Introduction At Distinct Company, we value and protect the privacy of our users. This policy outlines how we collect, use, store, and protect your personal data in compliance with: • General Data Protection Regulation (GDPR) in the European Union. • State Privacy Laws in the United States, including: o California Consumer Privacy Act (CCPA) in California. o Virginia Consumer Data Protection Act (VCDPA) in Virginia. o Colorado Privacy Act (CPA) in Colorado. o Connecticut Data Privacy Act (CTDPA) in Connecticut. o Utah Consumer Privacy Act (UCPA) in Utah. • Law 1581 of 2012 and Decree 1377 of 2013 in Colombia, which establish the general principles and guidelines for the protection of personal data in Colombia, ensuring the proper treatment and protection of personal information. • Distinct Company is committed to adhering to these legal frameworks to ensure that your personal data is handled responsibly and transparently, regardless of where you are located. Distinct Company is committed to adhering to these legal frameworks to ensure that your personal data is handled responsibly and transparently, regardless of where you are located. 1. Introduction The purpose of this Privacy Policy is to outline how Distinct Company collects, uses, stores, and protects personal data entrusted to us by our users. Our commitment to safeguarding privacy is at the core of our operations, ensuring compliance with applicable data protection laws and regulations. This policy applies to all users, including customers, employees, and candidates submitting resumes, ensuring transparency and accountability in our data handling practices. 2. Definitions For the purposes of this policy, the following definitions apply: • Personal Data: Any information that can identify an individual directly or indirectly, including but not limited to names, email addresses, identification numbers, and online identifiers. • Sensitive Data: Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning an individual’s sexual orientation. • Data Subject: The individual to whom personal data relates. • Data Controller: Distinct Company, which determines the purposes and means of processing personal data. • Data Processor: A third party that processes personal data on behalf of the Data Controller. • Processing: Any operation performed on personal data, including collection, storage, use, transfer, or deletion. 3. Principles of Data Processing Distinct Company adheres to the following principles when processing personal data: 1. Lawfulness, Fairness, and Transparency: Personal data is processed in a lawful, fair, and transparent manner. Users are informed of the purposes and methods of data collection. 2. Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes. 3. Data Minimization: Only the data necessary for the specified purpose is collected and processed. 4. Accuracy: Data is kept accurate and up-to-date. Reasonable steps are taken to rectify or delete inaccurate data without delay. 5. Storage Limitation: Data is retained only as long as necessary for the purposes for which it was collected or as required by applicable law. 6. Integrity and Confidentiality: Personal data is processed in a manner that ensures its security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage. 7. Accountability: Distinct Company is responsible for and can demonstrate compliance with these principles. 4. Information We Collect Distinct Company collects the following types of personal data: 1. Reviews: User-generated content such as feedback, ratings, and comments. 2. User Data: Names, contact details (e.g., email addresses, phone numbers), preferences, and location data. 3. Resume Information: Academic qualifications, professional experience, skills, and any additional details provided by the user in their curriculum vitae (CV). 5. Purpose of Data Processing We process personal data for the following purposes: • Reviews: To analyze user feedback, improve services, and provide responses to user concerns. • User Data: To personalize services, communicate updates, and enhance user experience. • Resume Information: To manage recruitment processes, evaluate candidates, and maintain records of hiring activities. 6. Legal Basis for Processing Distinct Company processes personal data based on the following legal grounds: 1. Consent: When users explicitly agree to the collection and use of their data for specific purposes. 2. Contractual Necessity: When processing is required to fulfill a contract with the user. 3. Legal Obligations: To comply with applicable laws and regulations. 4. Legitimate Interests: When processing is necessary for the legitimate interests of Distinct Company, provided these interests do not override the rights of the data subject. 7. Data Retention and Security We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. Distinct Company employs robust security measures, including encryption, access controls, and regular audits, to safeguard personal data against unauthorized access, alteration, or destruction. 8. Data Subject Rights Users have the following rights regarding their personal data: 1. Access: The right to request and obtain a copy of their personal data. 2. Rectification: The right to correct inaccurate or incomplete data. 3. Deletion: The right to request the deletion of their data when it is no longer necessary for processing. 4. Objection: The right to object to processing based on legitimate interests. 5. Portability: The right to request transfer of their data to another organization. Requests to exercise these rights can be made by contacting Distinct Company’s Data Protection Officer (DPO). 9. International Data Transfers Distinct Company may transfer personal data to countries outside the user’s region, ensuring adequate safeguards are in place as required by applicable data protection laws. 10. Cookies and Tracking Technologies We use cookies and similar technologies to enhance user experience, track website usage, and provide personalized content. Users can manage their cookie preferences through browser settings or our cookie management tool. 11. Recruitment and Resume Handling Resume information is processed solely for recruitment purposes. Data of candidates not selected is retained for a defined period as per legal and organizational requirements and then securely deleted. 12. Contact and Complaints For inquiries, complaints, or to exercise data subject rights, please contact our Data Protection Officer: Email: privacy@distinctcompany.com 13. Policy Updates This policy is reviewed periodically to ensure compliance with legal requirements and best practices. Updates will be communicated to users through appropriate channels.
Effective Date: June 20, 2025, midnight
Form Name: contact
Key Features of the Policy • Ensures full transparency regarding the use of resumes and professional data. • Complies with GDPR (European Union), CCPA (California, USA), VCDPA (Virginia, USA), CPA (Colorado, USA), CTDPA (Connecticut, USA), UCPA (Utah, USA), NRS 603A (Nevada, USA), 201 CMR 17.00 (Massachusetts, USA), NY SHIELD Act (New York, USA), BIPA (Illinois, USA), and Colombian Law 1581 of 2012. • Provides users with control over their data and clear channels for consent withdrawal or deletion. Policy Amendment: Contact and Processing of Course Information Requests Data Collected When a user submits the course contact form on our platform, we collect the following information: 1. Identification and Contact Information: o Full name. o Email address. o Phone number (optional). o Company (optional). 2. Request Details: o Selected course. o Free-text message describing needs or questions (optional). 3. Technical and Metadata: o IP address (for security and audit). o Browser/device user agent. o Timestamp of the request and consent.