Privacy Policy

I. PRIVACY POLICY

Effective on: October 6, 2023

II. INTRODUCTION AND SCOPE

Human Resources Briefings (“we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. Human Resources Briefings provides business customers (“Customers”) with lead generation services, including content syndication, data analytics and email marketing services, as well as our Content Indication Platform (collectively, the “Lead Generation Services”). This Privacy Notice (the “Notice”) addresses how we collect, receive, use, store, share, transfer and process your Personal Data, as well as your rights in determining what we do with the information collected via our website and in connection with our Lead Generation Services (collectively, the “Services”). This Notice does not apply to Personal Data we collect by other means, such as Personal Data of our employees.

III. CONTROLLERSHIP

Within the scope of this Notice,Human Resources Briefings is a domain owned by the data controller. Intentgine (a trading name of Intentgine, Inc.), acts as a data controller for the Personal Data we process when you visit our websites or when you interact with us. Intentgine is acting as Data Processor for the Personal Data we process through our Services. For more information about this, visit https://intentgine.com/privacy-policy/

IV. CATEGORIES OF PERSONAL DATA

In this privacy policy we refer to “Leads,” “Customer Representatives” and “Website Visitors”, as follows: (1) if you are a Lead, you are an individual about whom we process Personal Data in connection with the Lead Generation Services (for example, individuals who interact with content that we send in emails on behalf of our Customers or content available on our websites);  (2) if you are a Customer Representative, you are an employee, contractor or other individual authorized by a Customer to use our Services and we provide you with Personal Data about the Leads; (3) if you are a Website Visitor, you are an individual who visits our website and you do not fall under the Lead or Customer Representative categories.

If you are a Lead, we process the following types of Personal Data about you:

• biographical information, such as first and last name and date of birth; and contact information, such as email address, phone number, postal address, and country of residence postal;
• employment information, such as industry, job title, company name, seniority within company, department name, or company size;
• business contact information, such as company email address and postal address; and public LinkedIn profile;
• analytics information, including the type of content that you engage with when using the Services, or after clicking a link in an outreach email;
• device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, IP address, wireless network, and mobile network information (including the mobile phone number);
• geo-location information when you use the Services; and/or
• records and copies of your correspondence (including e-mail addresses), if you contact us. This may include call recordings where we monitor and record such calls for staff training or quality assurance purposes.

If you are a Customer Representative, we process the following types of Personal Data about you:

• business contact information such as first and last name, email address, phone number, postal address;
• billing and payment information, including the address for billing, billing contact information and credit card information;
• device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, IP address, wireless network, and mobile network information (including the mobile phone number);
• geo-location information when you use the Services; and/or records and copies of your correspondence (including e-mail addresses), if you contact us. This may include call recordings where we monitor and record such calls for staff training or quality assurance purposes.

If you are a Website Visitor, we process the following types of Personal Data about you:

• contact information such as first and last name, email address and phone number;
• device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, IP address, wireless network, and mobile network information (including the mobile phone number);
• geo-location information when you use our website; and/or
• records and copies of your correspondence (including e-mail addresses), if you contact us. This may include call recordings where we monitor and record such calls for staff training or quality assurance purposes.

We do not process information that may be considered ‘special category’ or ‘sensitive’ Personal Data, such as health related information or information relating to racial origin or political affiliations.

V. HOW WE RECEIVE PERSONAL DATA

If you are a Lead, we receive your Personal Data when:

• you provide it directly to us through our Services, or by clicking a link in a Human Resources Briefings or Intentgine outreach email;
• our Customers (including Customer Representatives) provide it to us;
• we receive it from other companies within our corporate group;
• our service providers provide it to us;
• we obtain lists from our business partners and data vendors with respect to individuals who might be interested in becoming customers of or are otherwise interested in our Customers;
• you provide it on publicly accessible sources, such as on LinkedIn or your company website; and/or
• information is captured via cookies and similar technologies (collectively referred to as “cookies”), as outlined in the “Cookie” section below.

If you are a Customer Representative, we receive your Personal Data when:

• you provide it directly to us through our Services;
• our Customers provide it to us; and/or
• such information is captured via cookies and similar technologies (collectively referred to as “cookies”) as outlined in the “Cookie” section below.

If you are a Website Visitor, we receive your Personal Data when:

• you provide it directly to us through our website; and/or
• such information is captured via cookies and similar technologies (collectively referred to as “cookies”), as outlined in the “Cookie” section below.

VI. PURPOSES OF PROCESSING

If you are a Lead, we process your Personal Data to:

• respond to your requests or questions;
• provide you with access to the Services and the content therein, including content that we send you on behalf of our Customers;
• create a record for our Customers about your interactions, which we may enhance with additional information about you (e.g. your name, job title, location and email address); and/or
• share your Personal Data with our Customers in connection with the Lead Generation Services, including to help them improve their business, target marketing campaigns and services through different strategies.

