Last updated October 1, 2022

Lever Talent, Inc. (“Lever Talent,” “we,” “us,” or “our”) is a talent strategy agency that provides coaching and consulting services, PI software sales and account management, and leadership training to our clients (“Clients”) and their employees (collectively, the “Services”) and the website located at levertalent.com (the “Site”) subject to Lever Talent’s privacy practices outlined in this Privacy Policy.

Please read this Privacy Policy closely. By visiting the Site and/or using the Services, when providing your personal information to Lever Talent, you agree that Lever Talent may collect, use, and disclose your personal information as described in this Privacy Policy. We routinely update this Privacy Policy as our services, products, and offerings change, so check back regularly for updates or changes.

We collect Personal Information and Aggregate Information. We use the term "Personal Information" to refer to information that can be used to identify an individual, and the term "Aggregate Information" to refer to information that does not allow for such identification (e.g., aggregated demographic information, areas visited on the Site, duration of page views, what browser was used to access the Site, and similar information).  The collection, use and storage of personal information is described in this Privacy Policy.  The collection of aggregate information is also described in this policy. Because aggregate information does not personally identify who it pertains to, such information may be used and/or shared by us for any purpose.

We may remove identifiers from Personal Information to make it anonymous. After Personal Information has been anonymized, we will treat and use such information as Aggregate Information.

The Services and/or the Site may make available links to other websites. Lever Talent is not responsible for the content, privacy policies, and/or practices of any linked websites. Before providing personal information to third parties, such parties' privacy policies should be reviewed by you, as they will govern how information disclosed directly to such third party may be used.

The Services are intended for use by adults only. They are not directed to children (as defined by applicable federal or state law or regulation), and Lever Talent will not knowingly collect or use information from children, and we request that such individuals, or any third party acting on their behalf, not use or access the Services or provide any personal information through the Services. If at any time we learn that we have collected or received personal information from a child, we will promptly close the account and follow our process for retention of personal information.

We follow the same privacy policies and practices for our former Clients as are described in this Privacy Policy.

 

OUR SERVICES

If you are an employee of one of our Clients (an “End User”), Lever Talent processes any required personal information for registering you as that Client’s authorized user on behalf of our Client. Our processing of End Users’ personal information is governed by our agreement with that Client. You acknowledge and agree that a Client may require you to share personal information as a condition to you using the Services. This Privacy Policy also describes in further detail how we process personal information on behalf of our Clients.

 

TYPES OF INFORMATION LEVER TALENT COLLECTS

When you or your End Users engage with our services, we may collect:

• Profile information, such as name of employer, email address, first name and last name, your title, and your LinkedIn profile link.
• Metadata associated with information or other data that are uploaded (e.g., geotags). 
• Cookies, web beacons, tracking pixels and other technologies. Lever Talent may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or device until you delete them) to provide you with a more personal and interactive experience on our website or when using our services. We may also use cookies or other tracking technologies provided by third-party analytics companies, such as Google Analytics, to collect information such as how often users visit the website, what pages they visit and for how long, what other sites they used prior to coming to the website, and other engagement data (including how you interact with our emails). Lever Talent uses this information to evaluate and improve our services. 
• Information collected by our servers, such as the referring/exit pages, your browser type, domain name, date/time stamp for your visit and your Internet Protocol (IP) address (a number that is automatically assigned to your computer or device when you use the internet). Lever Talent uses this information to analyze trends, administer our services, monitor for fraudulent activities using fraud management tools, and better tailor the services to our Clients’ needs.
• Mobile service data, such as your general geographic location, how you use the application(s), and information about the type of device you use. This information is generally used to help deliver the most relevant information to you. In addition, in the event our application crashes your mobile device, Lever Talent will receive information about your mobile device model, software version and device carrier, to identify and fix bugs and otherwise improve the performance of our applications. This information is sent to Lever Talent as aggregated information. The aggregated information is not used to identify an individual.
• Location information, if you have enabled location services on your phone and that information is associated with any photos or other data that you share with Lever Talent, or that is otherwise relevant for features or functionality of the Services that you are using, you agree to our collection and use of the associated location information. If you do not want Lever Talent to collect this information, you may adjust the location services settings on your device. In some cases, if you decline to provide information to Lever Talent, we will not be able to provide certain services, capabilities, or features to you that require that information.

