Privacy & Cookies Policy

The Judge Group, Inc. and its subsidiaries, including Judge Technical Services, Inc., Berkeley Associates Corp., Judge Consulting, Inc. and Slayton Search Partners (collectively “Judge” or “we”) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Judge has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Judge commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

About Judge

Judge is a privately-owned, leading professional services firm. What does that mean? It means we provide technology, talent and learning solutions to businesses around the globe, and we’re great at it. Our expertise is positioned at the crossroads of people and technology—two of the most important aspects of successful business today.

When this Policy Applies

This Policy applies to our collection, use and disclosure of your personal information:

(i) through our website(s) and related applications and content that link or refer to this Policy (including its website www.Judge.com) ; and Judge computer or mobile software applications (“apps“) and content made available to you (collectively the “Sites“);
(ii) in connection with any of our events or sales, marketing, advertising and recruitment activities or in the course of providing other Judge services to you (collectively with the Sites, the “Judge Services“); and
(iii) when receiving services from you.

This Privacy Statement does not apply to the practices of third parties that Judge does not own or control.

Collection of Personal Information

With respect to your personal information, under Regulation (EU) 2016/679 (“GDPR”), we serve as the controller, and our contact information is as follows:

The Judge Group INC.
151 South Warner Road
Wayne PA 19087
privacyofficer@Judge.com

Judge collects and maintains personal information from the following categories of individuals:

• Visitors: individuals who visit or use our Site(s) or any other Judge Services, so that we can provide them with the Site(s) or Judge Services they require;
• Job seekers: individuals that apply for job opportunities with Judge to fill our internal positions or as part of our staffing and recruiting services or Judge’s customers through our business solutions services;
• Customers, vendors, service providers and other suppliers: employees, representatives and/or agents of our customers, service providers, vendors and other suppliers with whom we have a business relationship and/or manage on behalf of our customers.

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

The types of information we collect include the following:

• Information submitted to us: Judge collects personal information that individuals provide to us, such as when they visit one of our Sites, post on our forums or blogs, or access certain Judge Services or if they subscribe to our marketing or register for a Judge event or otherwise contact us. We may also collect personal information from individuals offline, for example when individuals provide information to us by telephone or in person.

The types of personal information we may collect include:

• Contact information (such as name, address, email address and telephone number);
• Professional information, such as your job title, department or job role;
• Information you provide about others you would like us to contact (for example referrals or references) or information regarding your
  emergency contacts;
• Resume or C.V. information, such as employment and education history, language proficiencies, security clearance information and
  other work-related skills, awards and honors, membership in clubs and organizations, personal interests and activities and information
  regarding your career interests and other qualifications for or desires regarding future employment opportunities, including information
  regarding desired compensation and benefits; and citizenship and work authorization status.
• Information we collect automatically: We automatically collect certain technical information from visitors to our Site, such as the Internet protocol (IP) address of their device, their login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platforms. We may also automatically collect certain information about their visits to our Site(s), such as download errors experienced and length of visits to certain pages. When you download, install or use Judge apps, we and our service providers may track and collect certain device related information (such as your device’s unique ID) and certain app usage data (such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device ID).
• Information we receive from other sources or third parties: We may receive or acquire information about our visitors, job seekers, customers and suppliers from third party partners (such as background check providers) or other third party sources (such as information from publicly available sites (like Monster.com, CareerBuilder.com or LinkedIn)), or a job seeker’s third party reference.
• By authorizing Judge to have access to this information, you agree that we may collect, store and use this information in accordance with this Privacy Policy.

Sensitive Personal Information: In connection with the various services we provide or if you are applying for a job opportunity with us or one of our customers, you may be asked for types of personal information that are viewed by some countries as sensitive personal information. Sensitive personal information includes, for example, government-issued identification number (such as a social security number), information relating to a person’s race or ethnic origin, political opinions or religious beliefs, physical or mental health or condition, sexual orientation, trade union membership, genetic data and any related legal actions or the processing of biometric data for the purposes of uniquely identifying an individual. It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws (collectively “Sensitive Personal Information”).

