General Data Protection Regulation 2016/679 (‘GDPR’) as well as the UK GDPR (the retained EU law version of the General Data Protection Regulation ((EU) 2016/679), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018). In other words, we are the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

Personal Data shall have the meaning given to it under Article 4(1) of the GDPR 2016/679, and the UK GDPR, and which is more particularly defined in this Notice below.

We may amend or update this section of the Notice from time to time and will publish revised versions on our Website. We reserve the right to alter and make changes to this section of the Notice at our sole discretion, and we therefore request all users to regularly refer to our Notice for updates and variations.

Who is the person responsible for the management of your Personal Data in the UK?

Cognity Life Inc. is responsible for the management of your Personal Data. We are a company incorporated in the state of Minnesota in the United States of America. However, as a business with its presence in the United Kingdom, and providing services to UK resident data subjects, we are registered with the Information Commissioner’s Office (ICO) under reference number: CSN0948851

The person responsible for data protection in the UK is Shilpi Bordoloi Mahindroo. For any queries relating to the management of your Personal Data please do not hesitate to send us an email at [shilpi.bordoloi@wisdomcircle.com](mailto:shilpi.bordoloi@wisdomcircle.com) or please contact us as outlined in the “Contact Us” section below

What are the Lawful bases for Processing your Personal Data?

The following are the lawful bases for us Processing your Personal Data:

  • Article 6.1 (a) of the GDPR 2016/679 and the UK GDPR- Consent
    In order to avail of our services, you consent to us obtaining and Processing your Personal Data. While dealing with you, we may issue terms and conditions (‘Terms of Service’) or execute a contract outlining the terms and conditions of our engagement with you. The Terms of Business/contract, along with this Notice, set out the purposes for which your Personal Data may be obtained and Processed by us. By accepting the Terms of Business or by using our Website, mobile application, and/or any other service offered by us, or by executing a contract with us and by continuing to deal with us, you confirm that you have consented to us collecting and Processing your Personal Data in accordance with our Terms and this Notice.

    By creating your profile on our portal, you consent to your Personal Data being used and Processed, manually or through the use of artificial intelligence, in order to match you with a suitable employer and/or to notify you of suitable opportunities that match your skill set and search criteria.

    By expressly opting in to receive our newsletters and promotional material, you consent to us using your email address for the said purposes, in which case the lawful basis for us using your Personal Data is your consent as outlined in Article 6.1 (a) of the GDPR 2016/679, and the UK GDPR.

    ‘Consent’ as defined under Article 4(11) of the UK GDPR, means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her. Therefore, where you opt-in for us to contact you or voluntarily request for our services, you consent to us using your Personal Data to fulfill the requests made by you.

  • Article 6.1 (b) of the GDPR 2016/679 and the UK GDPR- Contractual Necessity
    One of the grounds for obtaining and Processing your Personal Data is so that we can perform our services in line with the Terms of Business mutually agreed to by us. This includes the collection and use of your Personal Data in order for us to perform our services, such as to match you with a suitable employer and/or to notify you of suitable employment opportunities based on your skill set and search criteria.
  • Article 6.1 (c) of the GDPR 2016/679 and the UK GDPR- Compliance with Legal Obligations
    We may have to collect and Process Personal Data where such Processing is necessary for compliance with a legal obligation to which we, as the Data Controller, are subject. In order to comply with certain legislative and regulatory requirements relating to client due diligence, we may have to collect and Process your Personal Data. Consequently, we may process your Personal Data to carry out identity checks, DBS checks, and maintain records of client due diligence.

    We may employ third-party service providers for the purposes of carrying out client identity checks, or for Processing your Personal Data for the purposes of due diligence. However, we remain the Data Controllers.

  • Article 6.1 (f) of the GDPR 2016/679, and the UK GDPR- Legitimate Interests
    In circumstances where you are a client or an employee of, or independent contractor for WisdomCircle, we may have to process your Personal Data to promote and pursue legitimate interests of the public and/or our organisation, and/or yours as our client or employee/independent contractor.

