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Privacy Policy

Click here for the Bright Sky Privacy Policy

 

Aspirant Privacy Statement

 

1. Terms of Use

Aspirant Consulting, LLC wants you to have a positive experience using our website, respects your privacy and is committed to protecting it. This document explains our policies and practices regarding on-line survey participant information. It is through this document that we intend to provide you with information on the use of our website as well as a level of comfort and confidence in how we collect, use, and safeguard personally identifiable information (if captured) and other data that is collected or that you provide through this survey, and how you can contact us if you have any questions or concerns.

 

2. The business purpose of this website

a. The purpose of the Aspirant website is to share details with the public on the services provided by Aspirant.

b. The website also provides an option for a potential client or employee to enter information to stay in touch and join our email list service for marketing purposes.

c. A separate policy covers our Digital Discovery® assessment and Bright Sky.

 

3. Confidentiality

a. By entering your information into the “Let’s Connect” section, you are granting Aspirant the right to process your information as a potential client. You consent to receive emails until you unsubscribe from such marketing materials.

b. Data Security: We take reasonable steps to protect information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have put in place physical, electronic, and managerial procedures to safeguard and secure information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. We cannot guarantee the security of information on or transmitted via the internet.

 

4. If personally identifiable information is used

General use of the website will not require personally identifiable information to be used or gathered.

a. “Let’s Connect”: If you request further information by entering your name and email, you consent to the processing of that information.

b. Employment Application: Personally Identifiable Information is gather through our employment application.   This information is used for employment decisions.

 

5. How aggregate or non-personally identifiable information is collected from website visitors

We also collect non-personally identifiable information (also referred to as "non-personal information" or "aggregate information") from website visitors. We collect this information on an aggregate/anonymous basis. Non-personal information collected includes tracking the website pages that are visited or the amount of time spent on this website.

Our primary goal in collecting aggregate information is to be able to perform website metrics that allow us to improve the website. We need to collect aggregate/anonymous information for the following reasons, including but not limited to, tracking page visits and peak website usage times.

 

6. How aggregate or non-personally identifiable information is used

Non-personally identifiable information we collect may be used to:

  • Compile aggregate and statistical data to help in website design and to identify popular features
  • Measure website activity to enable us to update our website to better meet user wants and needs
  • Make the website visitor experience more customer friendly
  • We may utilize non-personally identifiable information for the purpose of performing analytics on the users' experience while visiting this website. This analysis may be performed:
    • on an aggregate level and does not identify you or your information personally
    • by a third-party vendor acting on behalf of Aspirant
    • to improve the user experience

Any information that is provided to a third-party vendor is to be used only for the purpose of performing the analytics and compiling reports of the data. The third-party vendor is restricted from using this data in any other way other than to provide these services to Aspirant and they may not share or resell this data.


7. Sharing your information

Other than pseudonymized analytics, we share the information we collect with third parties in limited situations. Specifically:

  • Service Providers: We share your personal information with service providers to support our Services. These companies provide services such as: applicant tracking, authentication systems, payment processing, and electronic signature. We have contracts with our service providers that address the safeguarding and proper use of your personal information.
  • Affiliates: We may share your personal information with other companies under common ownership or control with Aspirant. These companies use your personal information as described in this Notice.
  • Consent: We may share your personal information in other ways if you have asked us to do so or have given consent.

The data that is shared outside the European Union is shared pursuant to the terms set out in the standard contractual clauses or Model Clauses drafted by the EU Commission.

 

8. Processing of personal data

  • Collection of personally identifiable information happens when a user enters their information into the “Let’s Connect” form. It will be handled in compliance with this Privacy Statement and our Data Retention Policy.
  • Collection of personally identifiable information happens when a potential employee enters their information into Careers page. It will be handled in compliance with this Privacy Statement and our Data Retention Policy.

By visiting this website and by providing your personally identifiable information to us, you understand and consent voluntarily to the collection, use, processing, transfer, and disclosure of any personally identifiable and non-personally identifiable information globally, including but not limited to the United States, in accordance with this Privacy Statement.

