Arch Staffing

Committed to protecting the personal data we process and adhering to international recognized principles regarding privacy and/or personal data protection, at ARCH STAFFING & CONSULTING we have adopted actions that allow us to comply with this commitment; therefore, through this Privacy Policy, we inform you of the information regarding the existence and main characteristics of the processing to which your personal will be submitted.

ARCH STAFFING & CONSULTING is commercially known as a provider of services related to the search and management of human capital, which operates through various legal entities located in the United States of America, specifically in the state of Florida and California, as well as in Canada (in the state of Ontario). By virtue of the foregoing, we issue and adhere to this Privacy Policy that complies with the internationally recognized standards. However, in the case of the application of a particular standard related to privacy and/or protection of personal data, we will make a specific reference to it.

I. Identity and address of the responsible person for data processing.

In accordance with the legal entity that provides the services and/or that is related to you, we inform you that the Responsible person for the processing of the personal data you provide is:

1. Arch Staffing & Consulting located at LLC 1000 Brickell Ave., Ste 725, Miami, FL 33131,
2. Arch California LLC located at 777 E Tahquilz Canyon Way Ste 200-45, Palm Springs, CA 92262, o
3. ARCH Staffing and Consulting Canada Corporation located at Toronto Office, Suite 5600, 100 King Street West, Toronto, ON M5X 1C9.

The aforementioned legal persons are commercially known as ARCH STAFFING & CONSULTING, hereinafter referred to as “ARCH” or “Data Controller.”

II. Definitions

1. Personal data.- All information concerning an identified or identifiable natural person or individual. An identifiable natural person or individual is considered as any person whose identity can be directly or indirectly determined.
2. Sensitive personal data.- Personal data that affect the most intimate sphere of its Holder, or whose improper use may give rise to discrimination or entail a serious risk for him/her.
3. Holder.- The natural person or individual to whom the personal data identifies or corresponds.
4. Data controller.- Each legal person mentioned in section I hereby, who will be responsible for the individual and independent processing.
5. Processing.- Any operation or set of operations conducted on personal data, whether by automated procedures or not, such as obtaining, registering, organizing, structuring, using, handling, exploiting, communicating, transferring, disposing of, disclosing, storing, keeping, adapting, modifying, extracting, consulting, or destroying personal data.
6. Privacy Policy.- The instrument hereby, through which the Data Controller informs and makes transparent to the Holder, whose personal data is processed, the conditions under which such personal data will be processed.
7. Transfer.- Any data communication that will be made to a person different that the Data Controller, in which case, the third-party recipient becomes the new Data Controller for the processing of the personal data.
8. ARCO rights.- Right of Access, Rectification, Cancellation and Opposition of personal data. Such rights are defined as follows: (i) the right of access, understood as the prerogative that the holders have to know their personal data, as well as the conditions or generalities of processing it; (ii) the right of rectification, understood as the prerogative that the holders have to request the rectification of personal data that prove to be inaccurate or incomplete; (iii) the right of cancellation, understood as the prerogative that the holders have to request the cessation of the processing when they consider that it is not being legally processed, so it will have to be blocked (only stored for the time allowed by law or defined by the Data Controller to determine possible responsibilities regarding their processing until the legal or contractual limitation period); and (iv) the right of opposition, understood as the prerogative that the holders have to refuse the processing of their data for secondary purposes.
9. Primary Purposes.- Those purposes for which personal data are mainly requested and for which the relationship between the Data Controller and the Holder is originated.
10. Secondary Purposes.- Those purposes that are not essential for the relationship between the Data Controller and the Holder.

III. Collected personal data.

In order to fulfill the purposes indicated in the instrument herein, the Data Controller will process the following personal data:

a) Job candidates: Personal data in the categories of identification, contact, work, academic, skills, and aptitudes are processed. If required, due to the required profile according to the published job vacancy, sensitive personal data will be processed regarding its origin, location, assets, and health.

b) Employees of the staffing service (who provide their assigned services to ARCH clients) and staff employees (who provide direct services for the development of operational or substantive activities of ARCH): Personal data in the categories of identification, contact, work, skills, and aptitudes are processed. If required, for the employment to be developed, sensitive personal data will be processed regarding their origin and, where appropriate, immigration location, assets, and economic, legal and health situation.

c) Third parties related to job candidates and employees (family members or work or personal references: Personal data in the categories of the identification, contact and employment are processed. If required, sensitive personal patrimonial data will be processed, in the event that an employee must pay any amount of money and such payment obligation is executed through ARCH.

d) Clients: Personal data in the categories of identification, work, contact, where applicable, are processed. On the other hand, if required, sensitive private property data will be processed.

e) Suppliers: Personal data in the categories of identification, employment, contact, and location are processed. On the other hand, sensitive personal data will be processed for the purpose of paying goods or services provided to ARCH.

f) General public: Personal data in the categories of identification, contact, and work are processed.