• Although we aim to minimize the amount of Sensitive Personal Information we process, we may process such information in certain circumstances, such as where we are required to or permitted to do so by law (e.g. information about your racial / ethnic origin, gender and disabilities for equal opportunity monitoring or affirmative action program), or where it is necessary to provide you with a service, or if we need to perform a criminal background check, drug/alcohol test or fitness for duty testing. If required by applicable data protection laws, we will obtain your express consent to our use of your Sensitive Personal Information.

Use of Personal Information

The personal information Judge collects will be used only as described in this Policy and/or in the way we specify at the time of collection. For the most part, we collect and use personal information to effectively provide and improve the Judge Services (such as our Site and related staffing and recruiting services, or workforce management) and to comply with applicable laws and government regulations (such as, to comply with mandatory employment, tax and insurance requirements).

More specifically, we may use your personal information for the following purposes:

• Providing and administering the Judge Services and for internal operations (for example, troubleshooting, data analysis, statistical and survey purposes);
• Protecting the Judge Services (for example, fraud monitoring and prevention);
• Responding to your communications;
• Complying with applicable laws and government regulations;
• If you are a job seeker:
  • facilitating the recruitment, staffing or search process by helping to find job seekers a suitable assignment or job match with us or with our customers;
  • storing information about your recruitment or other preferences;
  • sending you e-mails and other communications about job postings that we think fit your profile, and to notify you about events, surveys, workshops and training sessions run by Judge; and
  • to interact with you on third party social networks (like LinkedIn).

• Gauging the number of users and usage of the Site(s), so we can plan Site bandwidth and capacity accordingly;
• Recognizing you when you return as a repeat visitor to our Site(s) or other online Judge Services;
• Providing information on goods and services you have requested;
• Sending you e-mails and other promotional communications about Judge marketing, advertising and promotions in accordance with your marketing preferences. You can opt-out of our marketing at any time;
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, services and offerings, enhancing, improving or modifying our Sites, products and services and operating and expanding our business activities; and
• Notifying you about changes to our Site(s) or other Judge Services.

Personal information collected online through the Judge Services may also be supplemented with information you provide to us through other Judge services, as well as other online and offline sources (such as recruitment fairs, social media platforms (like LinkedIn), trade shows, or other events) and other data appending methods (such as spot tags, tracking and cookies as referenced below).

We may also use the personal information we receive for the purposes of creating anonymized and aggregated statistics that do not reveal the specific identity of any person.

In most cases, Judge will process personal information for a variety of business purposes which are in our legitimate interests (for example, to operate its business and provide you with services you have requested), in order to enter into or perform a contract with you and/or for compliance with our legal obligations (as described above). However in some cases and always where required by applicable law, Judge will seek your consent to process your personal information (including any Sensitive Personal Information). Before we use your personal information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out.

Cookies and Online Tracking

The Judge website uses “cookies” and similar technologies (like web bugs) to help personalize your online experience and for our analytics purposes.

• A cookie is a small data file placed on the hard drive of your computer when you visit certain websites. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited.
• A web bug is a graphic on a web page or email that gathers information about the computers used to view the web page or email. A web bug can collect your computer’s IP address and the time you viewed the website or email.
• Some parts of Judge’s website use cookies and web bugs to track user traffic patterns on Judge sites.

Use of Cookies for Advertising and Targeting

• The Judge website uses cookies as part of our advertising and targeting efforts. These cookies may be set by third-party advertising partners, such as Google, to build a profile of you and your interests.
• Third-party vendors, including Google, use cookie information based on your previous interactions with our site to serve relevant ads to you across the web.
• Third-party vendors, including Google, use cookie information based on your previous interactions with our site to build audiences that share similar interests to you and advertise to those audiences.

Opt-Out of Cookies

• If you prefer not to receive cookies or web bugs while browsing our website, you can set your browser to warn you before accepting cookies or web bugs and refuse them when your browser alerts you to their presence.
• If you would like to Opt-Out of Advertising and Targeting Cookies:
  • You may visit Google Ads settings to change your preferences
  • You may visit the Network Advertising Initiative Opt-out page to change your preferences
  • You may configure your device settings to control the use of identifiers.
• You can also refuse all cookies and web bugs by turning them off in your browser, although you may not be able to take full advantage of the Judge website if you do so. You do not need to have cookies turned on to use/navigate through many parts of Judge’s website, except that access to certain Judge Web pages require a login and password.

