Latest update: June 30, 2023

Privacy and General Data Protection Regulation (GDPR) Policy of WGA Consulting, LLC

This Website collects some Personal Data from its Users.

Personal Data collected for the following purposes and using the following services:

- Advertising
  - Google AdSense

Personal Data: Cookies and Usage Data

- Analytics
  - Google Analytics

Personal Data: Cookies and Usage Data

- Contacting the User
  - Contact form

Personal Data: email address, first name, last name, phone number and various types of Data

- - Phone contact

Personal Data: phone number

- Data transfer outside the EU
  - Data transfer to countries that guarantee European standards

Personal Data: various types of Data

- Heat mapping and session recording
  - Heat Maps & Recordings

Personal Data: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service

- Hosting and backend infrastructure

Personal Data: various types of Data as specified in the privacy policy of the service

- Location-based interactions
  - Geolocation

Personal Data: geographic position

- Managing contacts and sending messages
  - Email

Personal Data: Cookies, email address and Usage Data

Further information about Personal Data

- Privacy Notice

This Privacy Notice sets out the basis on which WGA Consulting, LLC will process personal information provided to us, this information is also referred to as ‘personal data’. This privacy notice applies to all WGA Consulting, LLC companies and all references to “we”, “us”, “our” and “ours” shall include all of our group of companies. We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. To ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you. We help individuals to find work and we are also an employer. Our core business activity is recruitment, we assist individuals in finding work with our hirer clients, whether this is directly or through supply by us, and we assist hirers in introducing or supplying the staff that they require. We also recruit staff to work for us to provide our Recruitment and Consulting Services. For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Recruitment and Consulting Services’, and our actual or potential hiring customers are referred to as ‘Clients’. The person responsible for data protection matters within our organization is the Managing Partners and they can be contacted by emailing info@wgaconsulting.com. If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us. Please refer to Section 4 ’Your rights‘, in respect of data that we already hold, or which we receive from third parties.

Section 1 This section applies to individuals wishing to use or using our Recruitment and Consulting Services or looking for a role to work with us (‘a Candidate’): The personal data we collect or receive includes the following as applicable: – Name – Address – Email and other contact details – Date of birth – Job history (including information relating to placements through us) – Educational history, qualifications & skills – Visa and other right to work or identity information – Passport – Bank details – National insurance and tax (payroll) information – Next of kin and family details – Contact details of referees – Personal information relating to hobbies, interests and pastimes – Information contained in references and pre-employment checks from third parties – Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below) – Your marketing preferences We may obtain your personal data from the following sources (please note that this list is not exhaustive): – You (e.g. a Curriculum Vitae/Résumé, application or registration form) – A client – Other candidates – Online jobsites – Marketing databases – The public domain – Social Media – At interview – Conversations on the telephone or video conferencing (which may be recorded) – Notes following a conversation or meeting – Our websites and software applications Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you. How we will use your personal data: The processing of your personal information may include: – Collecting and storing your personal data, whether in manual or electronic files – Notifying you of potential roles or opportunities – Assessing and reviewing your suitability for job roles – Introducing and/or supplying you to actual or potential Clients – Engaging you for a role with us or with our Clients including any related administration e.g. timesheets and payroll – Collating market or sector specific information and providing the same to our Clients – Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment and Consulting Services – Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers including insurers – To market our Recruitment and Consulting Services – Retaining a record of our dealings – Establishing quality, training and compliance with our obligations and best practice – For the purposes of backing up information on our computer systems

Why we process your personal data:

1. Entering into and performing a contract with you: In order to provide our Recruitment and Consulting Services we may enter into a contract with you and/or a third party. To enter into a contract, we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary to those obligations. For example, to process payroll, a national insurance number and bank details will be required.

2. Compliance with legal obligations (regulatory and statutory obligations): We must comply with several statutory provisions when providing our Recruitment and Consulting Services, which necessitate the processing of personal data. These include all employment and regulatory requirements in a given jurisdiction around the world, which amongst other things requires us to: – Verify your identity – Assess your suitability for an external job role – Maintain records for specific periods Where we engage a person to work for us (whether directly or as supplied to a Client), there are other statutory obligations that must be complied with including payroll, tax, social security, reporting requirements, and any other law or regulation. We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities.

