Last Revised: June 23, 2024

Effective Date: August 23, 2024

We, STM Associates (“we,” or “us”), are committed to protecting the privacy and security of personal information and to transparency about how we use personal information (also known as personal data). This Privacy Policy sets forth our policies and practices for collecting and using personal information regarding any of our services that link to this Privacy Policy (our “Services”). This Privacy Policy does not address our use of personal information outside the context of these Services.

 

For purposes of this Privacy Policy, we regard personal information as any information that relates to an identified person or reasonably identifiable person.

Within the context of the Services, this Privacy Policy explains how we use and disclose personal information. It also discusses how you can control certain uses and disclosures of your personal information. We will update this Privacy Policy from time to time, or as our privacy practices change, to ensure it accurately describes how we use personal information. When we do so, we will update the dates above. We recommend that you review this Privacy Policy occasionally for the latest information. If we change our practices in a material way, we will update this Privacy Policy.

If you have any questions regarding this Privacy Policy or our use of your information, please contact us using one of the methods detailed in the last section of this Privacy Policy.

 

1.  How we use and share personal information

We limit the collection and processing of personal information to that which we need for our business purposes, as explained below:

 

Categories of individuals Categories of personal information Purposes Methods of collection Categories of third-party recipients (see below)
Users of the Services
  • Device, usage, and activity information
  • Interest and demographic information
  • Non-precise location information
  • To provide the website
  • Service analysis, security, and administration
  • Directly from individual
  • Indirectly by observing individuals’ activities or behavior
  • From analytics providers
Analytics providers
Users who apply for employment using the Services
Professional qualification information, including employment history, credentials, and materials such as résumés/CVs, cover letters, and references
For consideration for employment
Directly from individual
Our clients who are seeking to find suitable persons for employment
Individuals who are employment references for our users
  • Name and contact information
  • Professional affiliation information
To enable us or our clients to contact you about a person seeking employment using our Services
Directly from employment applicant
None
Individuals who contact us or send us correspondence
  • Name and contact information
  • Contents of correspondence
To respond to the correspondence
Directly from individual
None

Please be aware that we use third-party tracking technologies to share information with third parties for analytics purposes, as described in the table above.

2.  Disclosure and sharing

In addition to the sharing with the third parties described in the table above, we may also share your personal information with:  

  • Processors/service providers. We share your personal information with third parties that provide services to us. We engage these kinds of third parties with contracts that require them to use your personal information only to deliver the services for which we have engaged the third party, and as required by law. These third parties provide business, professional, administrative, or technical support functions for us, such as data storage, quality assurance, and marketing.
  • Legal compliance recipients. We disclose personal information to the courts, the government, law enforcement agencies, litigants, and similar recipients when required by law.
  • Successors. We may disclose personal information associated with a part of our business to a buyer, potential buyer, or other successor to our business.

We also may disclose personal information to third parties with your consent or at your direction.

Because no consensus has emerged on how to process a web browser’s “do not track” signal, we do not currently take any action in response to the signal. We also do not process the Global Privacy Control signal and do not presently fall within the scope of any legal requirement to do so.

3.  Security, quality, and retention

We use reasonable administrative, technical, and physical safeguards to protect personal information in our possession from misuse, interference, loss, unauthorized access, unauthorized modification, or unauthorized disclosure. Nevertheless, you should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be completely secure, accurate, complete, or current. 

We also take reasonable steps to ensure that the personal information we collect is sufficiently accurate, up-to-date, and complete for the purposes for which we process or disclose the personal information.

We retain personal information for as long as necessary for the purposes for which we use it, or longer if required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal information:

  • retention periods established under applicable law;  
  • industry best practices;  
  • whether the purpose of processing is reasonably likely to justify further processing;  
  • risks to individual privacy in continued processing;  
  • applicable data protection impact assessment;  
  • information systems design considerations/limitations; and
  • costs associated with continued processing, retention, and deletion.

In any event, we generally retain résumé information for individuals during their working lifetime.

4.  International users

If you use our Services from outside the United States, please be aware that your personal information will be stored and processed in the United States or in Germany, where our systems are located. If we transfer personal information to these jurisdictions from another jurisdiction, we will do so in a way that complies with any applicable legal requirements.

5.  Children’s privacy

Our Services are not directed to children, and we do not knowingly collect any personal information from those under the age of 18. If we discover (or are informed) that we have collected personal information from a visitor under the age of 18, we will promptly delete such information.

6.  Your privacy rights

Depending on the law in the State where you live, you may have certain rights regarding your personal information. To exercise your rights, please submit a request by contacting us through any of the means outlined below.

Your rights may include the following:

  • the right to opt-out of the use of personal information for targeted advertising, personal information sales, or profiling resulting in significant consequences (note, however, that we do not process personal information for any of these purposes);
  • the right to confirm whether we process your personal information and to access a copy (from which we may, for security purposes, exclude certain personal information), including a copy that is in a portable data format;
  • the right to the correction of inaccurate personal information;
  • the right to the deletion of your personal information; and
  • the right to appeal the action we take in response to any request to exercise these rights.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.

Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legally authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

You may also appeal the decision we make on your request by using the contact information below. When you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.

7.  Contacting Us

To exercise your rights or for other privacy-related inquiries, please contact us at:

 

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