While it is unlikely that this information will be transferred outside of the United States, by visiting this website and by providing such information, you consent to the transfer of such information across country borders, including but not limited to the use, processing, and disclosure of such information to global locations as required.

All data retention is subject to certain conditions detailed in the Aspirant Data Retention Policy.

 

9. Intended geography

In the instance that personal identifiable information is shared between the United States of America and the European Union, it is shared pursuant to certain approved data transfer frameworks.

 

10. Legal bases for using your personal information

There are different legal bases that we rely on to use your personal information provided via the Website, namely:

  • Performance of a contract - The use of your personal information may be necessary to allow you to use the Website.
  • Consent – You provide consent to the processing of your data.

 

11. Your choices and rights

You have certain rights regarding your personal information. Every user is entitled to the following:

  • The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service, based on the administrative costs of complying with the request if the request is manifestly unfounded or excessive; or if an individual requests further copies of their data following any such request.

  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we to complete the information you believe is incomplete.

  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions, detailed at https://gdpr.eu/article-23-restrictions/.

  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions, detailed at https://gdpr.eu/article-23-restrictions/.

  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions, detailed at https://gdpr.eu/article-23-restrictions/.

  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions, detailed at https://gdpr.eu/article-23-restrictions/.

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12. Sensitive data / demographic data

We do not collect sensitive personally identifiable information through the public facing Aspirant website.

a. Demographic data is gathered on an optional basis through our standard employment application.

 

13. Limitation of liability

a. Disclaimers. While it is in Aspirant's interest to provide you with a great experience when using the Website (and we love to please our customers), there are certain things we do not promise about them. We try to keep our Website up, but they may be unavailable from time to time for various reasons. EXCEPT AS EXPRESSLY PROVIDED IN THESE TERMS AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICES AND ANY GUIDANCE OR RECOMMENDATIONS THEREIN ARE PROVIDED "AS IS" AND ASPIRANT DOES NOT MAKE WARRANTIES OF ANY KIND, EXPRESS, IMPLIED, OR STATUTORY, INCLUDING THOSE OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT OR ANY REPRESENTATIONS REGARDING AVAILABILITY, RELIABILITY, OR ACCURACY OF THE SERVICES.

b. Exclusion of Certain Liability. TO THE EXTENT PERMITTED BY APPLICABLE LAW, ASPIRANT, ITS AFFILIATES, OFFICERS, EMPLOYEES, AGENTS, SUPPLIERS, AND LICENSORS WILL NOT BE LIABLE FOR (A) ANY INDIRECT, CONSEQUENTIAL, SPECIAL, INCIDENTAL, PUNITIVE, OR EXEMPLARY DAMAGES WHATSOEVER, OR (B) LOSS OF USE, DATA, BUSINESS, REVENUES, OR PROFITS (IN EACH CASE WHETHER DIRECT OR INDIRECT), ARISING OUT OF OR IN CONNECTION WITH THE SERVICES AND THESE TERMS, AND WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, EVEN IF ASPIRANT HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IF A REMEDY FAILS OF ITS ESSENTIAL PURPOSE.

c. Limitation of Liability. TO THE EXTENT PERMITTED BY APPLICABLE LAW, THE AGGREGATE LIABILITY OF EACH OF ASPIRANT, ITS AFFILIATES, OFFICERS, EMPLOYEES, AGENTS, SUPPLIERS, AND LICENSORS ARISING OUT OF OR IN CONNECTION WITH THE SERVICES AND THESE TERMS WILL NOT EXCEED THE GREATER OF: (A) THE AMOUNTS PAID BY YOU TO ASPIRANT FOR USE OF THE SERVICES AT ISSUE DURING THE 12 MONTHS PRIOR TO THE EVENT GIVING RISE TO THE LIABILITY; AND (B) US $200.

 

14. Changes to this privacy notice

We may amend this Notice to reflect changes in the law, our companies, our Services, our data processing practices, or advances in technology. Our use of the personal information we collect is subject to the Privacy Notice in effect at the time such personal information is used.

 

15. Children's privacy

Our services are not designed for and are not marketed to people under the age of 18 or such other age designated by applicable (“minors”). We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your personal information. We delete personal information that we learn is collected from a minor without verified parental consent. Please contact us via legal@aspirant.com if you believe we might have information from or about a minor that should be removed from our system.