You can find information on popular browsers and how to adjust your cookie preferences at the following websites:

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer- delete-manage-cookies

http://www.mozilla.org/projects/security/pki/psm/help_21/using_priv_help.htm l

https://support.google.com/accounts/answer/61416

Apple Safari: Blocks cookies by default and accepts cookies only from your current domain. To change, click Safari, Preferences, Security, and choose your preference.

Sharing Your Personal Information within Judge

Judge may disclose your personal information to any affiliate within Judge for use in accordance with this Policy. This includes our subsidiaries, affiliates and our parent company.

This sharing of personal information with Judge affiliates may include combining the personal information gathered by certain Judge Sites with information independently gathered as well as information gathered offline into one or more database(s) useable by Judge, including all of its affiliates. Again, this combined information will only ever be used for the purposes disclosed within this Policy.

Sharing Your Personal Information with Third Parties

Judge may share and disclose personal information about you with the following types of third parties and in the following circumstances:

• Potential employers or potential customers: We may share your personal information if you are a job seeker with a customer for the purpose of providing the Judge Services (such as staffing and recruiting services, or workforce management services).

In connection with the above, we may need to disclose certain data about your previous employment (such as your resume and corresponding information or to the extent permitted by law, the results of any criminal background checks or other specific employee data such SSN/National ID) with that customer or other service providers or agents acting on our behalf to facilitate and enable the potential placement or employment. To the extent you are employed by a customer of Judge, the Judge customer will process such personal information in accordance with its own policies and procedures.

• Compliance with laws: We may disclose personal information to a third party where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process or government requests, including in response to public authorities to meet national security or law enforcement requirements. We also may disclose information that we collect as needed to enforce our rights, protect our property or protect the rights, property or safety of others, pursue available remedies or limit damages we may sustain or as needed to support external auditing, compliance and corporate governance functions.
• Vendors, consultants and other service providers: We use third party vendors, consultants and other service providers to assist us in providing the Judge Services, including to support us in areas such as recruiting and reviewing responses to job advertisements, managing résumé/CV data, IT platform management or support services, infrastructure and application services, marketing, data analytics, skills and assessments training, occupational health and safety screening, and drug and background screening. In providing these services on behalf of Judge, it may be necessary for us to provide these third parties with access to your personal information. Where required by the Privacy Shield, we enter into written agreements with those third party vendors, consultants and other service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps so that third party vendors, consultants and other service providers process personal information in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third party vendors, consultants and other service providers who perform services on our behalf for their handling of personal information that we transfer to them.
• Change of control: We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Judge does not share your personal information with third parties for those third parties’ direct marketing purposes.

Legal Bases for Processing

The legal bases of our processing of your personal information as described in this Policy are as follows:

• Performance of Contract. We may use your personal information to perform our contractual services.
• Legitimate Interest. We may use information for our legitimate interests. However, we rely on our legitimate interests as our legal basis only where those interests are not overridden by your interests or fundamental rights and freedoms (unless we have your consent or our processing is otherwise required or permitted by law). For instance, we may use your personal information to contact you and respond to your requests and inquiries, to administer our business including by creating statistical analyses, to identify prevent and detect fraud or to pursue or defend ourselves against legal claims.
• Consent. We may use your personal information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, we will not be able to send you marketing materials that you request. You are also free to withdraw your consent at any time. A withdrawal of consent will not affect processing that has been completed during the time in which the consent was valid. If you have granted us consent to use your information, we will use it only for the purposes specified when we request your consent. This includes use for our marketing campaigns.
• Fulfillment of Legal Obligations. We may use your personal information to comply with our legal obligations. To comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., retain certain information according to tax or commercial laws, respond to your requests to exercise your rights under applicable laws).

International Data Transfers

As a global company, we may transfer personal information to Judge companies and third parties located in the United States and in other countries that may be outside your country of residence for storage and processing in order to provide the Judge Services. These countries may not necessarily have data protection laws as comprehensive as those in your country or residence. We will however protect your personal information in accordance with this Policy and applicable law wherever it is processed and will only transfer your personal information through the use of appropriate safeguards.