IV. Purposes for processing your personal data.

The Responsible person will process your personal data for the following purposes:

a) Job candidates: Your personal data will be processed for the following primary purposes:

Verify and confirm your identity;

Verify if the profile published for the vacancy in question is met;

Make available technological tools to search for job vacancies, in which you can indicate comments or feedback regarding the application process or the provision of professional services;

Provide you with information on vacancies related to your search settings;

Conduct planning activities aimed at having you present yourself for the interviews required to validate your profile;

Identify you as a candidate for a published vacancy;

Contact you to inform you of the status of the recruitment procedure;

Schedule appointments for validation interviews of your profile with that of the vacancy published and/or for which you applied;

Conduct and evaluate the results of the exams or tests that are required according to the profile in question;

Inform you of the status of the procedure derived from your interviews with ARCH’s client;

Where appropriate, validate your health, habits, and behaviors, as well as their reliability, being able to visit you at home for interviews.

Your data will be processed to coordinate planning activities to execute such purposes, as well as analyze the results and evaluate them with respect to the position for which you applied.

Know and verify the environment in which you develop;

Gather and collect information to know the behavior and working conditions of the candidate;

Where appropriate, conduct actions to perform the hiring procedures as an employee.

Additionally, we will use your personal data for the following secondary purpose:

Contact you for subsequent vacancies in which your profile adapts to the requested requirements, to offer you a job.

b) Staffing service employees (who provide their assigned services to ARCH clients) and staff employees (who provide their direct services for the development of ARCH’s operational or substantive activities): Your personal data will be processed for the following primary purposes: Carry out the necessary documentation for your hiring; Verify that the data contained in the documentation of your hiring is correct; Locate you to communicate and execute actions that must be carried out for your hiring; Carry out the activities aimed at their contracting, management and http://www.archstaffingandconsulting.com/wp-content/uploads/2022/05/Thumbnail-1-446×446-1.jpegistration rights and/or benefits to which they are entitled; Register you in systems to carry out actions aimed at personnel http://www.archstaffingandconsulting.com/wp-content/uploads/2022/05/Thumbnail-1-446×446-1.jpegistration, including payroll payment; Compose, manage, consult, file, control and safeguard your employee file; Provide employment references to third parties; Identify situations of particular attention to ARCH clients to propose, execute and follow up on corrective actions; Compliance and documentation of ARCH’s labor obligations; Contact or locate you, by any means indicated by you, to communicate any emergency or urgent situation related to you or derived from the employment relationship with the Responsible person.

On the other hand, your personal data will be processed for the secondary purposes indicated as “General secondary purposes” in this section IV.

c) Third parties related to job candidates and employees (family members or work or personal references): Your personal data will be processed for the following primary purposes:

Keep your data in the file of the job candidate or employee, as appropriate;

Locate you to validate work or personal references of a candidate;

Contact you by the means that the worker has indicated to communicate an emergency or any urgent situation, related to him/her or to comply with an obligation of ARCH.

On the other hand, only if applicable, your personal data will be processed for the secondary purposes indicated as “General secondary purposes” in this section IV.

d) Clients: Your personal data will be processed for the following primary purposes:

Contact to prospect you as a client to offer ARCH services by different means, such as telephone, email, SMS messages, instant messaging tools or through social networks;

Make appointments to visit or contact you and offer you ARCH services;

Follow up on activities conducted with prospects; present and follow up on commercial proposals and quotes; conduct statistical reports of the activities conducted with prospects;

Prepare the document stating the commercial relationship with ARCH and conduct the actions aimed at the provision, http://www.archstaffingandconsulting.com/wp-content/uploads/2022/05/Thumbnail-1-446×446-1.jpegistration and monitoring of the contracted service;

Comply with the obligations of the parties;

Put at your disposal technological tools for the publication of vacancies, in order to search for suitable profiles, and even to make comments about an assigned employee;

Contact you to communicate situations related to the provision of the contracted services, and where appropriate, their implementation;

Comply with legal and/or contractual obligations;

Conduct actions aimed at improving the service provided and evaluating its quality.