 

16. Regional privacy notice

In addition to the other information and rights described in this Privacy Notice, certain states have additional requirements for their residents. This area of the law is fluid and rapidly changing in the United States. This portion of the notice explains how we collect, use, and disclose your Personal Information. It also describes how you can exercise your rights under the following US Privacy Laws, pursuant to their effective dates:

  • California Consumer Privacy Act (effective January 1, 2020) and California Privacy Rights Act (fully operative January 1, 2023;
  • Colorado Privacy Act (effective July 1, 2023);
  • Virginia Consumer Data Protection Act (effective January 1, 2023);
  • Utah Consumer Privacy Act (effective December 31, 2023);
  • Oregon Consumer Privacy Act (effective July 1, 2024);
  • Texas Data Privacy and Security Act (effective July 1, 2024);
  • Montana Consumer Data Privacy Act (effective October 1, 2024);
  • Delaware Personal Data Privacy Act (effective January 1, 2025);
  • Iowa Consumer Data Protection Act (effective January 1, 2025);
  • Tennessee Information Protection Act (effective July 1, 2025); and
  • Indiana Consumer Data Protection Act (effective January 1, 2026).

If you are not a resident from those states, this section does not apply to you and you should not rely on it.

Subject to certain exceptions and depending on where you live, you may have some or all of the following rights:

a. Right to access 

You have the right to request certain details about the personal information we have collected about you (generally, within the past 12 months). This includes the right to request:

  • The specific pieces of personal information and the categories of personal information that we have collected about them.
  • What categories of personal information we sold or disclosed for business purposes and the categories of third parties to whom we sold or disclosed that information for a business purpose.
  • The categories of sources from which we collected personal information.

b. Right to request deletion

You have the right to request that we delete the personal information we have collected from you. In certain circumstances, however, we are allowed to retain information for particular purposes (for example, if we need to retain the information to meet our legal obligations, and for certain other limited reasons set forth by the US Privacy Laws).

c. Right of portability

You have the right to request that the personal information about you be disclosed in a common file format.

d. Right of Data Correction

You have the right to request that we correct inaccurate Personal Information that we maintain about you.

e. Right to Opt Out of Targeted Advertising

Digital Discovery does not utilize targeted advertising.

f. Right to Opt Out of Sales of Personal Information

Digital Discovery does not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes, except where the Personal Information was gathered through an Engagement with a company as described at the start of such Engagement.

g. How to Exercise Access, Portability, Correction, and Deletion Rights

You may submit requests for access to or deletion of their personal information by emailing legal@aspirant.com.

For security purposes, we will attempt to verify your identify prior to fulfilling your request. We may need to respond to your request or otherwise contact you to request additional information from you to verify your identity(including, but not limited to your name, email address, or telephone number).

If we are able to verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you or we may deny your request. If we are unable to fulfill your request(s) in their entirety, we will provide further information to you about the reasons that we could not comply with your request.

Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information for certain features of the Website. If you ask us to delete it, you may no longer be able to use those features.

h. The Right to Nondiscrimination

You have the right not to be discriminated against for exercising your rights. We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to those consumers who choose to exercise their rights.

i. Automated Decision Making

Your data is not used for automated decision making.

j. Authorized Agents

You may designate an agent to make data requests on your behalf. For a consumer chooses to do so, we will take steps to verify both the identity of the consumer seeking to exercise their rights as described above, and to verify that the consumer’s agent has been authorized by them to make a request on their behalf by requesting a signed written authorization or a copy of a power of attorney.

k. “Shine the Light”

We do not utilize Personal Information for direct marketing purposes. Under certain US Privacy Laws, residents may ask for a list of third parties that have received your personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. If you would like to request this information, please contact us at legal@aspirant.com.

17. Contacting us

If you make a request, we have one month to respond to you. We have engaged GDPR Local as our EU Article 27 GDPR Representative and our UK Representative. Data Subject Requests are facilitated through their online web portal.