    In terms of promotional material, if you unsubscribe from our mailing list or revoke your consent to receive our newsletters and promotional material, the corresponding Personal Data will be removed from our mailing list and will no longer be Processed for these purposes. Including your email address in our blocking list is effected in order to safeguard our legitimate interests under Article 6.1 (f) of the GDPR 2016/679, and the UK GDPR. Our legitimate interests lie in not sending you any e-mails in the future.

What are the Lawful Bases for Processing your Special Category Personal Data?

In addition to one of the lawful bases contained in Article 6 of the GDPR and the UK GDPR, the following are the lawful bases for us Processing your Special Category Personal Data:

  • Article 9.2 (a) of the GDPR 2016/679, and the UK GDPR- Explicit Consent
    In order to provide our services to you, we require your consent to process Personal Data about you that comes under ‘Special Category Personal Data’. This includes but is not limited to Personal Data relating to your medical and health conditions.

    ‘Health data’, as defined under Article 4(15) of the UK GDPR means Personal Data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.

  • Article 9.2 (c) of the GDPR 2016/679, and the UK GDPR- Vital Interests
    Processing is necessary to protect the vital interests of the Data Subject or of another natural person where the Data Subject is physically or legally incapable of giving consent. For example, where such Personal Data has to be shared for emergency medical care, and where you may be not physically or legally capable of giving consent.
    However, you can object to us Processing your Personal Data, on any of these bases at any time and, if you do so, we will stop Processing the Personal Data unless we can show compelling legitimate grounds which override your rights and interests such as, without limitation your security or health, or the legitimate interest of our organisation and/or the public, or that we need the Personal Data to establish, exercise or defend legal claims – see ‘Your rights in relation to your Personal Data’ below.

How do we store and transfer your Personal Data?

Storage of Personal Data

All Personal Data collected by WisdomCircle is stored in a secure manner compliant with the GDPR and the UK GDPR.

Your Personal Data may also be stored on servers that may not be located in the United Kingdom and/or the European Economic Area (the EEA). Some of our servers may be located in the United States of America. Consequently, when you use our Website, or mobile application to sign up with us, to purchase our services or opt in to receive promotional material, your Personal Data may be processed by servers located in the United States of America, with less strict privacy laws and the associated risk of your Personal Data being easily accessible in the United States of America. In order to learn how your Personal Data is collected and Processed in the United States of America, refer to the relevant provisions of paragraph 5 of this Notice.

A purchase by you of services using our Website and/or using any of the payment platforms on our Website shall constitute your consent to your Personal Data being processed in the United States of America.

Transfer of your Personal Data

An explanation of who we share your Personal Data with has been provided in paragraph 4 of this Notice.

In addition, we may disclose your Personal Data:

  • To enforce our policies, to comply with our legal obligations (such as if we are required to disclose your Personal Data under a court order, legal requirement, and/or regulatory requirement), or in the interests of security, public interest, or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority, including without limitation, customs authorities of a country. We may also disclose Personal Data in connection with actual or proposed litigation or to protect our property, security, people, and other rights or interests
  • To our employees, independent contractors, consultants, partners, and/or third parties who help deliver our services to you. Examples include without limitation, hosting our web servers, analysing data, providing marketing and administration assistance, and providing customer service. These companies will have access to your Personal Data as necessary to perform their functions, but they may not use that Personal Data for any other purpose. Our contracts with all third parties processing our clients’ Personal Data shall outline their obligations relating to data protection.

We may also transfer Personal Data that we collect from you to locations within and outside of the United Kingdom but within the European Economic Area for Processing and storing. Also, it may be processed by staff operating within the European Economic Area who work for us or for one of our affiliates.

Some of the third parties we may transfer your Personal Data to within the UK and/or within the EEA include:

  1. Our accountants for the purposes of book-keeping.
  2. Our service providers.
  3. Our social media partners.
  4. Our corporate affiliates.
  5. In the context of a corporate transaction, such as a merger, sale, transfer of WisdomCircle’s assets, acquisition, bankruptcy, or a similar event.

