Privacy Policy

Updated May 7th 2020

Introduction

This Privacy Policy outlines how Bucher & Christian Consulting, Inc. d/b/a BCforward and its subsidiaries, affiliates, other related entities, successors, and/or assigns (“BCforward”, “Company”, “we”, “us”, or “our”) collect, use, and share your information.  This Privacy Policy applies to our website, https://www.bcforward.com (“Website”), the TalentForward Portal (“Portal”), the provision of our services and products (“Products”), and your communications with us by e-mail, telephone, and in person.

Please read this Privacy Policy carefully.  The practices described herein are subject to the applicable laws in the places in which we operate.

BY ACCESSING AND/OR USING OUR WEBSITE, PORTAL, OR COMMUNICATING WITH US IN ANY WAY, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

What Type of Information Do We Collect About You?

Personal Information

is generally non-public information that can be used to directly or indirectly identify or contact you.  Personal information may have a different definition depending on the applicable laws.  Examples of personal information we may collect from you and about you include, but may not be limited to:

  • Name, alias, or social media handle
  • Date of birth
  • Unique online identifier
  • Online username and password
  • Postal and/or e-mail address
  • Username and password
  • Demographic information, such as occupation, education and experience, and if you choose to provide it age, gender, and/or race and ethnicity
  • Job search behavior and preferences, and a record of the searches you make on the Website and/or Portal
  • Account name and/or account number
  • Social security number
  • Driver’s license number
  • Passport number
  • State identification number
  • Bank, credit, or debit card number
  • Financial information
  • Insurance policy number
  • Biometric information
  • License plate information
  • Current or past employment history (CV/resume/job application)
  • Current or past performance evaluations
  • Education information
  • Retirement information/planning
  • Immigration status
  • Family details, including marital status
  • Health information
  • Salary history
  • Background check forms and results
  • Job interview notes
  • Candidate evaluation records


Non Personal Information

is any other type of information.  Example of non-personal information we may collect from or about you include, but may not be limited to:


  • Publicly available information
  • General geographic location (e.g., country and city)
  • Aggregate or de-identified information
  • Browser type and version
  • Browser settings
  • Browser plug-in types and versions
  • Operating systems and platform
  • Device type and operation information
  • Mobile carrier
  • Page response time and download errors
  • Time zone
  • Zipcode

How Do We Collect Your Information?

Directly From You

We may collect your personal and non-personal information directly from you or your agents when you or your agent access or use our Website, Portal, or Products, or when you or your agent communicate with us in any manner, including but not limited to:

  • Information you or your agent provide by filling forms on our Website or Portal;
  • Information you or your agent provide when you access or use our Products;
  • Information you or your agent provide from phone calls with recruiters;
  • Information you or your agent provide when you fill-out onboarding documents;
  • Information you provide when you report a problem with our Website, Portal, or Products;
  • Records and copies of your correspondence (e.g., email address) if you contact us;
  • Your responses to surveys we may ask of you;
  • Details of transactions you carry out through our Website, Portal, and the fulfillment of your orders; and
  • Your search queries on the Website and Portal.

Automatically

We may collect your personal and non-personal information automatically when you access or use our Website or Portal, or when you communicate with us, including but not limited to

  • Details of your visits to the Website and Portal, including traffic data, location data, logs and other communication data;
  • Information about your computer and mobile device, and internet connection, including your IP address, operating system, and browser type; and
  • Interactivity with an e-mail, including opening, navigating, and click-through information.

From Third Parties

We may collect your personal and non-personal information from third parties, including business partners and affiliates, including but not limited to:

  • Third parties that provide your personal information to initiate engagement and placement on assignment with the third party, or to re-integrate you with a third party for placement;
  • Third parties that assist us with payroll operations, benefits administration, and other human resource functions;
  • Statistical data relating to your Website or Portal activity;
  • Social media profile information and activity, including your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social medial platform;
  • Transactional histories with third parties; and
  • Information from public sources, including local, state, and federal government agencies and departments.

How Do We Use Your Information?

