Welcome! Thank you for visiting www.harveynashusa.com, (“Site”) which is owned and operated by Harvey Nash Inc. We provide this notice explaining our information practices for California residents who interact with us on our Site, and our other related tools, mobile enabled services, mobile applications and other applications and services to which this Privacy Policy is linked (“Services”). This Privacy Policy applies to all California residents who interact with our Services, including website visitors, individuals seeking employment opportunities with our clients, and representatives of our corporate clients. While some of the information we describe here is technical, our goal is to make this policy straightforward, so please contact us if you have any questions. If you are a resident of Canada, please see the section “Your Rights – Canada”
Certain terms used in this Privacy Policy have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (the “CCPA”).
Scope and Consent.
This Privacy Policy explains what Harvey Nash Inc., together with its corporate affiliates and subsidiaries1 (collectively referred to here as “Harvey Nash”), does with your personal information, whether you are a website visitor, a job candidate seeking employment with one of our clients, or a representative of a Harvey Nash client company. It covers how we collect, use, retain, and disclose your personal information as part of helping you find a job, developing your career, providing recruiting services to our clients, or simply as a result of you visiting our website.
1 Including, but not limited to, Nash Squared, Alumni, Spinks (We Are Spinks), NashTech, PAT Management, Talent-IT, and Team4Talent.
Information Practices: How we collect, use, retain, and disclose personal information.
Collection of Information
When you use our Services, we collect the following types of information from and about you. The information we collect may vary depending on the nature of your interaction with us. Some of this information may be considered “personal information,” meaning it identifies, relates to, describes, is capable of being associated with, or otherwise can be reasonably linked to you or your household.
Personal Information You Provide
You may choose to provide us with personal information through the use of our Services, including:
Identifiers and contact information, such as name, address, email, phone number, social security number, driver’s license number, passport number, or other similar identifiers.
Categories of personal information described in California Civil Code § 1798.80, such as name, signature, telephone number, financial information, and medical information (for example, information you choose to provide in connection with accommodation requests).
Protected classifications, such as your age, sex, race, national origin, medical condition, marital status, military or veteran status, gender identity or expression and request for family care leave.
Commercial Information, such as products or services purchased, obtained, or considered.
Professional, Employment, and Education Information, such as information about your education, current and previous job title and employer, professional publications, and professional certifications.
Inferences from the information we collect about you, such as creating a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Other Personal Information you may disclose to us, such as bank account number, payroll details and other financial information.
Automatically Collected Information
We automatically collect personal information when you access and use our Services, including:
Identifiers: Identifiers such as your IP address, Internet service provider (ISP), device make and model, and unique personal identifiers.
Internet or Other Electronic Network Activity Information: We may collect information regarding your interaction with our Services, which includes but is not limited to browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you visit our Services, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Services and other information about your internet activity (“usage information”).
Geolocation Data: We may collect information regarding your approximate physical location when you use our website.
Information from Outside Sources
We may collect personal information about you from other sources. For example, depending on the nature of your interaction with us, we may obtain information about you from background check vendors, job boards, social media sites, publicly available databases, data aggregators, staffing agencies, and other third-party vendors.
Use of Information
We collect personal information for a variety of business and commercial purposes, such as to:
- Process payments
- Verify customer information
- Maintain or service accounts
- Process or fulfill orders and transactions
- Auditing related to a current interaction with the consumer
- Provide customer service (e.g., to resolve disputes, feedback, problems with the Services)
- Conduct and review Harvey Nash surveys
- Improve, upgrade or enhance our Services
- Short-term, transient use
We collect and use sensitive personal information only for limited purposes permitted under the CCPA, including to perform the services that you request, to verify or maintain the quality of our Services, for security purposes, for short-term transient use, to protect against malicious, deceptive, fraudulent, or illegal actions, and for other purposes set forth in the CCPA regulations. We do not use sensitive personal information for the purpose of inferring characteristics about you.
Data Retention
We store personal and sensitive information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. We determine our retention and deletion periods according to the following criteria: the scope, nature, and sensitivity of the personal information; the risk of harm from unauthorized use or disclosure; the purposes for which the information was collected and how long it is needed for those purposes; the period during which the information may remain accurate and relevant; applicable legal, accounting, reporting, or regulatory requirements; and the potential need to retain records for legal claims or compliance audits. In specific circumstances, we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
Disclosure
Personal information that we collect may be shared with:
The Harvey Nash Inc. Corporate Family: We may share the information we collect about you with the Harvey Nash Inc. corporate family and our affiliates and subsidiaries, including but not limited to Nash Squared. Service Providers: We may disclose your information to service providers and vendors under contract who help with our business operations, such as HR software providers, payroll vendors, health benefits providers, cloud storage providers, to assist with, bill collection, payment processing, web hosting, recruitment, employment, research, IT, direct mail and email distribution, site analytics and operations, fraud investigations, processing opt-out requests, and responding to consumer requests. We may also share your information with legal, financial, insurance and other advisors in connection with corporate transactions, the management of our business and operations, to defend against legal claims; to investigate, prevent, or act against illegal activities, suspected fraud, situations involving potential threats to safety, or violations of Harvey Nash Inc.’s terms of use; to protect our operations, assets, and intellectual property; to allow us to pursue appropriate legal remedies or limit damages; to pursue any reorganization, merger, sale, joint venture, assignment, transfer of assets, or other disposition of all or any portion of our business, assets, or stock; or as otherwise required by law.
Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Harvey Nash Inc. user to legal liability.
Change of Control – New Owners: We may transfer your personal information as an asset that is part of a merger, acquisition, bankruptcy or other transaction if a third party assumes control of all or part of our business.
Other Entities with your Consent: Other parties at your specific direction.
Summary of Information Practices in Last 12 Months.
The following table summarizes our personal information collection, use, and disclosure practices in the preceding 12 months. On mobile devices, scroll horizontally to view full table.
| Categories of Personal Information | Categories of Sources | Commercial / Business Purpose(s) for Collection/Disclosure | Categories of Service Providers to Whom Personal Information is Disclosed | Categories of Third Parties to Whom Personal Information is Sold or Shared |
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Examples: name, alias, email address, postal address, phone number, IP address, account name, social security number, driver’s license number, passport number, and unique personal identifier |
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Examples: bank account number, payroll details and other financial information |
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Examples: race, color, age, sex, citizenship, national origin, medical condition, marital status, military or veteran status, gender identity or expression and request for family care leave |
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Examples: Information regarding a consumer’s interaction with our Services; Domain information, pages visited, and hyperlinks clicked; Session information such as time spent on certain pages and page interaction |
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Examples: general location at city level |
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Examples: job history, educational history, professional certifications, publications, etc. |
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Sale or Sharing of Personal Information: We do not sell or share your personal information with third parties. We also do not knowingly sell, share, use or disclose the personal information of children under the age of 16. In addition, we do not sell end users SMS originator or opt-in information to third parties for marketing or promotional purposes. Please Contact Us below if you have any questions.
Choices for Access, Deletion, Correction, and Right to Non-Discrimination for California Residents or As Required by Law.
Depending on your state of residence, you may have specific legal rights regarding your personal information. This section describes the legal rights that are available to some individuals and explains how to exercise them.
- Know and Access: Residents of certain states may have the legal right to request, subject to certain limitations, that we disclose the personal information we have collected about them, such as the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
- Correction: Residents of certain states may have the legal right to request that we correct the personal information we maintain about them, if that information is inaccurate.
- Deletion: Residents of certain states may have the legal right to request that we delete certain personal information we have collected about them, subject to certain exceptions.
- Portability: Residents of certain states have the legal right of portability, or the right to have us transfer their personal information to other persons or entities upon their request, subject to certain exceptions.
- Non-Discrimination: Residents of certain states have the legal right to not be discriminated against for exercising their privacy rights.
Residents of states that provide the specific legal rights listed above may exercise their privacy rights by emailing us at CPRA@harveynash.com or calling us at 1-833-496-0299.
Verification: Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request and provide appropriate proof of identity.
For requests to know or delete information about a child under the age of 13, we accept requests for information regarding minors under the age of 13 if we can determine that such requests were submitted by a parent or guardian.
Authorized Agents: You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Appeals: Where required by law, we will also provide instructions on how you may appeal our decision or submit a complaint. We will maintain a record of the request and our response for 24 months. If applicable state law grants you the right to appeal our denial of their request to exercise their privacy rights, they may appeal our denial by contacting us at CPRA@harveynash.com, or call 1-833-496-0299.
Do Not Track Signals: Some internet browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, Harvey Nash does not respond to Do Not Track signals to the extent received from a web browser.
Communication Preferences and Marketing (Opt-out).
If you do not wish to receive marketing communications from us, you can indicate your communications preference within the direct communication from us.
Cookies.
When you visit the Services, we and our third-party services providers may use cookies and other tracking mechanisms to track information about your use of the Services. The information generated by the cookies may include your IP address, your browser type, the date and time of your visit, the pages you visit and the amount of time spent on each, your device’s operating system, your mobile device identifier, your geographical area, referring URLs, and other information on your interaction with our site. For example, we may use the Google Analytics cookie to learn more about our users. To learn more about Google Analytics, please visit the following website, https://analytics.google.com/analytics/web/provision/#/provision.
Third Party Links
Our Services may contain links to other third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but is instead governed by the privacy policies of those third-party websites. We are not responsible for the privacy practices or the content of these third-party sites.