We will transfer your Personal Data to a third-party only if it is required by law, or it is necessary to do so in your best interests, or for the purposes of performing our services and conducting our business. We will ensure that third parties with whom we share your Personal Data are made aware of their obligations relating to confidentiality and data protection.

We may share aggregated anonymised data with third parties in order to monitor our services and to ensure consistent quality and safety relating to the services provided to clients.

By submitting your Personal Data, you agree to this transfer, storage, or Processing. We will take all reasonable steps to make sure that your Personal Data is treated securely and in agreement with this Notice.

Emails: Emails are sent/received by WisdomCircle and its team on devices that are password protected, and as much as possible in a TLS (Transport Layer Security) encrypted format.

Security of Personal Data: The transmission of Personal Data via the internet is not completely secure, and therefore we cannot guarantee the security of Personal Data sent to us electronically and transmission of such Personal Data is therefore entirely at your own risk.

Video recordings: You can add a video introduction to your resume. Video recordings shall be made at your sole discretion and shall be shared as part of your resume in order for us to provide our services, as well as for the purposes specified in this Notice.

Sharing Personal Data for marketing purposes: WisdomCircle reserves the right to describe in general terms the services provided to you, success stories relating to you (if any), and use examples in written or spoken professional presentations and papers, and for marketing purposes. However, we undertake that they will be strictly non-attributed to any individual or organisation. We will always seek your permission before attributing you in our publicity material such as client testimonials.

Sharing Personal Data in case of emergencies: We will generally share your information/Personal Data with persons nominated as your ‘Emergency Contact’ or, where an ‘Emergency Contact’ has not been nominated, with your next of kin only in cases of emergencies where it is in the legitimate interest of the public or in the legitimate interest of our organisation, or in your own legitimate interest, as the case may be for us to disclose the Personal Data or where your interests (health and safety) over-ride our obligation of confidentiality. For such circumstances it shall be deemed that you have consented to your information being shared with the recipient of the information.

Storing Data and Information: Your Personal Data and any other details that you provide to us will be stored securely and will not be shared with third parties, unless the recipient of the information is an employee, independent contractor, or consultant of ours, or is receiving the information in circumstances outlined in this Notice, such as emergencies, and/or in the Data Subject’s interests.

For how long do we store your Personal Data?

Our policy is that we retain your Personal Data for as long as necessary for the purposes set out in this Notice, or as is required by applicable law. All of the Personal Data is disposed of securely to ensure compliance with Applicable Data Protection Law.

Transfer of your Personal Data outside of the European Economic Area

Your Personal Data may be transferred and stored outside the European Economic Area (EEA) in the circumstances set out in this Notice. Where we are required to do so, we will ensure appropriate safeguards and protections are in place, including undertaking safeguards required to be implemented by the Information Commissioner’s Office, such as undertaking a transfer risk assessment, and executing data protection clauses in the form of the International Data Transfer Agreement (IDTA), an International Data Transfer Addendum to the EU Standard Contractual Clauses, or the UK Binding Corporate Rules (UK BCRs) as applicable.

Access to Personal Data

The GDPR, UK GDPR, and The Data Protection Act 1998 give you the right to access the Personal Data that we hold about you. We will provide the Personal Data that we hold on you free of charge as long as it has not been provided to you already. If the Personal Data is a copy of information already provided or is excessive, then an administration cost of £10 will be charged. Should you wish to receive details that we hold about you please contact us by emailing us at [insert email]. You will need to provide suitable evidence that you are the person that the Personal Data pertains to before we will release it. Personal Data will be provided to you within one month of receipt of your request.

Verifying your identity where you request access to your Personal Data:

Where you request access to your Personal Data, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your Personal Data and to reduce the risk of identity fraud, identity theft, or general unauthorised access to your Personal Data.

How we verify your identity:

Where we possess appropriate Personal Data about you on file, we will attempt to verify your identity using that Personal Data. If it is not possible to identify you from such information, or if we have insufficient Personal Data about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your Personal Data. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Erasure of your Personal Data

If you are no longer a client with us, then you have a right to erasure of your Personal Data. Once we have received your request for erasure, we will ensure all Personal Data we hold on you is erased within one month of the receipt of the request unless we are required to retain your Personal Data under a legal requirement.