3. Our legitimate interests (carrying on the commercial activity of Recruitment and Consulting Services): In providing our Recruitment and Consulting Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include: – Retaining records of our dealings and transactions and where applicable, use such records for the purposes of: — establishing compliance with contractual obligations with Clients or suppliers — addressing any query or dispute that may arise including establishing, exercising or defending any legal claims — protecting our reputation — maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach — evaluating quality and compliance including compliance with this Privacy Notice — determining staff training and system requirements – Using your personal data to: — assess suitability and contact you regarding potential opportunities and/or our services — collate market information or trends including providing analysis to potential or actual Clients — source potential opportunities or roles as part of our Recruitment and Consulting Services — personalize your experience and our offering, whether via our website or otherwise This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.

4. Consent to our processing of your data: We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason. You may withdraw your consent to our processing of your personal information for a purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

What if we obtain your personal data from a third party? Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organizations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged. Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however we may maintain a limited record to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment and Consulting Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Sensitive Personal Data (SPD) Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health. Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment and Consulting Services. This will be for one or more of the following reasons: – You have explicitly consented to the processing – For the purpose of our assessment of your suitability for job roles or working capacity – Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law – To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defense of any legal claims

Who we share personal data with: We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include: – Individuals, hirers and other third parties necessary for the provision of our Recruitment and Consulting Services – Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us – Parties who process data on our behalf, which may include: — outsourced payroll providers — IT support — storage service providers including cloud — background screening providers – Legal and professional advisers – Insurers

Automated decisions We do not use any automated decision making software.

Section 2 This section applies where you are an individual working for a third party with whom we have dealings. For example, a client or a payroll company.

We may collect your personal data in the course of our dealings and this may include the following: – Your contact information, which may include your full name, job role, contact telephone number and email – Your statements and opinions about candidates and/or other personnel e.g. a reference – Information relating to our relationship with you or the party for whom you work including records of any meetings or discussions – Your marketing preferences

We may obtain your personal data from the following sources (please note that this list is not exhaustive): – You, including where you have provided us with your contact details or other information for the purposes of using our Recruitment and Consulting Services – Staff or other representatives of the organization you represent – Candidates – Marketing databases – Social media – The public domain – Conversations, with you or others, on the telephone or video conferencing (which may be recorded) or in meetings – Notes following a conversation, with you or others, or meetings you attend

How we will use your personal data: We will process your personal data in the context of our dealings with the third party for whom you work and as part of our Recruitment and Consulting Services. Processing may include: – Collecting and storing your personal data, whether in manual or electronic files – Using the data to communicate with you – Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment and Consulting Services – Actions necessary to further any obligation on us pursuant to a contract between ourselves and the third party you work for – Collating market or sector specific information and providing the same to our clients – Providing information to regulatory authorities or statutory bodies and our legal or other professional advisers including insurers – Retaining records of our dealings with you and the organization whom you represent – Establishing quality, training and compliance with our obligations and best practice

Why we process your personal data:

1. Compliance with legal obligations (regulatory and statutory obligations): We must comply with several statutory provisions when providing our Recruitment and Consulting Services, which necessitate the processing of personal data. These include all regulatory requirements for every given jurisdiction we operate in, which amongst other things requires us to assess suitability of candidates and obtain information from Clients. We are also required to comply with statutory and regulatory obligations relating to business generally, for example tax, bribery and fraud/crime prevention legislation, and co-operating with regulatory authorities.