We may collect your personal and non-personal information to:

  • Create and manage your account;
  • Integrate you with a third party to procure employment;
  • Operate, evaluate, and improve our Website, Portal, and Products;
  • Operate, evaluate, and improve our business;
  • Comply with laws and regulations;
  • Comply with relevant industry standards;
  • Comply with our policies;
  • Protect you, ourselves and other users against unlawful activity, including identity theft and fraud;
  • Protect and enforce your rights, our rights and other users’ rights under any agreements we’ve entered  into with you, other users or third parties;
  • Maintain the security of our Website, Portal, and Products;
  • Complete and facilitate invoicing requests for payment;
  • Providing you with information and advertisements about products, services, and promotions, from us or third parties, that may interest you; and
  • Facilitate other marketing activities.

How Do We Share Your Information?

We may collect your information about you in the following ways:

  • With your consent. We may disclose your personal information to a third-party with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of use for our Website, Portal, or Products; orally, either in person or on the phone; or by other means.
  • In a business transfer. As we continue to develop our business and service offerings, we may sell, buy, restructure, or reorganize businesses or assets. In the event of any sale, merger, reorganization, restructuring, dissolution, or similar event involving our business or assets, your personal information may be part of the transferred assets.
  • To service providers. We may disclose your personal information to third-party vendors and partners who complete transactions or perform services on our behalf (e.g., invoice processing,  customer service, auditing, marketing).
  • To subsidiaries and affiliates. We may disclose your personal information to subsidiaries and affiliates to further facilitate your use of our Website, Portal, or Products, and to ensure the smooth and consistent operations of BCforward.
  • For legal process and protection. We may disclose your personal information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
    • Enforce or apply agreements, or initiate, render, bill, and collect on invoices;
    • Protect our rights or interests, property or safety or that of others;
    • In connection with disputes, or litigation – in court or elsewhere;
    • Protect users of our Website, Portal, and Products and other providers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
    • Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or
    • In case of an emergency.

Links to Third Party Sites

Our Website and Portal may contain links to third-party websites and services.  For example, BCforward Talent Network is provided by Career Builder LLC.  Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review.  This Privacy Policy applies to our Website, Portal, Products, and your communications with us only, and we do not accept any responsibility or liability for the policies or practices of any third parties.

Third- Party Tracking | Do Not Track

Our Website and Portal may, from time to time, collect information about your online activities, over time, and across different websites and applications.  When you use our Website and Portal, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications.  Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit.  Our Website and Portal do not currently change the way they operate based upon the detection of a “Do Not Track” or similar signal.

Social Media Integration

Our Website and Portal may, from time to time, contain links to and from social media platforms.  You may choose to connect to us through a social media platform.  When you do, we may collect additional information from or about you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform.  Please be advised that social media platforms may also collect information from you.  We do not have control over the collection, use, and sharing practices of social media platforms.  We, therefore, encourage you to review their usage and disclosure policies and practices, including their data security practices, before using the social media platforms..

How Do We Store and Protect Your Personal Information ?

The security of your personal information is important to us.  That is why we take commercially reasonable steps to make sure your personal information is protected.  Although no system can guarantee the complete security of your personal information, we will use our best efforts to maintain commercially reasonable technical, organizational, and physical safeguards, consistent with applicable law, to protect your information.

How Long Do We Keep Your Personal Information?

We keep your personal information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and our legal and regulatory obligations.  If we dispose of your personal information, we will do so in a way that is secure and appropriate to the nature of the information subject to disposal.

Cookie Statement

We may use cookies (browser and flash), beacons, pixel tags, scripts, and other similar technologies from time to time to support the functionality of our Website and Portal.  This technology provides a better experience when you use our Website and Portal and allows us to improve our services.  We may also use analytic software, such as Google Analytics and others, to help better understand how our Website and Portal function on your device(s) and for other analytical purposes.

Our service providers, advertising partners, and ad networks may also use cookies and beacons to collect and share information about your activities both on our Website and Portal and on other websites and applications. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Website and Portal. We do not have control over these third party collection practices. If you wish to minimize these third-party collections, you can adjust the settings of your browsers or install plug-ins and add-ins.

Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. You may use the tools available on your computer or other device(s) to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Website and Portal. Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Website and Portal.