Your rights in relation to your Personal Data

Subject to certain limitations on certain rights, you have the following rights in relation to your Personal Data, which you can exercise by sending us an email at [insert email address].

  • to request access to your Personal Data and information relating to our use and Processing of your Personal Data
  • to request the correction or deletion of your Personal Data
  • to request that we restrict our use of your Personal Data
  • to receive Personal Data which you have provided to us in a structured, commonly used and machine-readable format (for example, a CSV file) and the right to have that Personal Data transferred to another data controller (including a third-party data controller)
  • to object to the Processing of your Personal Data for certain purposes for further information, see the section below titled ‘Your right to object to the Processing of your Personal Data for certain purposes’), and
  • to withdraw your consent to our use of your Personal Data at any time where we rely on your consent to use or process that Personal Data. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and Processing of your Personal Data on the basis of your consent before the point in time when you withdraw your consent.
  • to prevent us using your Personal Data for direct marketing
  • to have (in certain circumstances) inaccurate Personal Data corrected, blocked, or destroyed
  • to access a copy of your Personal Data that is undergoing Processing (‘subject access rights’)
  • to object to automated decisions
  • data portability, which allows you to get and use your Personal Data for different purposes
  • a right to object to Processing that is likely to cause or is causing damage or distress.

If you want to (1) tell us to stop using your Personal Data or withdraw consent from us Processing your Personal Data for any of the purposes mentioned in this Notice (2) exercise your subject access rights (3) tell us about inaccurate Personal Data you think we hold on you or (4) object to a use you believe we are making of your Personal Data which is causing, or is likely to cause damage or distress, please contact at the email provided in the Contact us section.

In accordance with Article 77 of the GDPR, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work  of an alleged infringement of the GDPR.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/.

You are entitled to make a complaint at the Information Commissioner’s Office (ICO) https://ico.org.uk/make-a-complaint/

The ICO’s address is:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

For Individuals Located in the European Economic Area (EEA) or Switzerland:

You have a number of rights under applicable data protection laws in relation to your personal information. Under certain circumstances, you have the right to:

  • Have access to your personal information by submitting a request to us;
  • Have your personal information deleted;
  • Have your personal information corrected if it is wrong;
  • Have the processing of your personal information restricted;
  • Object to further processing of your personal information, including to object to marketing from us;
  • Make a data portability request;
  • Withdraw any consent you have provided to us;
  • Restrict any automatic processing of your personal information; and
  • Complain to the appropriate Supervisory Authority.

To exercise any of these rights, please contact us as outlined in the “Contact Us” section below.

Notice for California Residents

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes. California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and processing of their personal information. Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:
  1. The categories of personal information we have collected about you.
  2. The categories of sources for the personal information we have collected about you.
  3. The specific pieces of personal information we have collected about you.
  4. Our business or commercial purpose for collecting or “selling” your personal information as defined by the CCPA.
  5. The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.
Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt-out of the “sale” or “sharing” of their personal information as defined by the CCPA by contacting us using the information in the “Contact Us” section below. Please note that we do not knowingly “sell” the personal information of any individuals under the age of 18. Where we are “sharing” your personal information with third parties for the purposes of cross-context behavioral advertising or profiling, you may opt-out of such sharing at any time by submitting a request as directed on the homepage of our website or by contacting us using the information in the “Contact Us” section below. Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted under the CCPA. Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our service providers to delete your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA. Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you. Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

Notice for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, email address, phone number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the information in the “Contact Us” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Notice for Residents of Certain Other States