Security.
We may store and process your information in the United States and around the world. Although we endeavor to safeguard your personal information using commercially reasonable precautions, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee the absolute security of your information. It is your responsibility to make sure that the personal information you submit is accurate. To help protect your information, you should take steps to protect against unauthorized access to your password and device by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. If you believe that your login credentials have been compromised, please contact us as indicated in the Contact Us section below.
Children’s Privacy.
The Services are not intended for individuals under the age of 18. We do not knowingly collect personal information via our websites, applications, services, or tools from individuals under 18 years old.
Notification Regarding Updates.
We will change this Privacy Policy from time to time. When we make changes, we will revise the date at the top of the policy and, in some cases, will notify you through the Services, such as on our homepage, or via email or other communication. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.
Contact Us.
If you have any questions or concerns about this Privacy Policy or our privacy practices, you may contact us by emailing us at CPRA@harveynash.com or calling us at 1-833-496-0299.
Appendix
Appendix 1
Audio Recording and Transcription
We may record telephone calls or virtual meetings with clients, consultants, candidates, and other business contacts where necessary and proportionate. Before any recording begins, we will inform participants that recording is taking place and that we rely on our legitimate interests to maintain accurate records of communications and agreements. Where recording is not necessary or if you object, we will pause or avoid recording and document the discussion through written notes instead.
The recordings are used to create written notes or transcripts using secure AI-based transcription tools. These notes help us maintain accurate records of our communications and any agreements reached. Recordings are automatically deleted within 30 days unless transcription or verification is still in progress. Once notes are finalized, audio files are deleted. Resulting notes or transcripts may be stored on our internal systems in line with our data retention policy.
Recording tools used by us (e.g., secure AI-based transcription services) are configured to enforce the above deletion window (for example, auto-delete settings set to "delete within 30 days"). Access is strictly limited to authorized personnel and handled in accordance with GDPR and our internal acceptable use and data security policies.
Appendix 2
Use of Artificial Intelligence Tools
This Appendix explains how we use artificial intelligence (“AI”) tools in connection with our recruitment, consultancy, outsourcing and related services. It should be read together with the rest of this Privacy Notice.
1. AI tools we may use
We may use approved AI tools to support recruitment workflows, candidate matching, communications, summarization, drafting and internal productivity. We may update the AI tools we use from time to time, subject to appropriate privacy, security and supplier due diligence.
2. Personal information processed
Depending on the tool and purpose, AI tools may process candidate, consultant, client contact and business contact information, including names, contact details, CV or professional history, recruitment preferences, application status and communications data such as emails, call notes, summaries or transcripts.
We do not intentionally input special category data into AI tools unless this is necessary, lawful and subject to appropriate safeguards.
3. Purposes of use
We may use AI tools to identify and match candidates to roles, support recruiter and administrative workflows, generate summaries, assist with drafting and improve the efficiency and consistency of our services. Where AI tools are used to assist with candidate matching or role suitability, this may involve profiling. Where AI-assisted scoring is used, it may help us identify potentially suitable roles, candidates or opportunities, but it does not determine recruitment outcomes without human review. Any such profiling is used to support, not replace, human decision-making. AI-generated outputs are subject to appropriate human review and are not relied on exclusively.
4. Lawful basis
Our lawful basis will depend on the relevant processing activity. We may rely on legitimate interests, performance of a contract, legal obligation and, where required, consent. Where we rely on legitimate interests, our interests may include improving the efficiency, quality and consistency of our recruitment services, matching candidates to suitable opportunities, managing communications and supporting internal administration. Where AI tools are used to record or transcribe calls or meetings, individuals will be informed before the recording or transcription begins and, where required, consent will be obtained.
5. Controls and safeguards
We apply controls to ensure that AI tools are used appropriately and proportionately. These include data minimization, employee usage rules, restrictions on highly sensitive or confidential information, supplier due diligence, contractual safeguards, access controls, encryption and monitoring where appropriate.
6. Retention and model training
Personal information processed using AI tools is retained only for as long as necessary for the relevant purpose and in line with our retention policy. This information is used for inference and employee training but not to train AI models. Where available and appropriate, we configure AI tools, and put contractual controls in place, to limit retention of prompts, inputs and outputs and restrict the use of personal information to train third-party AI models, unless expressly agreed, documented and lawful.
7. Automated decision-making and individual rights
AI tools support our services but do not replace human involvement. We do not use AI tools to make solely automated decisions about candidates, workers or consultants that produce legal or similarly significant effects, such as decisions to submit, shortlist, reject, engage or terminate, without meaningful human involvement. You retain the rights set out in this Privacy Notice, including rights to access, correct, delete, restrict or object to processing and rights relating to automated decision-making.