Privacy Policy

The Privacy Policy (referred to as a Privacy Statement in certain jurisdictions) describes how Veterans Sourcing Group, LLC (VSG) processes personal information about you. This Privacy Policy applies when you visit or use our websites or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media, communicate with us on behalf of a vendor or client, purchase our products or services, or otherwise interact with us.

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This Policy does not apply to personal information processed in connection with your employment with VSG or appointment as a consultant to fulfill roles for VSG.  

 

By using the website or any of our products or services, you are understand and agree that we will collect, use, and disclose personal information as described in this Privacy Policy.

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We collect the following categories and types of personal information with your consent or as otherwise required or permitted by law: 

• Contact Information. We collect full name, email address, current and prior address, telephone number, and business contact information.

• Identifiers. We collect Internet protocol address, signature, username and password, and social media user names.

• Protected Classifications. We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status and disability information.

• Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, and billing address.

• Commercial Information. We collect records of products or services purchased, obtained, or considered.

• Internet or Electronic Usage Data. We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.

• Audio/Visual Data. We collect audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings.

• Geolocation Data. We collect geolocation data including the general region or area from which you access our Sites.

• Professional or Employment Information. We collect your job title, office location, business contact details, and employer name when you contact us on behalf of a third-party company. If you apply to work for us, either as an employee or as a consultant, we collect job application details such as your resume, previous work history, reference information, and professional memberships and certifications.

• Non-Public Education Information. If you apply to work for us, either as an employee or a consultant, we collect education history, degrees, transcripts and certifications.

• Sensitive Personal Information. We collect social security number, driver’s license number, passport number, state identification card number, and health information.

• Inferences. We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.

 

We collect information in a variety of ways:

 

• Directly from you. We collect contact information, identifiers, financial information, commercial information, and professional or employment information that you provide directly to us.

• When you visit our locations. When you visit our offices or facilities, we also collect contact information and audio/visual data.

• Automatically. When you access our Sites, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies.

• From third parties. We may collect contact information, identifiers, financial information, commercial information, and professional or employment information from third-parties including our vendors, clients, recruiters, and service providers.

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We use your personal information for the following purposes: 

• Transactional Purposes. We use contact information, identifiers, financial information, professional or employment information, and commercial information to: (i) provide you or our clients with products and services that we offer; (ii) communicate with you; (iii) provide you with customer assistance; and (iv) administer contracts with our vendors, clients, and service providers.

• Account Creation. If you download our application and choose to create an account, we will collect contact information and identifiers and use that information to create your account.

• Recruiting and Hiring. We use contact information, identifiers, audio/visual data, professional or employment information, non-public education information, financial information, medical information, sensitive personal information, and inferences to make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process. We will also use your information to provide qualifications and credentialing information to our clients so that they may assess your suitability for a role, onboard you, and credential you into their systems.

• Background Checks. Where permitted by law and with your consent, we require our applicants to complete a background check to verify your identity, check for criminal history, and confirm the validity of your application. We use your identifiers, personal characteristics or traits, professional or employment information, non-public education information, and sensitive information to enable the completion of the background check form.

• Business Operations. We use contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, education information, sensitive information, and inferences for our day-to-day business operations including billing and collections, procurement, tax-related activities, maintaining records, planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.

• Analytical Purposes. We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.

• Combination of Information. We combine contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

• Marketing and Promotional Purposes. We use contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients or consultants, client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.

• Maintenance and Improvement of our Sites and Systems. We use identifiers, geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.

• Develop and Improve Our Products and Services. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing products and service offerings.

• Security and Fraud Prevention. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to: (i) protect our Sites, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.

• Legal: We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

• Other Purposes: We may use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information for other reasons we may describe to you.

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We share personal information in the following circumstances or as otherwise described in this Privacy Policy: 

• Service Providers. We may share personal information with vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, order fulfillment, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, such as payment processors, the vendor or service provider may directly collect the information from you on our behalf.

• Affiliates. We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.

• Clients. We may share your personal information with our clients and companies we represent so that they may assess your suitability for employment or work as a consultant, onboard you into their systems, and credential you.

• Marketing/Analytics/Advertising Partners. We may share personal information with third party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails.

• Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.

• Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.

• Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.

• With Your Consent or At Your Direction. We may share information with third parties whenever you consent to or direct such sharing.

• Other Reasons. We may share information for other reasons we may describe to you.

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We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future. We use the following criteria to determine retention periods: 

• how long the information is needed to provide our services and operate our business;

• whether there are contractual or legal obligations that exist that require us to retain the information for period of time;

• whether any law, statute, or regulation allows for a specific retention period;

• whether an individual has agreed to a longer retention period;

• whether the data is considered to be sensitive data, and

• what the expectation for retention was at the time the data was provided to us.