 

HOW LEVER TALENT USES YOUR INFORMATION

We use personal information of End Users for:

• Services delivery: 
  • Facilitate the creation of, and secure and maintain your profile;
  • Identify you as a legitimate user in Lever Talent’s system;
  • Provide improved administration of the Services;
  • Provide the Services;
  • Improve the quality of experience when you interact with the Services;
  • Send you administrative email notifications, such as security or support and maintenance advisories; and 
  • With respect to End User information, for any authorized purpose at the direction of the Client in connection with the provision of the Services by us.
• Creation of anonymous data: To continuously improve Lever Talent’s technology, we may anonymize your personal information, including the photos you share with Lever Talent, and use that data to train our algorithms and data models, test and improve how existing products and services look and function, develop enhancements and new capabilities and features, and for other business purposes. 
• Compliance, fraud prevention and safety: We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern our services; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including without limitation cyber-attacks, cyber-bullying or stalking, and identity theft.

 

HOW LEVER TALENT SHARES YOUR INFORMATION

We may share personal information:

• At the direction of our Clients, if you are an End User of one of our Clients. 
• With service providers that perform services on our behalf or help us operate our services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These service providers may use your information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose. 
• With The Predictive Index, in connection with PI software sales and account management and support and the delivery of Services.
• At your direction, we may share your photographs and some of your profile information with other End Users.
• In the context of a business transfer, we may sell, transfer or otherwise share some or all of our business or assets, including information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.  
• To comply with the law: we may be required to disclose your information to comply with applicable local, state, federal, or international laws or regulations, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities or court orders, or for the compliance, fraud prevention, and safety reasons described above. 

 

SAFEGUARDS

We implement administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. 

End Users are responsible for establishing unique credentials to access their profiles. All users are responsible for any actions on their profiles that result from access to the accounts with users’ valid credentials, except where the user, or the Client, notified Lever Talent at support@constructionconnectivity.com that the credentials have been compromised.

 

RETENTION

We retain personal information in accordance with all applicable laws and for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

PRIVACY CHOICES

• Cookies
  • As described in the “Types of Information Lever Talent Collects” section above, when you visit the Lever Talent website, we may place cookies on your device. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our website may not work properly. Similarly, your browser settings may allow you to clear your browser web storage. For more information on your choices, please see the Online Tracking Opt-Out Guide
  • Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communications. There is currently no standard that governs what, if anything, websites should do when they receive these signals. Lever Talent currently does not take action in response to these signals. If and when a standard is established, Lever Talent may revise its policy on responding to these signals.
• Opt-out of push notifications
  • When you use a Lever Talent application, you may opt out of push notifications we may send you by changing the settings on your mobile device.
  • Some Lever Talent-powered apps may also offer this choice to End Users, depending on how the business configured their product or service.

 

• Device permissions
  • When you use a Lever Talent application, you may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, in the settings menu on your mobile device.

• Opt-out of email or SMS communications
• We may send email or SMS communications in connection with the Services, including without limitation for alerts, reports, or other information based on the preferences or settings you have selected.
• If you have signed-up to receive our email marketing communications, you can unsubscribe at any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under "Contact Us" below.
• If you provide your mobile phone number to us, Lever Talent may send you notifications by SMS, such as to verify your identity or in connection with providing the Services, including without limitation alerts or reports or similar. You may opt out of SMS communications by removing your mobile phone number from your application profile.

