Privacy Notice

The Forem websites and any associated services, including (without limitation) all websites, mobile applications, live services (including coaching), and other interactive properties through which such services are delivered (collectively, the “Service”) are owned, operated and distributed by Foremy, LLC, a New York limited Liability Company (referred to in this Privacy Notice as “The Forem,” “we,” and through similar words such as “us,” “our,” etc.). This Privacy Notice outlines the Personal Information that The Forem may collect, how The Forem uses and safeguards that information, and with whom we may share it.

The Forem encourages our clients, visitors, business associates, and other interested parties to read this Privacy Notice, which applies to all users, including users who are simply viewing content available via the Service, companies seeking to engage The Forem for their employees (“Companies”), and professionals/employees who have provided information to the Service to for career coaching or other services (“Clients”).

By using our Service or submitting Personal Information to The Forem by any other means, you acknowledge that you understand and agree to be bound by this Privacy Notice, and agree that The Forem may collect, process, transfer, use and disclose your Personal Information as described in this Notice. Further, by accessing any part of the Service, you are agreeing to THE TERMS AND CONDITIONS OF OUR TERMS OF SERVICE (the “TERMS OF SERVICE”). If you do not agree to any of these terms, you should not use the Service.

What Personal Information do we collect about you?

Personal Information (also commonly known as Personally Identifiable Information (PII) or Personal Data) is information that can be used to identify you, or any other individual to whom the information may relate. We do not collect Personal Information unless you choose to provide it to us.

The Personal Information that we collect directly from Clients, includes the following:

• Name and contact information (e.g. home and/or business address; home, business, and/or cell phone number; personal and/or business email; fax, etc.);
• Work and education history;
• Areas of expertise and competencies;
• Information contained on your resume;
• Other information as may be deemed relevant to the Service.

The Personal Information that we may collect from Companies includes the following:

• Name and contact information of Company representatives;
• Billing information.

Please note that you should not submit to the Forem any sensitive data relating to your (i) racial or ethnic origin (ii) political beliefs (iii) philosophical or religious beliefs (iv) membership of a trade union or political party (v) physical or mental health or genetic makeup (vi) addictions, sexual life (vii) the commission of criminal offences or proceedings and associated penalties or fines, or (viii) any Social Security Number or national identification number, unless you have previously sent to us your written consent that we may process such Personal Information, if The Forem determines consent to be a requirement of applicable law. If you provide such sensitive data to The Forem, that data will be promptly deleted.

How do we use your Personal Information?

Subject to the terms of this Privacy Notice, The Forem uses your Personal Information in several ways:

• to administer the Service to you;
• to respond to your requests;
• to distribute communications relevant to your use of the Service, such as system updates or information about your use of the Service;
• as may be necessary to support the operation of the Service, such as for billing, account maintenance, and record-keeping purposes;
• to send to you The Forem opportunities, product announcements, and the like that we feel may be of interest to you (you may “opt out” of receiving these marketing materials);
• in other manners after notice is provided to you and/or your consent is obtained, if necessary.

The Forem does not sell, re-sell, or distribute for re-sale your Personal Information.  

How do we share your Personal Information with third parties?

We may provide Personal Information to The Forem employees, consultants, affiliates or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Service to you. In such circumstances, we require that these parties agree to protect the confidentiality of such information and to comply in all respects with this Privacy Notice.

We will not share your Personal Information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.  Further, the Forem will not disclose any Client Personal Information to Companies, their employers, or other third parties without the Client’s written consent. The Forem will not disclose the Client’s name as a reference without the Client’s consent.

In addition, we may release Personal Information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law, enforce any provision of the Terms of Service, protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user or protect the public welfare; (ii) to respond to a court order, subpoena, or search warrant; or (iii) in the event we are acquired by or merged with a third-party entity.

International Data Transfer

For individuals outside the United States (“US”), in particular Switzerland and the EU, please note that The Forem is a US based company. If you use the Service, all information, including Personal Information, will be transferred to The Forem (including third parties to which data is disclosed as described above) in the US. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your Personal Information than in your country, we will protect your information in accordance with requirements applicable to the law in your particular jurisdiction. By using the Service, you unambiguously consent to the transfer of your Personal Information and other information to the US and elsewhere for the purposes and uses described herein.

EU Data Privacy Rights and Basis for Processing

If you are located in the EU, the General Data Protection Regulation grants you certain rights under the law. In particular, the right to access, correct, delete, restrict processing of, and data portability of the Personal Information The Forem holds about you. The Forem will retain your data for the length of time you engage with The Forem’s services until you request deletion of such Personal Information.

Upon request, The Forem will grant individuals reasonable access to Personal Information that it holds about them. In addition, The Forem will take reasonable steps to permit individuals to correct, amend, delete, restrict processing of, and request portability of the Personal Information it holds about them. The Forem also relies upon each individual to assist in providing accurate updates of his or her Personal Information. In order to make a request regarding the Personal Information The Forem holds about an you, you should contact _______________.

If you have a comment, question, or complaint about how The Forem is handling your Personal Information, we hope that you contact us at _____________ in order to allow us to resolve the matter. In addition, individuals located in the EU may submit a complaint regarding the processing of their Personal Information to the EU data protection authorities (DPAs). The following link may assist you in finding the appropriate DPA: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

The Forem processes Personal Information pursuant to the lawful basis to complete performance of a contract for Services to which a Client or Company is a party as well as based on its legitimate interest to provide the Service. In limited circumstances, where required by law, the Forem processes Personal Information based on the consent of the individual. Where processing is based on consent, individuals have the right to withdraw that consent. You may inquire about the specific legal basis for processing your Personal Information by contacting The Forem at ___________.

Cookies, Device Data, and How it is Used

When you use our Service, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Service, and your network location. The Forem uses aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Service and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends.

In addition, we may use "cookies," clear gifs, and log file information that help us determine the type of content and pages to which you link, the length of time you spend at any particular area of the Service, and the portion of the Service you choose to use. A cookie is a small text file that is sent by a website to your computer or mobile device where it is stored by your web browser. A cookie contains limited information, usually a unique identifier and the name of the site. Your browser has options to accept, reject, or provide you with notice when a cookie is sent. Our cookies can only be read by The Forem; they do not execute any code or virus; and they do not contain any Personal Information. Cookies allow The Forem to serve you better and more efficiently, and to personalize your experience with the Service. We may use cookies for many purposes, including (without limitation) to save your password so you don’t have to re-enter it each time you visit the Service and to deliver content (which may include third party advertisements) specific to your interests.

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on the Service. We may permit these service providers to use cookies and other technologies to perform these services for The Forem. We do not share any Personal Information about our Clients with these third-party service providers, and these service providers do not collect such information on our behalf. Our third-party service providers are required to comply fully with this Privacy Notice.

Children’s Privacy

The Service is not available to children under 13 years of age. We do not knowingly collect Personal Information from children under 13 years of age.

Information Storage and Security

The Forem retains information as long as it is necessary and relevant to provide you with the Service. We also retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, collect any fees owed, and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies.

We employ industry-standard security measures designed to protect the security of all information submitted through the Service. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Service are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Service. In order to protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if any breach

of security is suspected.

California Privacy Rights

California Civil Code Section 1798.83 permits users of the Service who are California residents to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail with “California Privacy Rights” in the heading to ___________ or write us at

_______________

Changes to this Privacy Notice

The Forem reserves the right to modify this Privacy Notice from time to time in order that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Privacy Notice, The Forem will post the revised Notice on our website. This Privacy Notice was last modified as of June 2019.

How to Contact Us

Questions regarding this Privacy Notice should be directed _________ or contact us at:

_______________