Flash Cookies. Certain features of our Website and Portal may use locally stored objects called flash cookies to collect and store information about your preferences and navigation to, from and on our Website and Portal. We also include cookies to provide aggregate reporting. Some portion of our Website and Portal may allow Adobe to set and enable special cookies that are necessary to deliver video content for Adobe Flash Player. You cannot remove flash cookies simply by changing your browser settings. If you would like to limit the websites that can store information in flash cookies on your device, you must visit the Adobe website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Beacons. Our Websites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings, and web pages. You may use the tools in your device to disable these technologies as well.

Your Choices

We provide you the ability to exercise certain controls and choices regarding our collection, use, storage, and sharing of your personal information.  In accordance with applicable law, your controls and choices may include:

  • Correcting or updating your personal information;
  • Choosing or changing your choices for subscriptions, newsletters, and alerts;
  • Choosing whether to receive from us offers and promotions for our Products, or Products we think may be of interest to you;
  • Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services;
  • Controlling targeted advertising from many ad networks and partners, data exchanges, and marketing analytics and digital advertising and marketing service providers. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance or the Network Advertising Initiative, both of which maintain websites where people can opt-out of interest-based advertising from their members. To opt-out on these pages, visit www.AboutAds.info and www.networkadvertising.org;
  • Choosing to control targeted advertising you receive within Website and Portal by using the settings and choices made available to you through your device(s) (e.g., by resetting your device’s advertising identifier and/or opt-out of interest-based ads).

Your California Rights (California Residents Only)

If you are a California resident, you have certain rights under California law.

California Consumer Privacy Act (CCPA)

Under the CCPA, you have a right to know how we collect, use, and disclose your personal information.  The CCPA defines personal information as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular  consumer or household.  All phrases used under this heading have the same meaning as those phrases are defined under the CCPA.

CCPA Rights – Overview

Right to Know. As a California resident, you have the right to request that we disclose:

  • The categories of personal information we have collected about or from you;
  • The categories of sources from which we collected that personal information, and the business or commercial purpose for which we collected the information;
  • The categories of third parties with whom we have shared your personal information, and the business or commercial purpose for said sharing; and 
  • The specific pieces of personal information collected.

Right to Delete.  As a California resident, you have a right to request that we delete your personal information.  However, please note we may be permitted to retain certain personal information necessary to complete the transaction for which the information was collected, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair errors, and for other reasons as articulated in California Civil Code § 1798.105(d).

Right to Opt-Out.  We do not sell your personal information and do not plan to do so in the future.

Right to Non-Discrimination.  As a California resident, you have a right to exercise your rights under the CCPA without suffering discrimination.  We will not discriminate against you in any way if you choose to exercise your rights hereunder.

CCPA Rights – Instructions on Submitting a Request

Right to Know and Delete.  To submit a request to know or delete, you may click here, send an e-mail to support@bcforward.com, or call us toll-free at 1-844-467-7300.  You may also designate an authorized agent to submit a request on your behalf by clicking here or calling us at 1-844-467-7300 and then also submitting written proof of such authorization via e-mail to support@bcforward.com.  Please note that to protect your personal information and prevent against fraud, we will verify your identity before responding to your request by matching the information provided in your request with the information we have on file about you, and depending on the sensitivity of information requested utilizing more stringent verification methods, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.

CCPA Disclosures

Personal Information Collected

The following is a list of the categories of personal information we have collected from and about California resident over the twelve months prior to the last updated date provided herein, and the business and/or commercial purpose for its collection:

