At Dresden Free Partners, Inc., (“Dresden Partners”) we are dedicated to offering nearshore staffing and recruitment services. At “Dresden Partners” we care about your privacy, therefore through this Privacy Policy we outline how we collect, use, disclose, store, and protect your “Personal Information”, collected through your interaction with us; including through our website www.dresdenpartners.com (the “Site”), and any other means defined below. 

The aim of this Privacy Policy is to ensure that you understand the “Personal Information” and “Sensitive Information” we collect from you, the purposes for which we collect it, how we use it,  how we share it, how we protect it, and your rights in connection to the “Personal Information” and “Sensitive Information” we collect and process about you. 

By using our services, you consent to the practices described in this policy. 

1 Data Controller

Dresden Free Partners, Inc, is a Delaware corporation headquartered in California, with a registered address at 2173 Salk Ave, Suite 250, Carlsbad, 92008, and telephone number + 1 858 703 06103. For the purpose of the General Data Protection Regulation (“GDPR”), “Dresden Partners”, is the data controller of your “Personal Information” and “Sensitive Information”, unless expressly specified otherwise.  

2 Definitions 

For the means of this Privacy Policy, “Dresden Partners” will understand “Personal Information” and “Sensitive Information ” as defined below

• Personal Information: any data relating to an identified or identifiable individual 
• Sensitive Information: also known as special category data, is any type of data or information that, if compromised, can result in harm, privacy violations, or whose potential misuse can lead to discrimination or serious risk for its owner. Sensitive data includes race, ethnicity, religion, sexual orientation, health and medical information, gender identity, political opinions, and criminal history. 

 3 How we collect your Personal Information 

The “Personal Information” and “Sensitive Information”  we collect from you to comply with the purposes described below are collected in the following ways

• Register, or complete or submit information or forms through this Site
• Through our employees by phone, verbally, or by email
• Through public access sources such as profiles on social networks, among others.
• During in-person or online meetings
• Through our Live Chat
• Purchase or use “Dresden Partners” services

Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our Site or sites of third parties. For more information on cookies and similar technologies, please visit our Cookies Policy.

4 Categories of Personal Information and Specific Pieces of Personal Information we collect from you

We have collected within the last twelve (12) months and may collect in the future the following categories of Personal Information listed below from consumers, for commercial and/or business purposes under the California Consumer Privacy Act of 2018 (“CCPA”)

• Identifiers and registration contact information: such as full name, email address, postal address, telephone number, official identification number, unique personal identifiers, or other similar identifiers. 

• Customer records information: such as full name signature, address, telephone number, official identification number, education history, employment history, bank account number, and other financial information.

• Characteristics of protected classifications under California or federal law: such as age, gender, national origin, marital status, and citizenship.

• Records of commercial information: such as delivery information, services purchased, obtained, or considered, and transactions made with us.

• Internet or other electronic network activity information: device information and device identifiers, browsing type and language, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement, and data connection and use, such as information you download.

• Geolocation data: Physical location.

• Inferences: such as a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

•  Professional or employment-related information: such as current or past job history, and performance evaluations

5 How we use your Personal Information

“Dresden Partners” uses the “Personal Information” and “Sensitive Information” we collect from you for the following business purposes including but not limited to 

• From the applicants: to identify and contact the applicant, create a file as a candidate or job applicant, consider and evaluate the candidate for a vacancy offered by “Dresden Partners”, carry out the recruitment, selection, and placement procedure, verify the information provided by the candidate, validate academic data, request and corroborate personal and work references, if required, carry out socioeconomic studies, make a comparison between the compensation and current salary of the candidate, carry out studies and psychometric evaluations, carry out interviews, If necessary, create a job offer, an individual employment contract and create a work file.

• From actual or potential clients: provide our nearshore staffing and recruitment services of specialized personnel, provide technological support services, provide specialized services, provide personnel augmentation services, provide human resources administration and management services, send information regarding our services, submit quotes regarding our services, make a record in our customer database, make commercial contracts and comply with the obligations that we have acquired by those contracts, make and manage invoices.