Judge is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regards to our compliance with the Privacy Shield.

Your Choices:

Cookies and other similar technologies: For information about how to disable selected cookies and other similar tracking technologies from collecting information on the Judge Services to third party properties, please see the Section headed “Cookies and Online Tracking”.

Marketing Communications: Where it is in accordance with your marketing preferences, we may periodically send you updates via e -mail about promotional opportunities or services we think may interest you, such as jobs in our database that match your selection criteria.

You can opt-out of receiving marketing communications by clicking “Unsubscribe” in any e-mail communications we send you. At the point where we request personal information about you, our Sites also give you the opportunity to decide which communications you receive.

Security of Your Personal Information

Judge is committed to protecting the personal information you share with us. The Judge Group uses appropriate physical, technical, organizational and administrative security measures to help protect your personal information from unauthorized or unlawful access, use or disclosure, and from accidental loss, destruction or damage.

Judge supports online security using secure server technology because we want your data to be safe. We use state-of-the-art security arrangements and facilities on our Sites and through the Judge Services to maintain data security. Unfortunately, the transmission of information via the internet cannot be guaranteed 100% completely secure and we cannot guarantee the security of your personal information that is transferred over the internet.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section below.

Retention

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

Access Rights

You may have the right to access the personal information that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal information, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Links to Other Sites and Public Forums

The Judge Site may contain links to other sites for your convenience and information. If you access those links, you will leave the Judge Site. Judge does not control those sites or their privacy practices, which may differ from Judge’s practices. Judge is not responsible for the privacy practices or the content of other websites outside of Judge. The personal information you choose to provide or that is collected by these third parties is not covered by this Policy. We encourage you to review the policy of such third parties before submitting your personal information.

Judge may make message boards, news groups, and/or public forums available to users on its Site. Any information that you disclose in these areas becomes public information that may be accessed by third parties; therefore, you should use caution before deciding to disclose any personal information in these forums.

Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

Children

We do not knowingly collect or maintain personal information from any person under the age of thirteen. No parts of our Site are directed to or designed to attract anyone under the age of thirteen.

EU Residents

If you are an EU resident, under the GDPR, you have the following privacy rights, which you may exercise by contacting us at privacyofficer@Judge.com with “GDPR Request” on the subject line and in the body of your message:

• Right of Access. You have the right to obtain confirmation as to whether your personal information is being processed, as well as access to the personal information along with certain information, including the purposes of the processing, the categories of personal information concerned and the recipients or categories of recipients to whom the personal information have been or will be disclosed.
• Right to Rectification. You have the right to rectify your inaccurate personal information and to complete any incomplete personal information, including by means of providing a supplementary statement.
• Right to Erasure or Right to be Forgotten. You have the right to erase your personal information under certain circumstances.
• Right to Restrict Processing. You have the right to restrict our processing of your personal information under certain circumstances.
• Right to Object. You have right to object, on grounds relating to your particular situation, at any time to our processing of your personal information, which is based on public interest or our legitimate interests, including the profiling of data. In this case, we will stop processing your information, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims. You also have a right to object to the processing of your personal information for direct marketing purposes.
• Right to Data Portability. Under certain circumstances, you have the right to receive your personal information that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such information to another controller without hindrance from us.
• Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal information, you may withdraw your consent at any time to stop any further processing.
• Right to Lodge a Complaint. You have a right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates the GDPR.
• Right to Opt-Out of Certain Processing. You may opt out of the disclosure of your personal information to third parties (other than third parties acting as our agents and performing tasks under our direction) or from having your personal information used for a purpose that is materially different from the purposes for which it was collected. Before we use your personal information for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out.

 

Nevada Residents

Under Nevada law, Judge does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us as set forth below.

Questions or Complaints

In compliance with the Privacy Shield Principles, Judge commits to resolve complaints about our collection or use of your personal information.

EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Judge Customer Service Dept. at: customerservice@judge.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal information within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints.

If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities for further information and assistance.

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Judge and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Contacting Us

If you have any questions about this Policy or if you wish to exercise Your Privacy Rights, please contact:

The Judge Group INC.
151 South Warner Road
Wayne PA 19087
privacyofficer@Judge.com