Web Portal:

EU: https://aspirantltd.gdprlocal.com/eu

UK: https://aspirantltd.gdprlocal.com/uk

Address:

EU: INSTANT EU GDPR REPRESENTATIVE LIMITED Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland

UK: GDPR Local Ltd 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

If you have any questions, comments, or concerns about this online privacy statement or have any questions regarding the contents of this website, please contact us at:

Aspirant

Nova Tower 1, One Allegheny Square, Suite 502

Pittsburgh, PA 15212

legal@aspirant.com

 

18. How to contact the appropriate authorities (Europe)

You also have the right to make a complaint to the appropriate authorities. By country they are as follows:

Austria: Österreichische Datenschutzbe-hörde - dsb@dsb.gv.at

Belgium: Autorité de la protection des données – Gegevensbeschermingsautoriteit - https://www.autoriteprotectiondonnees.be/ or https://www.gegevensbeschermingsautoriteit.be/

Bulgaria: Commission for Personal Data Protection – https://www.cpdp.bg

Croatia: Croatian Personal Data Protection Agency – http://www.azop.hr

Cyprus: Commissioner for Personal Data Protection – http://www.dataprotection.gov.cy

Czech Republic: The Office for Personal Data Protection - www.uoou.cz

Denmark: Datatilsynet – http://www.datatilsynet.dk

EDPS: https://edps.europa.eu

Estonia: Estonian Data Protection inspectorate (Andmekaitse Inspeksioon): http://www.aki.ee

Finland: Office of the Data Protection ombudsman: http://www.tietosuoja.fi/en

France: Commission Nationale de I’lnformatique et des Libertés – CNIL - https://www.cnil.fr/en/contact-cnil

Poland: Urząd Ochrony Danych Osobowych (Personal Data Protection Office) - https://uodo.gov.pl/

Germany: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit: http://www.bfdi.bund.de/

Greece: Hellenic Data Protection Authority – http://www.dpa.gr

Hungary: Hungarian National Authority for Data Protection and Freedom of Information – http://www.naih.hu

Iceland: Persónuvernd – https://www.personuvernd.is

Ireland: Data Protection Commission – http://www.dataprotection.ie

Italy: Garante per la protezione dei dati personali: http://www.garanteprivacy.it/

Latvia: Data State Inspectorate – https://www.dvi.gov.lv

Liechtenstein: Data Protection Authority, Principality of Liechtenstein – https://www.datenschutzstelle.li

Lithuania: State Data Protection Inspectorate – https://vdai.lrv.lt

Luxembourg: Commission Nationale pour la Protection des Données – http://www.cnpd.lu

Malta: Office of the Information and Data Protection Commissioner – http://www.idpc.org.mt

Netherlands: Autoriteit Persoonsgegevens – https://autoriteitpersoonsgegevens.nl

Norway: Datatilsynet – https://www.datatilsynet.no

Poland: Urząd Ochrony Danych Osobowych (Personal Data Protection Office) - https://uodo.gov.pl/

Portugal: Comissão Nacional de Proteção de Dados – CNPD – http://www.cnpd.pt

Romania: The National Supervisory Authority for Personal Data Processing – http://www.dataprotection.ro

Slovakia: Office for Personal Data Protection of the Slovak Republic – http://www.dataprotection.gov.sk

Slovenia: Information Commissioner of the Republic of Slovenia – https://www.ip-rs.si

Spain: Agencia Española de Protección de Datos (AEPD) – https://www.aepd.es

Sweden: Integritetsskyddsmyndigheten – http://www.imy.se

United Kingdom: Information Commissioner's Office: www.ico.org.uk/concerns/

 

19. Supplemental privacy disclosures for certain countries

IF you reside in one of the following countries, the below Privacy Notice also applies to the processing of your personal information. To the extent there is a conflict between the country-specific language below and the provisions above, the below provisions control to the extent of that conflict.

a. Canada: Transfers to the U.S. and Third Countries. We may transfer your personal information outside of your jurisdiction for further processing where it will be subject to that foreign jurisdiction’s law.

 

20. Version

The terms of use and privacy statement may be updated from time to time to reflect changes.

Version Updated by Dates
Initial Creation Legal June 5, 2013
Version 2 Legal January 17, 2019
Version 3 Legal October 10, 2023