We collect your “Personal Information” and “Sensitive Information” for the following commercial purposes

• From the applicants: To keep you in our database, to be considered for future vacancies, to contact you to offer you open vacancies that match your profile, marketing, and mailing.

• From clients or potential clients: Marketing, mailing, and commercial prospecting.

At any moment, you can withdraw your consent to process your  “Personal Information”. For this, you must send a request to the following email address: dataprivacy@dresdenpartners.com.

6 Cookies and Web Beacons

Our website automatically collects certain data through cookies and web beacons, among others. These tools, automatically collect the following information

• Technical information: such as browser type, operating system, device information, online identifiers including cookie data and Internet Protocol address (IP), domain name, referral URL, time zone setting, and/or time-stamp for your visit, information about your devices.
• Usage information: such as geographic location information (such as your country and/or state), date and time you visited our Site, numbers and frequency visitors to our Site, page views and search queries, and clickstream behaviors, amongst others. 

You can delete or remove all cookies that are already on your device by clearing the browsing history or by following the procedures of cookie settings in your preferred browser.

To learn more visit our Cookies Policy.

7 Legal basis for collecting and processing personal information

“Dresden Partners” collects and processes your “Personal Information” and/or  “Sensitive Information” based on different legal grounds, depending on the nature of the “Personal Information” and/or “Sensitive Information” provided and the purpose of the collection. 

• Performance of a contract: Some of your “Personal Information” and/or “Sensitive Information” collected and processed by us is necessary for the performance of an agreement with you, for example; celebrating a job contract with “Dresden Partners” and/or a third party.

• Legal Obligation: We collect and process your “Personal Information” and/or “Sensitive Information” to comply with various laws, for example, employee information required by diverse governmental bodies.

• Legitimate interest: Processing “Personal Information” and/or “Sensitive Information” is necessary for legitimate interests pursued by us or by you. For example,  when you request more information about our services, pricing, and quotes, as well as for internal administrative operations such as payroll. 

• Consent: In certain limited situations, we will request your express consent to use your “Personal Information” and/or “Sensitive Information” for the purposes described in this Privacy Policy for example; to apply for a third-party job vacancy. 

8 Data Sharing and Disclosure 

In the preceding 12 months, and to comply with the business and commercial purposes described in this Privacy Policy, we have disclosed “Personal Information” and/or “Sensitive Information” to third parties. The categories of third parties with whom we share personal information are

During the past 12 (twelve) months we have disclosed the categories of “Personal Information” and/or “Sensitive Information” about you listed above for our business and commercial purposes. We have not, however, sell your Personal Information and/or “Sensitive Information” to third parties and shall not sell your “Personal Information” and/or “Sensitive Information” to third parties.

9 Your Rights 

Under current privacy laws and regulations, CCPA and the General Data Protection Regulation (GDPR), you possess certain rights in relation to your “Personal Information” and “Sensitive Information” as follows

9.1 Under the GDPR

• Right of access: you can request a copy of the “Personal Information” and/or “Sensitive Information” we have collected and processed about you.

• Right to rectification: you can request to correct any incomplete or inaccurate information concerning you.

• Right to erasure: you can request to delete or remove any “Personal Information” and/or “Sensitive Information” we have collected and processed about you.

• Right to restriction of processing: you can request to suspend the use of your “Personal Information” and/or “Sensitive Information”, temporarily or permanently.

• Right to data portability: you have the right to request a copy of your “Personal Information” and/or “Sensitive Information” in electronic format and the right to transmit your data to another controller.

• Right to object: you have the right, at any time, to object to us processing your “Personal Information” and/or “Sensitive Information” on grounds relating to your particular situation, and the right to object to your “Personal Information” and/or “Sensitive Information” being processed for direct marketing purposes.

• Right not to be subject to automated decision making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you want to exercise any of the above-mentioned rights, please email us at dataprivacy@dresdenpartners.com.  

