Last modified: 1/26/24 

Introduction

This Privacy Policy (“Policy”) outlines how Bucher & Christian Consulting, Inc. d/b/a BCforward and its subsidiaries, affiliates, other related entities, successors, and/or assigns (“BCforward”, “we”, “us”, or “our”) collect, use, and share your information.  This Privacy Policy applies to our website, https://www.bcforward.com (“Website”), the Portal (“Portal”), the Payfwd mobile application, the provision of our services and products, and your communications with us by e-mail, telephone, and in person (collectively, our “Services”). This Policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by BCforward or any third party or 
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Policy.  This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. 

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under the age of 18 may provide any information to the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or the Portal or use any of the Services. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].  

Information We Collect About You and How We Collect It

BCforward collects, uses and stores personal information for our Services related to recruiting, placement, employment, and consulting. We collect several types of information from and about users of our Services, including information or data by which you may be personally identified or any other identifier by which you may be contacted online or offline (“Personal Information”), including, but may not be limited to: 

• 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. 
• Additional Data Subject to Cal. Civ. Code § 1798.80: 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.
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
• Employment Information: professional or employment-related information and history (CV/resume/job application), Current or past performance evaluations, salary history, background check forms and results, job interview notes, candidate evaluation records, retirement information/planning.
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
• Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Protected classification characteristics under California or federal law: Age (40 years or older), race, color, national origin, citizenship, marital status, physical or mental disability, sex, gender, gender identity, gender expression, sexual orientation, veteran or military status.
• Biometric information: Identifying information, such as fingerprints, iris scans, and related information.
• Geolocation Data: Physical location or movements. 
• Audio, electronic, visual, thermal, olfactory: Information such as surveillance footage.
• Inferences: 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.

We may also collect information that is about you but individually does not identify you, including, but may not be limited to:

• publicly available information, general geographic location (e.g., country and city)
• aggregate or de-identified information 
• information collected through cookies; and/or information about your internet connection, the equipment you use to access our Website, the Portal, or the App and usage details.

We collect this information:

• Directly from you when you provide it to us through your use of the Services, including, but not limited to, submitting job applications or engaging with us for work, and individuals placed through our recruitment services. 
• Automatically as you navigate through the Website or Portal. 
• From third parties, for example, our customers, business partners, or service providers regarding your engagement in connection with our Services.

BCforward may also collect Personal Information about you from your use of third parties’ services and/or third-party websites whose privacy practices may differ from the practices described in this Policy. Your use of third-party services and/or third-party websites, including information collected from you or that you may provide to the BCforward website operated by WorkLLama, is governed by and subject to the terms and conditions of those third parties and/or third-party websites. We do not make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available through third parties. We encourage you to carefully review the privacy policies and statements of such third parties and/or third-party websites.

Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with BCforward’s Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website or the Portal, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website or the Portal.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website or the Portal.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate settings on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 
• CrazyEgg: BCforward uses CrazyEgg to obtain information on how visitors are interacting with specific BCforward web pages. This allows BCforward to evaluate and, if necessary or beneficial, to modify its websites to improve value and usability. The data CrazyEgg collects includes information about how visitors navigate a web page and the most commonly clicked links on a specific web page. CrazyEgg does not collect personally identifiable information. The CrazyEgg Privacy Policy is available at http://www.crazyegg.com/privacy.
• Google Analytics. BCforward also uses Google Analytics as a tool for tracking and analyzing its web traffic.  Google Analytics runs on the forward server and uses a combination of first-party cookies and JavaScript code to compile information that is synthesized into reports about page visits, referring sites, user habits, and the like.  Google is not provided access to any user information other than IP addresses.  

Google has created an “Opt-out Browser Add-on” for users who wish to use websites while preventing their data from being accessed or used by Google Analytics.  If you want to opt out of the features on the Website that rely on Google Analytics, please follow the directions provided by Google here: https://tools.google.com/dlpage/gaoptout/ features. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Services and related content to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for employment or other applicable engagement with the Services.
• To notify you about changes to our Website, the Portal, or the Services.
• To allow you to participate in interactive features on our Website.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-party goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual without restriction. For more information, see Choices About How We Use and Disclose Your Information. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of BCforward’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by BCforward about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of BCforward, our customers, or others. 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information: 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Please consult your browser’s documentation to learn how. Note that certain portions of the Website may not operate as intended if you refuse certain cookies.
• Promotional Offers from BCforward. If you do not wish to have your email address/contact information used by BCforward to promote our own products or services, you can opt out by using the UNSUBSCRIBE feature in the email you receive from BCforward, which will remove you from future email distributions. This opt-out does not apply to information provided to BCforward as a result of activity on the Website.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. 

Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We also use the Secure Sockets Layer (SSL) protocol to protect information when routed between your browser and our Website. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  Unfortunately, the transmission of information via the Internet is not completely secure. While we have industry-standard security controls in place, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Retention

We will retain your personal data for periods mandated or allowed by law in accordance with our evolving retention policies. The duration of this retention is influenced by several factors, including the necessity to keep data for business purposes such as service provision, record maintenance, website performance and quality enhancement, addressing user inquiries or complaints, and identifying issues. Additionally, the retention period may be extended if the user consents, if the data is deemed necessary for potential legal matters, or if there are specific legal, contractual, or equivalent requirements for data retention.