On the other hand, your personal data will be processed for the secondary purposes indicated as “General secondary purposes” in this section IV.

e) Suppliers: Your personal data will be processed for the following primary purposes:

Request information on the goods or services provided;

Enter into contracts or documents that establish the relationship with PAE for the provision of goods and services;

Locate you to enforce compliance with contractual obligations;

Comply with legal and/or contractual obligations.

g) General public: The primary purposes will be those identified as “General primary purposes”. On the other hand, your personal data will be processed for the secondary purposes indicated as “General secondary purposes” in this section IV.

General primary purposes: For all the aforementioned holders, if applicable, their personal data will be processed for the following primary purposes:

Where appropriate, provide service for the registration/cancellation of roles and http://www.archstaffingandconsulting.com/wp-content/uploads/2022/05/Thumbnail-1-446×446-1.jpegistration and technical support regarding the tools or systems that ARCH uses and are http://www.archstaffingandconsulting.com/wp-content/uploads/2022/05/Thumbnail-1-446×446-1.jpegistered by it;

Where appropriate, send you documentation by courier for review and/or signature and/or acceptance and/or acknowledgment and/or use;

If applicable, identify you to authorize your entry to ARCH facilities;

In the event that you contact ARCH, provide the required assistance;

In case of being in ARCH facilities and suffering an accident, provide the required assistance;

Comply with the obligations required by law against the Holder of personal data;

Make operational, statistical, or historical reports;

Where appropriate, monitor and address requests for procedures made before ARCH;

Where appropriate, through video surveillance systems, monitoring the activities conducted at ARCH facilities, as well as providing security through video surveillance systems;

Execution and performance of actions for the fulfillment of employer obligations by ARCH.

General secondary purposes: Additionally, we will use your personal data for the following secondary purposes:

Invite you to events organized by ARCH;

Have a control of attendees to ARCH events, integration activities, challenges, contests, or dynamics conducted by ARCH;

Send you advertising information from ARCH;

Congratulate you for particular or general reasons;

Where appropriate, preparation and publication of advertising with your identification data;

Where appropriate, posting comments or testimonials about your experience with us;

Where appropriate, delivery and control of recognitions, gifts, or prizes.

In case you do not want your personal data to be processed for any or all secondary purposes, from this moment you can notify us by sending an email to the address [email protected].

For the cases in which personal data have been obtained indirectly, you have a period of 5 (five) business days, from the first contact that the Responsible person has with you, in order to send an email to the address [email protected], stating the refusal to process your personal data.

The refusal to use your personal data for additional purposes may not be a reason to deny the requested services or terminate the relationship established with us.

V. Transfer of personal data.

If you do not want your personal data to be processed with respect to those transfers for which your consent is required as indicated in the table above, we ask you to send an email to the address [email protected].

VI. ARCO rights and/or revocation of consent.

You or your legal representative may exercise any of the rights of Access, Rectification, Cancellation or Opposition, also known as “ARCO Rights”, as well as revoke your consent for the processing of your data, communicating this via email to the address [email protected], which is managed and addressed by our ARCH Personal Data Department.

You must submit an application: (i) indicate the name of the applicant, and where appropriate, his/her legal representative; (ii) prove the personality of the applicant, and where appropriate, of his/her legal representative; (iii) indicate the address and/or email where to find him/her; (iv) identify the right he/her wishes to exercise and the data on which it is required to exercise it – if it is a right of rectification, indicate the data to be corrected and the correction to be made, or if it is a right of opposition, indicate the secondary purposes on which he/she wants to exercise such right. Failure to comply with the point indicated in numeral (iii), the request will be considered as not submitted.

Once the request is received, ARCH will have 5 (five) business days to verify compliance with the provisions of the previous paragraph; in case it does not meet the requirements, ARCH will notify you and you will have 10 (ten) business days to comply with the requirement that we made. If it is not done within such period, the request will be considered as not submitted.

ARCH will have 20 (twenty) business days to inform you about the origin of your request. Once the above notification has been made, and if the exercise of the right is appropriate, ARCH will have 15 (fifteen) additional business days to make such right effective.

The terms indicated in the preceding paragraph may be extended for the same time indicated for a single occasion and for justified cause.

ARCH will keep your personal data in strict adherence to the retention periods applicable in accordance with the legislation in force in each of the States indicated in section I of the instrument herein, which are stipulated in the Quality Policy for personal data processed by the Responsible person, and that you will be able to know, by making the request to the email [email protected], which will be addressed in accordance with the provisions of this paragraph.