The laws of your state of residence (“Applicable State Law”) may provide you with certain rights, including the following: Your Right to Confirm and Access: You have the right to confirm whether we are processing personal information about you and access the personal information we process about you. Your Right to Portability: You have to right to obtain a copy of the personal information we maintain and process about you in a portable and, to the extent technically feasible, readily-usable format. Your Right to Delete: You have the right to request that we delete the personal information we maintain or process about you. Your Right to Correct: You have the right to request that we correct inaccuracies in the personal information we maintain or process about you, taking into consideration the nature and purpose of such processing. Your Rights to Opt-Out: You have the right to opt-out of certain types of processing of personal information, including:
  • Opt-Out of the “sale” of personal information as defined by Applicable State Law;
  • Opt-Out of targeted advertising by us;
  • Opt-Out of automated profiling for the purposes of making decisions that produce legal or similarly significant effects.
Please note, as explained above, we do not “sell” personal information as that word is traditionally defined. However, we do share personal information with third parties to provide you with personalized advertising from us and to better understand how you interact with our Services. Through the use of cookies, we may also make available certain personal information to third parties for targeted advertising. You may opt-out from any of these disclosures under Applicable State Law by contacting us using the information in the “Contact Us” section below.

Appeals Process & Other Concerns

Certain information may be exempt from the rights described above under applicable law. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.

6. SECURITY

WisdomCircle takes reasonable steps to help protect and secure the information it collects and stores about WisdomCircle Users. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

7. CROSS-BORDER DATA TRANSFERS

Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States and Israel, whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, there are also transfers of personal information from the European Economic Area (“EEA”) to countries outside of the EEA not deemed to provide an adequate level of data protection from a European data protection perspective, such as the United States. With regard to data transfers to such recipients outside of the EEA we provide appropriate safeguards, in particular, by way of entering into European Union (EU) standard contractual clauses as amended from time to time, and/or equivalent data transfer safeguards. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

8. LINKS TO OTHER SITES

Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

9. CHANGES TO THIS POLICY

This Privacy Policy is effective as of the date stated at the top of this page. WisdomCircle may update this Privacy Policy at any time and any changes will be effective upon posting. We reserve the right to modify, alter, amend, change or update this Privacy Policy at any time without (i) any prior notice; (ii) assigning any reason, or (iii) assuming any liability whatsoever. We have no obligation to individually intimate each user or visitor about any changes or amendments made to this Privacy Policy. We recommend that you check the Policy periodically for any updates or changes. We make no representations that materials, information, or content available on or through this Website are appropriate or available for use in other locations, and access to them from territories where, accessing such materials, information, or content is illegal or prohibited. Those who choose to access this Website from other locations do so on their own volition and are responsible for compliance with applicable local laws.

10. SOCIAL MEDIA

Please remember that when you share information publicly on the Website or on social media platforms, for example, a comment on a blog post or within social media groups, it may be indexable by search engines, including Google, which may mean that the information is made public. We, therefore, encourage you not to publish or share your Personal Data on social media platforms.

When you participate in conversations on social media, your Personal Data may be visible to members of the concerned social media group and to the public in general. Please note that you participate in social media related activities at your sole discretion, and we shall not be liable for the access and use of your Personal Data by third parties via social media. This includes circumstances where third parties contact you or initiate a conversation with you, on social media or otherwise, as a result of your Personal Data being made available to them via our social media groups or any activity you participate in through our social media platforms or by connecting with us on social media.

Also please note you may be tracked by LinkedIn, Instagram (Meta), WhatsApp, or YouTube cookies if you access our profile via these social media platforms. The links to their respective privacy policies have been provided below:

  1. Instagram- privacy policy
  2. Facebook (Meta)- privacy policy
  3. WhatsApp- privacy policy
  4. YouTube and Google- privacy policy
  5. LinkedIn- privacy policy

11. CONTACT US

If you have any concerns or questions about this Privacy Policy, any complaint, or information on potential breach or violation of this Privacy Policy, this can be taken up with the designated Grievance Officer mentioned below.

Grievance Officer:

Joanna Sundharam: joanna.sundharam@wisdomcircle.com

We request you to provide the following information in your complaint:

  • clear statement explaining your request or concern and how that relates to your or another person’s Personal Information;
  • your email address and telephone number; and
  • an undertaking by you stating that your request or complaint is being made on a good faith basis and all material facts disclosed by you is true to the best of your knowledge.

We shall make our best efforts to resolve complaints within one (1) month from the date of receipt.

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