• Opt-out of location tracking
• End Users using our application(s) can control our collection of location data using their mobile device’s settings. Please note, however, that if you withdraw consent to Lever Talent’s collection of location information, you may no longer be able to use some features of our services.

 

NOTICE TO CALIFORNIA USERS

We are providing this supplemental privacy notice to Clients and their End Users in California, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). End Users should submit their requests to the relevant Client and Lever Talent will cooperate with the Client pursuant to the terms of our agreement.

We do not sell our End Users’ personal information in the traditional sense. As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt Out Guide.

The CCPA grants California residents the following rights.

• Information: You can request information about how we used and shared your personal information through the Lever Talent Services during the past 12 months.
• Access: You can request a copy of the personal information that Lever Talent maintains about you.
• Deletion: You can ask to delete the personal information that Lever Talent maintains about you.
• Opt-out of sale of your personal information: We do not sell personal information. We offer instructions on how to limit online tracking in the Online Tracking Opt Out Guide.

Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.

You are entitled to exercise the rights described above free from discrimination.

We describe the sources through which we collect personal information and the types of personal information collected in the “Types of Information Lever Talent Collects” section above. We describe the purposes for which we use and share this information in the “How Lever Talent Uses Your Information” section above and the “How Lever Talent Shares Your Information” section above.

Here is how you can submit requests:

• To request access to or deletion of personal information collected via your use of our website or applications, please email us at privacy@constructionconnectivity.com.

• To learn how to limit tracking, please see the Online Tracking Opt Out Guide.

• To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of an End User.
• Authorized agents: California residents can empower an “authorized agent” to submit requests on their behalf.

 

PRIVACY POLICY UPDATES

This Privacy Policy is subject to occasional revision. Lever Talent will notify you of any material changes in its collection, use, or disclosure of your personal information by posting a notice in the Services. Any material changes to this Privacy Policy will be effective thirty (30) calendar days following notice of the changes. These changes will be effective immediately for new users of the Services. If you object to any such changes, you must notify Lever Talent prior to the effective date of such changes that you wish to deactivate your profile. Continued use of the Services following notice of any such changes will indicate your acknowledgement and agreement to such changes.

 

CONTACT LEVER TALENT

If you have any questions or complaints about this Privacy Policy or Lever Talent’s data collection or processing practices, or if you want to report any security violations to Lever Talent, please contact Lever Talent at:

Email: contact@levertalent.com

Phone: (781) 680-5123

Mail: Lever Talent, Inc., 10 Brookfield Road, Westwood, MA 02090

Because Internet email transmissions may not be secure, we request that you do not send us or request sensitive information such as account numbers, passwords and payment information via any public email system.

We generally will acknowledge emails within one (1) business day, but we will not take actions based on your email request until we actually receive your email message and have a reasonable period of time to act.

We will NEVER ask you for any private information (such as account numbers, passwords, social security numbers, etc.) for any of our services through an unsolicited email. If you receive any such request, DO NOT respond to it. Please notify us immediately at (781) 680-5123 or contact@levertalent.com.

© 2022 Lever Talent, Inc.

 

ONLINE TRACKING OPT OUT GUIDE

Like many companies online, we may use services provided by Google, Facebook, Twitter and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

• Blocking cookies in your browser: Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit: www.allaboutcookies.org.
• Blocking advertising ID use in your mobile settings: Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers: You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Platform opt-outs: The following advertisers offer opt-out features that let you opt-out of use of your information for interest-based advertising:
• Google: adssettings.google.com
• Facebook: www.facebook.com/about/ads
• Twitter: twitter.com/settings/personalization
• Advertising industry opt-out tools: You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
• Digital Advertising Alliance for Websites: optout.aboutads.info
• Digital Advertising Alliance for Mobile Apps: www.youradchoices.com/appchoices
• Network Advertising Initiative: optout.networkadvertising.org/?c=1

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, so you will need to opt out on every browser and device that you use.