2. Our legitimate interests (carrying on the commercial activity of Recruitment and Consulting Services): In providing our Recruitment and Consulting Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include: – Using your personal data: — to contact you regarding our Recruitment and Consulting Services — to assess suitability of Candidates and roles, for example, referencing or other feedback — to collate market information or trends including providing analysis to potential or actual Clients — as otherwise necessary to provide our Recruitment and Consulting Services and/or to meet our obligations towards either the party whom you represent, or other Clients or suppliers — to personalize your experience and our offering, whether via our website or otherwise – Retaining records of our dealings and transactions and where applicable, use such records for the purposes of: — establishing compliance with contractual obligations with Clients or suppliers — addressing any query or dispute that may arise including establishing, exercising or defending any legal claims — protecting our reputation — maintaining a backup of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach — evaluating quality and compliance including compliance with this Privacy Notice — determining staff training and system requirements For our commercial viability and to pursue these legitimate interests, we may continue to process your personal information for as long as we consider reasonably appropriate for these purposes.

3. Consent We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you have provided your contact details in order that we may use these to provide you with details of our services you may have consented to our processing of the data for that purpose. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason, for example references. You may withdraw your consent to our processing of your personal data for a purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.

What if we obtain your personal data from a third party? Part of our business activity involves researching information for the purposes of finding and filling job roles. This may include obtaining personal data from sources including job boards, advertisements, LinkedIn or other social media, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal data about you from hiring organizations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged. Where information from third party sources is of no use to us we shall discard it, however we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment and Consulting Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.

Sensitive Personal Data (SPD) Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our dealings with you in respect of our Recruitment and Consulting Services. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health. Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that personal data for the purposes of our relationship with you or for the provision of our Recruitment and Consulting Services. This will be for one or more of the following reasons: – You have explicitly consented to the processing – Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law – To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defense of any legal claims

Who we share personal data with: We shall not share your personal data unless we are entitled to do so. The categories of persons with whom we may share your personal information include: – Candidates and other third parties necessary for the provision of our Recruitment and Consulting Services – Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us – Parties who process data on our behalf, which may include: — outsourced payroll providers — IT support — storage service providers including cloud providers — background screening providers] – Legal and professional advisers – Insurers

Section 3: This section applies to all personal data.

Data storage We store data on servers at Microsoft Office 365 located in the United States, UK, and other geographies around the world. These servers are secure and backed-up in an offsite facility.

Access to data by WGA Consulting, LLC’s Employees WGA Consulting, LLC have physical offices in the United States. WGA Consulting, LLC’s employees have access to the data we store to provide Recruitment and Consulting Services.

Transfer of data to other jurisdictions In the course of the provision of our Recruitment and Consulting Services we may transfer data to countries or international organizations outside of the countries where we have physical offices. This may, for example, be to Clients or Candidates, or third parties who provide support services to us. Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place. Details relating to specific countries or organizations are available on request by emailing info@wgaconsulting.com.

If you do not wish to provide us with necessary data There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or perform our Recruitment and Consulting Services. If you do not wish to provide us with information we request, then please notify us. However, please be aware that as a result we may be unable to provide you or the party who you represent with a Recruitment Service, and in some cases may result in a breach of the contract we have with you or a third party you represent.

Data transfer In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to this Privacy Notice and any processing being only in accordance with this Privacy Notice.

Data Security and Confidentiality It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorized third parties in line with contemporary practice

Retaining your data In most circumstances your data will not be retained for more than 6 years from the last point at which we provided any services or otherwise engaged with you and it is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period. If you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons. Please see Section 4 ‘Your Rights’ below.

Changes to this Privacy Notice This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you.

Section 4: Your rights We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to: – Request a copy of the personal data that we hold – Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data – Request that we restrict processing of your data in certain circumstances – Request that data is erased where the continued use of that data cannot be justified – Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process – Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations – Request that inaccurate or incomplete data is rectified – Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract – Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimize the prospect of any data being processed in the future should it be received again from a third party source. If you have any questions concerning your rights or should you wish to exercise any of these rights please email info@wgaconsulting.com.

Complaints If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter by emailing info@wgaconsulting.com. This does not affect your right to make a complaint to the Information Commissioner’s Office.