If you are a Customer Representative, we process your Personal Data to:

• respond to your requests or questions;
• process and complete transactions, including to obtain sales leads, and send you related information;
• provide technical and other support to you;
• send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, and the Lead Generation Services;
• enable our service providers to perform certain responsibilities and provide certain services in connection with the Lead Generation Services and our business and operations
• provide you with notices about your account;
• carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; and/or verify your identity and prevent fraud or other unauthorized or illegal activity.

If you are a Website Visitor, we process your Personal Data to:

• provide you with access to our website;
• respond to your requests or questions;
• provide technical and other support to you; and/or
• send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, and the Lead Generation Services.

VII. BASIS OF PROCESSING

We process your Personal Data on the basis of:

• your consent (you may withdraw your consent at any time by contacting us via the information in the “Contact Us” section below. This will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect processing performed on other lawful grounds);
• if you are outside Canada, our legitimate interests in providing effective Services to our Customers and maintaining our business relationship;
• need to comply with the law; or
• any other ground, as required or permitted by law.

VIII. DATA PRIVACY FRAMEWORK

Intentgine, who owns the domain Human Resources Briefings, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. 

Intentgine 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 in reliance on the EU-U.S. DPF. Intentgine has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-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/. 

Intentgine is responsible for the processing of personal data it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. Intentgine complies with the DPF Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Intentgine’s compliance with the EU-U.S. DPF and Swiss-U.S. DPF.  In certain situations, Intentgine may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Intentgine commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States.  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

IX. DATA RETENTION

We will retain your Personal Data for the period necessary for the purposes of processing listed in this notice unless a longer retention period is required by law or if it is reasonably necessary for us to comply with our legal obligations, or to resolve a dispute. If you stop using our Services, we will store your information in an aggregated and anonymized format; we may use the anonymized information indefinitely without further notice to you.

X. SHARING PERSONAL DATA WITH THIRD PARTIES

We share Personal Data with our affiliates and Customers, as well as with our service providers who process Personal Data on our behalf and who agree to use the Personal Data only to assist us in providing our Services to our Customers, or as required by law. We share Personal Data of Leads with our Customers as specified in the “Purposes of Processing” section above. We share Personal Data with our service providers in relation to the following services they provide to us:

• application hosting services;
• cloud storage services;
• business productivity services;
• communication services and software;
• email verification software;
• customer relationship management (CRM) software; and
• contact verification and data enrichment services.

However, before transferring your Personal Data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your Personal Data that we do. We remain liable for the protection of your Personal Data that we transfer or have transferred to third parties through our designated data transfer mechanism, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.

Personal Data may be stored or processed by us and/or our third party service providers outside of your jurisdiction, including to the United States. When this occurs, your information may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. We may also transfer Personal Data to third countries outside of the European Union, the EEA, the UK or Canada. The European Commission and/or the UK government may have determined that some of these third countries do not provide an adequate level of protection with respect to Personal Data. We will only transfer your Personal Data to third parties in these countries when there are appropriate safeguards in place. These include the Standard Contractual Clauses (“SCCs”) as approved by the European Commission or the equivalent mechanism approved by the UK government. Such mechanisms are formally integrated into our agreements with third parties when the processing is subject to EEA and/or UK data protection laws.

XI. OTHER DISCLOSURE OF YOUR PERSONAL DATA

We disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.

XII.  DIRECT MARKETING

Where required by applicable law, we will only send you direct marketing communications, such as through email, including offers any news and exclusive offers, promotions, or events, where you have consented to do so.

You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt-out facilities provided in the direct marketing communications.

XIII. COOKIES

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our websites and services.

We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. For more information, please visit https://www.aboutcookies.org/.

Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites visited by the user about the user’s browser DNT preference setting. We do not currently commit to responding to browsers’ DNT signals with respect to our website, in part, because no common industry standard for DNT has been adopted, including no consistent standard of interpreting user intent.

We and third parties on our digital properties may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:

• Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)
• European Interactive Digital Advertising Alliiance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)
• Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

XIV. DATA INTEGRITY & SECURITY

We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction. Such measures, which may necessarily evolve over time as the availability and effectiveness of methods vary, include physical, organizational and technological safeguards.

Still, no system can be guaranteed to be 100% secure. If you have questions about the security of your Personal Data, or if you have reason to believe that the Personal Data that we hold about you is no longer secure, please contact us immediately as described in this Privacy Notice.

XV. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section §1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to us at: privacy@intentgine.com or write to us at: Intentgine, 316 California Ave. #34, Reno, NV, 89509.

