Privacy Policy

How We Use the Information We Collect

Information relating to current and prospective clients and others that we collect in the course of business

• The personal information we collect with respect to our current and prospective customers includes:
  • the name, address, e-mail address, details on how to contact the customer, the nature of the talent requirements entrusted to us, financial, credit, billing and account information as well as all other related information related to the services we provide;
  • information we collect when representing candidates that relates to individuals, including personal information, employers, references, etc.
  • information about you contained in communications between Enthos Talent and you, whether online or not.

• We use this information for the following purposes:
  • to offer and provide our clients with talent information and services;
  • to communicate with our clients about the services they request and to respond to requests and questions;
  • to administer our consultants’ time charging and customer billing databases and to issue and collect accounts;
  • to present candidates to our clients and provide proof of qualifications and skills
  • to offer documentation on our services and on the progress of active talent searches
  • to manage and administer our business, including to prevent negligence and to protect you and us against error and fraud
  • to comply with legal, and regulatory requirements

If you prefer not to receive emails we send on our services and on active topics on Talent Services, you only have to ask us to remove your name from our lists, and we will no longer communicate with you for these purposes.

Information Regarding Prospective Enthos Talent Members

If you are applying for a position with Enthos Talent, we will collect the personal information contained in and obtained in connection with your application to assess your application and consider employment, or the presentation of your profile to a prospective employer or client to whom you may provide consulting services via Enthos Talent. We generally retain information collected about candidates to whom we have not offered a position, or who do not accept an offered position, for a reasonable period of time in the event that a position meeting their needs becomes available or in the event that such candidates would apply again to Enthos Talent. If a candidate accepts a position with Enthos Talent or a client of ours, the information will be retained in accordance with the privacy procedures we apply to our team.

Information about our representatives, vendors, and suppliers

Enthos Talent may collect information about outside representatives, vendors, or suppliers of Enthos Talent (“Service Providers”) who provide goods, services and information to the organization. This information may include the name, contact and banking information of these individuals, as well as any information about their experience and skills. We use this information to assess the suitability of service providers to fulfill specific mandates, to communicate with them, if necessary, regarding the goods, services and information they provide to Enthos Talent and to compensate them for this. We may also use this information to provide them with documentation about our services or talent expertise, or to invite them to participate in our electronic notifications. If you prefer not to receive documentation on our services, nor invitations to receive electronic communications regarding talent services, you only have to ask us to remove your name from our lists, and we will no longer communicate with you for these purposes.

How We Collect Information About You

Usually, the personal information that concerns you comes to us directly from you or arises from your relationship with us. However, sometimes we obtain personal information about you from other sources. For example, with respect to customers, in addition to the personal information you provide to us, we may collect personal information from the following entities or individuals:

• a government agency or registry;
• third parties, such as your financial institution, insurance company or employer;

With respect to prospective Enthos Talent Members, in addition to the personal information you provide to us, we may collect personal information from the following entities or individuals:

• third parties that you have listed as references in your job application;
• people who participated in the evaluation and review process
• criminal or credit check data collected with your consent, based on the requirement our customers may have, to ensure we disclose any history relevant to the employment contract available to you

How we communicate and share information about you

We share personal information we collect about customers or other individuals with whom we do business with third parties when:

• when the talent services we provide to you require us to disclose personal information about you to third parties, for example to a background check resource with your consent
• when the communication of the information is necessary, for example to a financial institution or insurance company
• where we are required to comply with regulatory requirements (including requirements of self-regulatory bodies) or requests from governmental authorities
• you have instructed us to disclose your personal information to a third party for a specific purpose
• we reasonably believe that a third party requesting information about you is your agent

We may share personal information about Enthos Talent alumni to provide an employment reference to a third party when requested by you.

Service providers. Enthos Talent may also transfer personal information about you to service providers retained by us to administer or provide products, services or information on our behalf. We require our service providers to use your personal information only as necessary to perform the services for which we have retained it. Most of our service providers process personal information in Canada or the European Economic Area (the “EEA”). Occasionally, we may use service providers who process personal information in the United States or other countries and who do not offer the same legal protections for personal information as Canada or the EEA. In such cases, we ensure that adequate contractual safeguards are in place, as required by applicable laws. If you have any questions about our use of Service Providers, including those located outside of Canada or the EEA, please contact our Chief Privacy Officer.