- Website Hosting

The websites created by WGA Consulting LLC are hosted on servers managed by Bluehost (www.bluehost.com) and Microsoft Office 365 (www.microsoft.com). The data you share with us by using WGA Consulting, LLC websites may be temporarily stored on a website content management system database. This enables us to securely transfer data submitted when using our websites to our central database.

- Personal Data collected through sources other than the User

The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing. Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

Contact information

- Owner and Data Controller

WGA Consulting, LLC inclusive of: 3780 Kilroy Airport Way Ste 870

Long Beach CA, 90806

Owner contact email: info@wgaconsulting.com

Restrictions on use

This site is owned and operated by WGA Consulting, L.L.C. (WGA) and contains material which is derived in whole or in part from material supplied by WGA and other sources. The material on this site is protected by international copyright and trademark laws. You may not modify, copy, reproduce, republish, upload, post, transmit, or distribute in any way any material from this site including code and software. You may download material from this site for your personal, non-commercial use only, provided you keep intact all copyright and other proprietary notices.

License to WGA

By posting messages, uploading files, inputting data, or engaging in any other form of communication through this service, you are granting WGA a royalty-free, perpetual, non-exclusive, unrestricted, worldwide license to:

Use, copy, sublicense, adapt, transmit, publicly perform or display any such communication.

Sublicense to third parties the unrestricted right to exercise any of the foregoing rights granted with respect to the communication.

The foregoing grants shall include the right to exploit any proprietary rights in such communication, including but not limited to rights under copyright, trademark, servicemark or patent laws under any relevant jurisdiction.

Disclaimer

WGA has provided links, content, information and pointers to Internet sites maintained by third parties. Neither WGA, its parent or subsidiary companies, nor their affiliates operate or control in any respect any information, products or services on these third-party sites. The materials in this site and the third-party sites are provided “as is” and without warranties of any kind either express or implied. To the fullest extent permissible pursuant to applicable law, WGA disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose. WGA does not warrant that the functions contained in the materials will be uninterrupted or error-free, that defects will be corrected, or that this site, including bulletin boards, or the server that makes it available, are free of viruses or other harmful components. WGA does not warrant or make any representations regarding the use or the results of the use of the materials in this site or in third-party sites in terms of their correctness, accuracy, timeliness, reliability, or otherwise. You (and not WGA) assume the entire cost of all necessary maintenance, repair, or correction.

Limitation of liability

Under no circumstances, including, but not limited to, negligence, shall WGA, its subsidiary and parent companies or affiliates be liable for any direct, indirect, incidental, special or consequential damages that result from the use of, or the inability to use, WGA materials. You specifically acknowledge and agree that WGA is not liable for any defamatory, offensive or illegal conduct. If you are dissatisfied with any WGA material, or with any of WGA’s terms and conditions, your sole and exclusive remedy is to discontinue using WGA.

Notices and Procedure for Making Claims of Copyright Infringement

Pursuant to Title 17, United States Code, Section 512(c)(2), notifications of claimed copyright infringement should be sent to: Contact@wgaconsulting.com ALL INQUIRIES NOT RELEVANT TO THE FOLLOWING PROCEDURE WILL RECEIVE NO RESPONSE.

Termination

This agreement is effective until terminated by WGA, at any time without notice. In the event of termination, you are no longer authorized to access the bulletin boards and the restrictions imposed on you with respect to material downloaded from the bulletin boards, the disclaimers and limitations of liabilities set forth in this agreement, shall survive.

Governing Law

This agreement shall be governed by and construed in accordance with the laws of the State of California without giving effect to any principles or conflicts of law. If any provision of this agreement shall be unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from this agreement and shall not affect the validity and enforceability of any remaining provisions.

WGA Consulting, LLC (“us”, “we”, or “our”) operates www.wgaconsulting.com (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.

We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

Information Collection And Use

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name (“Personal Information”).

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”).

This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this data.

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information.

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Changes To This Privacy Policy

This Privacy Policy is effective as of 5/24/2018 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

If you have any questions about this Privacy Policy, please contact us info@wgaconsulting.com.