VII. Use of Cookies, web beacons or other similar technologies.

We inform you that, through our internet sites, we use cookies and other technologies, through which it is possible to monitor your behavior as an internet user, as well as provide you with a better service and experience when browsing our page. The personal data that can be obtained through the use of these technologies are the following: locations, source IP address, browser used, operating system, and access devices. These technologies may be disabled by following the procedures of the internet browser you use.

VIII. Application of the Personal Information Protection and Electronic Documents Act (PIPEDA).

In the case of the processing of personal data conducted under the jurisdiction of Canada, what is indicated in the previous sections of the instrument herein will be applicable, unless otherwise indicated. In order to comply with Principle 8 – Openness indicated in PIPEDA, it is stated that, if such legislation is applicable, we make the following information available to you:

a) The name or title, and the address, of the person who is accountable for the organization’s policies and practices and to whom complaints or inquiries can be forwarded: ARCH Staffing and Consulting Canada Corporation’s Personal Data Department located at Toronto Office, Suite 5600, 100 King Street West, Toronto, ON M5X 1C9, which may be contacted via email dataprivacy@archstaffing.ca.

b) The means of gaining access to personal information held by the organization: In order to comply with this requirement, the provisions of section VI of the instrument herein will be followed. Although it is true that numeral 4.9.4 of PIPEDA indicates that the response to the request must be made within a reasonable time, in the event that you make a request, we will validate that the attention time in section VI is fulfilled in a timely manner and treating its reduction.

Likewise, it is reported that, in principle, your request for access will have no cost; however, if we require payment for the cost of reproduction, we will let you know when informing you about the declaration of origin of your request.

If your request for access is appropriate, we promise that the information that we provide you is recorded in a generally understandable format.

c) A description of the type of personal information held by the organization, including a general account of its use: In order to comply with this requirement, the provisions of sections III and IV of the instrument herein will be followed. It should be noted that the uses indicated in section IV comply with principle 2. Identifying Purposes and 5. Limiting Use, Disclosure, and Retention of PIPEDA, since the purposes of use have been specifically indicated for each of the holders of which we process personal data, in addition to the fact that such purposes are legitimate because they are related to the relationship that the Data Controller has with the Holder in question.

d) A copy of any brochures or other information that explain the organization’s policies, standards, or codes: The instrument herein contains the guidelines under which the Data Controller undertakes to protect your personal data. If you require a copy of it, you have free access through consultation on our website https://www.archstaffingandconsulting.com/.

e) Which personal information is made available to related organizations: In order to comply with this requirement, the provisions of section V of the instrument herein will be followed, section in which the communications related to personal data are made, indicating the third party that receives them and the purposes for which personal data is transferred. It should be noted that, in the consent section, those transfers that do not require your consent are indicated, which addresses to the fact that the transfer is necessary according to the purposes that give rise to the relationship that the Holder has with the Responsible person for processing. Due to the foregoing, regarding the transfers in which it is indicated that the consent is necessary, they refer to transfers that address the fulfillment of secondary obligations, so that the Holder, at any time, may deny his/her consent for such transfers not to take place.

IX. California Consumer Privacy Act (CCPA) enforcement.

In principle, the processing of your personal data will be conducted in accordance with what is indicated in the previous sections of the instrument herein, unless otherwise indicated, in the event that the Responsible person for processing is placed in applicability cases or under the cases of specific processing of personal data.

Only in cases where CCPA will be applicable, the following applies:

a) Selling your personal information: We inform you that your personal data is not offered for sale or given to any organization in exchange for monetary remuneration.

b) Information requests: If you wish to submit a request related to the processing of your personal information, we inform you the following:

• Responsible person for managing your requests: Arch California LLC’s Personal Data Department located at 4020 Palos Verdes Drive North, Ste 120, Rolling Hills Estates, CA 90274, which can be contacted via email dataprivacy@us, or you can make a request on our Website https://www.archstaffingandconsulting.com/ in the Contact Us section, selecting the option “Question about Privacy?” for the question How Can We Help.
• Deadline to address requests: First of all, your request must comply with section VI of the instrument herein; however, if the request in question is appropriate, the Data Controller agrees to reveal and deliver the requested information free of charge within 45 days after receipt, being able to extend this period for an additional 45 days whenever reasonably necessary, in which case, we will inform you before the end of the first period granted by law.

X. Changes to the instrument herein.

Any update to the document herein will be published on our website https://www.archstaffingandconsulting.com/.

Update: January 25th, 2022.