Categories of personal information collected Categories of sources from which we collect the information Purpose for Collection
Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agent. Our customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Facilitating leaves of absence requests. Facilitating requests for accommodation. Facilitating payroll. Ensuring the administration of benefits for you and your dependents. Obtaining emergency contact information. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging and repairing errors that impair existing functionality of internal resources and databases
Categories of personal information described in California Civil Code § 1798.80(e) not otherwise listed above, such as signature, physical characteristics or description, insurance policy number, education, employment, employment history, bank account number, credit card number, or any other financial information, medical information, or health insurance information. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Facilitating leaves of absence requests. Facilitating requests for accommodation. Facilitating payroll. Ensuring the administration of benefits for you and your dependents. Obtaining emergency contact information. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging and repairing errors that impair existing functionality of internal resources and databases
Characteristics of protected classifications under California or federal law, such as race, religious creed, color, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, or military and veteran status. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Processing your onboarding documents. Facilitating leaves of absence requests. Facilitating requests for accommodation. Facilitating payroll. Ensuring the administration of benefits for you and your dependents. Obtaining emergency contact information
Commercial information, such as quote history, claims history, and other purchasing or consuming histories or tendencies. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Facilitating leaves of absence requests. Facilitating requests for accommodation. Facilitating payroll. Ensuring the administration of benefits for you and your dependents
Biometric information, such as fingerprints, iris scans, and related information. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Facilitating leaves of absence requests. Facilitating requests for accommodation. Facilitating payroll. Ensuring the administration of benefits for you and your dependents. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging and repairing errors that impair existing functionality of internal resources and databases
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for youReferring you for a job opportunity with BCforward on assignment with BCforward’s clientsProcessing your onboarding documentsDetermining your eligibility for promotions and/or other job status changesDetecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activityDebugging and repairing errors that impair existing functionality of internal resources and databases
Geolocation data Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging and repairing errors that impair existing functionality of internal resources and databases
Audio, electronic, visual, thermal, olfactory, or similar information, such as surveillance footage. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activityDebugging and repairing errors that impair existing functionality of internal resources and databases
Professional or employment-related information. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Facilitating leaves of absence requests. Facilitating requests for accommodation. Facilitating payroll. Ensuring the administration of benefits for you and your dependents. Obtaining emergency contact information. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging and repairing errors that impair existing functionality of internal resources and databases
Education information under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99). Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging and repairing errors that impair existing functionality of internal resources and databases
Inferences drawn from the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Directly from you or your authorized agent (e.g., in person, over the phone, over email, your completion of online forms)Indirectly from you or your authorized agentOur customers (e.g., businesses to whom we provide services)Our service providers (e.g., partners that process personal information on our behalf)Other third parties (e.g., suppliers, screening vendors, job boards) Providing potential job opportunities for you. Referring you for a job opportunity with BCforward on assignment with BCforward’s clients. Processing your onboarding documents. Determining your eligibility for promotions and/or other job status changes. Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
Personal Information Sold

We have not sold the personal information about California residents in the past twelve months.

Personal Information Disclosed for a Business Purpose

In the preceding twelve (12) months, BCforward has disclosed the above categories of personal information to the following categories of third parties for a business purpose:  (1) service providers; and (2) third parties to whom the individual or the individual’s agent directs or authorizes BCforward to disclose personal information.

California Minors

If you are a California resident under the age of 18, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information you have publicly posted on any of our Websites. To make such a request, please send an email with a detailed description of the specific content or information to support@bcforward.com with the subject line “CALIFORNIA MINOR CONTENT REMOVAL REQUEST.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow removal even if requested.

Minors

The Website and Portal are not intended for the collection of data of any individuals under the age of 18.  BCforward does not knowingly collect the personal information of individuals under the age of 18.  No information for individuals under the age of 18 should be provided through the Website or Portal.

Communications

If an individuals’ personal information is received by BCforward through the Portal, he/she can reasonably be expected to be contacted by email, phone, or postal mail for the following purposes:

  • To initiate the pre-integration process;
  • To initiate the integration process;
  • To initiate the re-integration process; and/or,
  • Approve, reject, or confirm details about a submitted invoice.

Future Changes to the Privacy Policy

BCforward may update this privacy policy from time to time.  The updated version will be indicated by an updated revision date and the updated version will be effective as soon as it is accessible.  If BCforward makes material changes to this privacy policy, BCforward will notify individuals either by prominently posting notice of such changes or by directly sending notification of such changes to individuals.  BCforward encourages individuals to review this privacy policy frequently to be informed of how the company is protecting personal information.

Contact

Any individual with questions or comments about this privacy policy is encouraged to contact BCforward:

  • By email: support@bcforward.com
  • By phone: 1-844-467-7300
  • By mail: ATTN: Compliance Manager, BCforward, 9777 N College Ave, Indianapolis, IN 46280