9.2 Under the CCPA

Sections 3, 4, and 5 of this Privacy Policy describe the categories of “Personal Information” and/or “Sensitive Information” we collect, use, and disclose, and have collected, used, and disclosed for the preceding 12 (twelve months); and the sources from which we obtain each category, and the purposes for which we obtain such information.

If you are a resident of the state of California, USA, be advised that you may exercise the following additional rights under the CCPA 

• Right, to Know: You have the right to request information about the categories and specific pieces of “Personal Information” and/or “Sensitive Information” we have collected about you in the past 12 months, as well as the sources of that information.

• Right to Delete: You have the right to request the deletion of your “Personal Information” and/or “Sensitive Information” collected or maintained by us.

• Right to Opt-Out: You have the right to opt out of the sale of your “Personal Information” and/or “Sensitive Information”. As stated earlier, we do not sell personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

If you want to exercise any of the above-mentioned rights, please email us at dataprivacy@dresdenpartners.com.  

10 How to Exercise Your Rights

10.1 Under the CCPA

You may exercise any of your rights under the CCPA  by submitting a verifiable request to the following email address dataprivacy@dresdenpartners.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your “Personal Information”. You may also make a verifiable consumer request on behalf of your minor child.

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 you are the person about whom we collected personal information or an authorized representative.
•  Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 the “Personal Information” relates to you. 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 note that we may require additional information to verify your identity and process your request. We will respond to your request within 45 days of receiving it, as required by the CCPA. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons 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.

10.2 Under the GDPR

To exercise your rights under the GDPR, please submit your request to the following email address dataprivacy@dresdenpartners.com. The request must include 

• Name and address, and any other means to communicate a response
• Documents proving your identity
• The clear and precise description of the specific privacy rights you wish to exercise in your request}
• In the case of rectification requests, you must indicate the modifications to be made
• The documentation that supports your request

Please note that we may require additional information to verify your identity and process your request. We will respond to your request within 30 days of receiving it, as required by the GDPR. Upon receiving your request, we will provide you with information regarding the actions taken in response to your request electronically. If your request is granted, we will provide you with the requested information or make the necessary amendments as per your instructions.

11 Data retention and deletion

We will keep your “Personal Information” and/or “Sensitive Information” as long as necessary to fulfill the purposes described herein. Upon your request, we will delete your “Personal Information” and/or “Sensitive Information”, unless we are legally permitted to or required to keep certain data, for example, to fulfill a legal obligation or to resolve a dispute, etc.

12 Security

At “Dresden Partners” we have implemented the security, technical, administrative and physical measures necessary to ensure the integrity of your “Personal Information” and/or “Sensitive Information”, and prevent its damage, loss, alteration, destruction or the use, access or unauthorized treatment. Only authorized personnel, who have complied with and observed the corresponding confidentiality requirements, may participate in your treatment.

12.1 Data Breaches

Despite our best efforts to secure your information if we suffer a data breach, we will do our best to reduce its effects and will follow the applicable notification provision of the CCPA and GDPR and any other applicable laws.

13 Sales of Personal Information or Right to Opt-out the sale of your Personal Information

The CCPA gives California residents the right to opt out from the sale of “Personal Information”. We do not sell, exchange for money, or other considerations of your “Personal Information” to third parties. We share information with third parties who work with us, as explained in previous sections, for the purposes described herein. However, should you prefer for us not to sell your “Personal Information”, please contact us at the following email address dataprivacy@dresdenpartners.com to opt out of the future sale of your “Personal Information”.

14 Children’s Privacy 

Our services are not intended for children under the age of 13. We do not knowingly collect personal information from children. If you believe a child has provided us with “Personal Information”, please contact us immediately at the following email address  dataprivacy@dresdenpartners.com to delete it.

15 Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes via a prominent notice on our website. Please review the policy periodically to stay informed about how we handle your data.

Dresden Partners reserves the right to modify and update this Privacy Policy at any time without previous notice. Any changes will be notified by placing a prominent notice on this Site. 

16 Contact Us 

 If you have any questions, requests, comments, and/or concerns regarding this Privacy Policy, please contact us at the following e-mail address dataprivacy@dresdenpartners.com.