If you are a California resident, you may have rights under the Consumer Privacy Act of 2018 and the related regulations (the “CCPA”) regarding your “Personal Information” (as defined in the CCPA.) This section does not apply to information exempted from the scope of the CCPA.

The below table explains our practices in the preceding 12 months related to the categories and types of Personal Information that we collect about you and the categories of third parties that we disclosed and/or sold this information to. We do not have actual knowledge that we sell Personal Information of individuals under 16 years of age.

As a California resident, you may have the rights listed below in relation to Personal Information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Know. You have a right to request the following information about our collection, use and disclosure of your Personal Information over the prior 12 months, and ask that we provide you with a copy of the following:

• categories of and specific pieces of Personal Information we have collected about you;
• categories of sources from which we collect Personal Information;
• the business of commercial purposes for collecting Personal Information;
• categories of third parties to whom the Personal Information was disclosed for a business purpose; and
• categories of Personal Information disclosed about you for a business purpose.

Right to Delete. You have a right to request that we delete Personal Information, subject to certain exceptions.

Right to Opt Out. You have a right to opt out of the sale of your Personal Information to third parties. To opt out of the sale of your Personal Information, please click “Do Not Sell My Info” link or reach out using one of the methods outlined below.

To submit a request to exercise any of your California privacy rights, please contact us by emailing privacy@intentgine.com.

We may need to verify your identity before processing your request, and may ask you for limited information, such as your email address, government issued ID before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

We will not discriminate against you for exercising any of your rights under the CCPA.

XVI. OTHER PRIVACY RIGHTS

Depending on where you live, you may have some or all of the rights listed below in relation to Personal Data that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Confirmation of existence of processing: you may have the right to confirm that we process Personal Data about you;  

Access: you may have the right to access Personal Data we hold about you, how we use it, and who we share it with;

• Portability: you may have the right to receive a copy of the Personal Data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions;
• Correction: you may have the right to correct any of your Personal Data we hold that is inaccurate;
• Anonymization: you may have the right to anonymization, blocking or elimination of Personal Data that is unnecessary, excessive or processed in a way that is noncompliant with the provisions of laws of certain jurisdictions;
• Erasure: you may have the right to delete the Personal Data we hold about you;
• Restriction of processing to storage only: you may have the right to require us to stop processing the Personal Data we hold about you, other than for storage purposes, in certain circumstances;
• Objection: you may have the right to object to our processing of your Personal Data. We will stop the relevant processing unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms, or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim;
• Information regarding entities with whom data shared: you may have the right to information regarding the public and private entities with whom we have shared use of your Personal Data;
• Information on consent: you may have the right to information on the possibility of not providing consent, and on the effects of consent denial;
• Objection to marketing: you can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you; and

· Withdrawal of consent: where we rely on consent to process your Personal Data, you may have the right to withdraw this consent at any time by contacting us via the information in the “Contact Us” section below.

Some of the above rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your Personal Data.

We sometimes use computers to study your Personal Data. We might use this Personal Data so we can attempt to predict your buying behavior and interests. Depending on where you live, for decisions that may seriously impact you, you may have the right not to be subject to automatic decision-making or the right to request the revision of the decisions made solely on the basis of automatic processing of your Personal Data, including profiling. But in those cases, we will always explain to you when we might do this, why it is happening and the effect.

Intentgine and Human Resources Briefings, the domain it owns, has limited rights to access Personal Data our service providers submit to us. Therefore, if you contact us with such a request, we will forward your request to that service provider and provide any needed assistance as they respond to your request.

To exercise any of these rights or raise any other questions, please contact us by using the information in the “Contact Us” section below.

XVII. PRIVACY OF CHILDREN

The Services are not directed at, or intended for use by, children under the age of 13. If you believe we have inadvertently collected information about your child, please contact us and we will attempt to delete the information.

XVIII. U.S. REGULATORY OVERSIGHT

Human Resources Briefings the domain owned by Intentgine is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

XIX. EEA AND UK SUPERVISORY AUTHORITY OVERSIGHT

If you are located in the EEA and/or the UK and we process your Personal Data subject to the data protection laws of these jurisdictions you have the right to lodge a complaint with a data protection regulator in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you.

XX. CHANGES TO THIS NOTICE

We may update this Privacy Notice and its effective date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page. We encourage you to periodically review this page for the latest information on our privacy practices.

XXI. CONTACT US

If you have any questions about this Notice or our processing of your Personal Data, please write to us by email at privacy@intentgine.com and privacy@humanresourcesbriefings.comby postal mail at:

Intentgine, Inc.
Attn: Paul Hong, COO
316 California Ave #34
Reno NV 89509
United States

Please allow up to four weeks for us to reply.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.