Commercial operations. We may also use and disclose personal information about you to parties associated with the proposed or pending financing, insuring, sale or other form of assignment of all or part of our business or our assets, for purposes related to the evaluation and execution of the transaction. This may include deciding whether or not to proceed with the transaction or the business relationship, or meeting registration or other reporting requirements. Where appropriate, we will take steps to require these parties to process personal information about you in accordance with this Privacy Policy, and that they only use or communicate them for the purposes for which they were collected, in particular to provide the services or information that Enthos Talent would otherwise provide to you and, in general, to carry out the activities of Enthos Talent.

Our website

As with most websites, we use automatic data collection technologies to track trends in the use of our website. Each time you visit our website, our server logs the name of your Internet service provider, your IP address, the date and time of your visit, the pages you visit, the documents you download, the searches you make and the referral URL you used to access our site. We use this information to optimize the services offered on our website.

To serve you better, we may provide links on our website to other websites. However, Enthos Talent is not responsible for the personal information collection, use and disclosure practices of other entities which you may access from our website and the firm accepts no responsibility in this regard. We urge you to review the privacy policies of these other entities before providing any personal information about you on their websites.

Legal basis for processing

During our business activities outside of the EEA, we process personal information subject to obtaining consent to do so, except as required by law. For example, we may have the right to collect, use or disclose personal information, without obtaining consent, to collect debts owed to us, to comply with a subpoena or a court order or to comply with the rules of a court regarding the production of documents. Your consent may be express or implied, depending on the circumstances and the level of confidentiality of the personal information in question. For example, in the majority of cases, a customer's consent to collect,

In the course of our business activities in the EEA, we rely on one of the following legal grounds (as applicable) to justify the processing of personal information

• To enter into and perform a contract with you, or take any action required of you prior to entering into a contract.
• To defend our legitimate business interests in establishing, managing, or terminating our business relationship with you.
• Where you have expressly consented to our processing of your personal information.
• To comply with our legal obligations and establish, exercise or defend our rights.

Where personal information is processed subject to obtaining consent to do so, you may (subject to legal and contractual restrictions) refuse to give your consent or choose to withdraw your consent to our processing of your personal information by contacting our Chief Privacy Officer: virginia.poly@EnthosTalent.com or 416-885-3934. Please note that if you refuse to give or withdraw your consent to certain processing of your personal information, we may no longer be able to provide you with certain of our services.

Records Security and Retention

Enthos Talent has implemented reasonable physical, organizational, and technological security measures to safeguard personal information in our custody or control. These measures include safeguards to protect this information against loss or theft as well as against unauthorized access, communication, copying, use or modification. Members of Enthos Talent, its representatives and authorized agents have access to your personal information.

In general, you can visit the Enthos Talent website without providing any personal information. However, since data submitted electronically is not 100% secure, we cannot guarantee the security of any personal information you submit to us, which you do at your own risk.

Personal information is retained as described in this Privacy Policy, and in accordance with our record retention policies. We establish our record retention periods, considering obligations under privacy laws, the purposes for which the information was collected, legal and regulatory information retention requirements for minimum periods, limitation periods for bringing claims, and our business objectives.

Access, Correction and Other Rights

We maintain a file of personal information about you for the purposes described in this Privacy Policy. You can access this file by request, or request corrections to, by submitting a written request to our Chief Privacy Officer at the address provided below. We may need to verify your identity before seeking or providing you with personal information.

Because we primarily use this personal information to provide talent services to you, it is important that it is accurate and up-to-date. Please notify us as soon as possible of any changes to your personal information.

Inquiries and Complaints

If you have any questions, inquiries or complaints about our privacy practices, please contact our Chief Privacy Officer, Enthos Talent, by email at virginia.poly@EnthosTalent.com, or by phone at 416-885-3934.

Changes to this Policy

This Privacy Policy is effective as of the date listed below. Enthos Talent reserves the right to make changes to this Privacy Policy at any time. We will take reasonable steps to notify you of any changes to this policy, including by posting the revised policy on our website. We recommend that you review this policy occasionally to ensure that you are up to date with the latest version. You may contact us at the mailing address, email address or telephone number above for an up-to-date copy of this policy.