International Data Protection Rights

If you live in Canada or India, your Personal Information may be transferred to countries outside of your own, including to the United States, where data protection regulations may differ. We ensure compliance with applicable data protection laws when transferring data internationally. Additionally, in specific circumstances, we may need to disclose Personal Information in response to lawful requests from authorities like law enforcement or security agencies. Depending on the jurisdiction and data protection laws that are applicable, you may have additional rights pertaining to the following:

• Access and Transparency. You have the right to request information about the data we hold on you, including the types of data collected, the purpose of its processing, and with whom it is shared.
• Erasure and Control. You have the right to request the deletion of your personal data, particularly when it is no longer needed or if you withdraw your consent, barring exceptions for legal or public interest reasons.
• Processing Limitations. You can restrict how your data is processed, including setting limits on its use and who can access it.
• Objection and Choice. You have the right to object to certain uses of your data, such as direct marketing, profiling, and automated decision-making based on your data, with options available for you to easily opt-out.
• Data Portability and Ownership. You are entitled to receive your data in a structured, machine-readable format, facilitating its transfer to other service providers if you wish.
• Consent and Withdrawal. You can withdraw your consent for data processing at any time and will be informed about the consequences of this action.
• Complaint and Accountability. If you believe your data rights have been violated, you can file a complaint with the data protection board or agency of your jurisdiction.

You are not required to pay any charge for exercising your rights. Please contact us at the information provided below if you wish to exercise your rights with respect to your personal data. We will review your request in accordance with applicable laws and regulations and respond as appropriate. Please be aware that under certain circumstances, applicable laws may limit your exercise of these rights. 

California Resident Privacy Rights

This section is our Privacy Notice for California Residents (“Notice”). This Notice is provided to comply with the “CCPA,” and any terms defined in the CCPA have the same meaning when used in this Notice. Scope This California Notice applies to the Personal Information we collect, both online and offline, about California consumers, including Personal Information that we collect:

• from users of our Services, including the services available via our Website or the Portal;
• about clients and individuals who use or inquire about the that we make available;
• about employees, contractors or job applicants;
• about individuals acting in their capacity as representatives of our customers, prospective customers, vendors and other businesses that we conduct business with only in the context of conducting our business relationship with the respective business;
• about individuals who otherwise communicate or engage with us; or
• about individuals from customers and others related to the services we provide.

This California Notice does not address or apply to:

• Our handling of Personal Information that is exempt under Section 1798.145 of the CCPA or
• Personal information we collect about individuals who are not California residents.

Disclosure of Personal Information We may disclose and have disclosed Personal Information to third parties in the past 12 months for business purposes as set forth in this Policy. In the preceding twelve (12) months, we have not sold Personal Information. The following is a list of the categories of personal information we have collected from and about California residents over the twelve months prior to the last updated date provided herein and the business and/or commercial purpose for its collection:   We will only collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes if we provide you with notice.

California Privacy Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. Your CCPA rights include the following: 

• Right to Access: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months, which includes:
  • The categories of Personal Information we collected about you;
  • The categories of sources for the Personal Information we collected about you;
  • Our business or commercial purpose for collecting or selling that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The specific pieces of Personal Information we collected about you (also called a data portability request);
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • Sales, identifying the Personal Information categories that each category of recipient purchased; and
    • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
• Right to Data Portability: You have the right to request a copy of your Personal Information in a portable, readily usable format to be transmitted to another entity without hindrance.
• Right to Correct Inaccurate Information: You have the right to request that we correct any inaccurate Personal Information we maintain.
• Right to Deletion: You have the right to request that we delete any Personal Information we collected from you and retained, subject to certain exceptions.
• Right to Be Free from Discrimination: You have the right not to be discriminated against by us for exercising your rights under the CCPA. Unless permitted by the CCPA, we will not:
  • Denying goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services;
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services or 
  • Retaliate against an employee, applicant for employment, or independent contractor, as defined in the CCPA, for exercising their rights under this title.

Additional California Privacy Rights

California’s “Shine the Light” law permits California resident users to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. Please see the “Contact Information” section below to make such a request.

Verifiable Consumer Requests and Opting Out

In addition to the CCPA, many jurisdictions in the United States have enacted comprehensive data privacy laws that include resident consumer rights. To exercise your rights under such laws, please submit a verifiable consumer request by contacting us with the information below. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail, allowing us to understand, evaluate, and respond appropriately.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require creating an account with us. However, we consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Please be aware that certain data privacy laws may limit your exercise of these rights under certain circumstances.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to do the following:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) or similar laws.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically at your option. Any disclosures we provide will only cover the 12 months preceding the receipt of the verifiable consumer request. Our response will also explain why we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We only charge a fee to process or respond to your verifiable consumer request if it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opting Out of BCforward Communications 

If you would like to opt out of receiving emails or other communications directly from us, you may do so by following any instructions in the email or other communication or by contacting us at the contact information listed below. Please note that although you may opt out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Website, as permitted under the CAN-SPAM Act. Opting out of our communications or modifying, updating, or deleting your Personal Information will not result in modifying, updating, or deleting any Personal Information that may reside in backup or disaster-recovery storage.

Updating Your Information

If you are a user who has a registered account with the Services, you can review and change some of your Personal Information by logging into the Services and visiting your account details page or contacting us at the information below.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by providing notice in advance of such change by highlighting the change on our Website and by direct notification upon login. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: 

• By email: [email protected]
• By phone: 1-844-467-7300
• By mail: ATTN: Compliance Manager, BCforward, 9777 N College Ave, Indianapolis, IN 46280