WHOPLUSYOU Privacy Policy for the MAGNET Network

This Privacy Policy applies to Personal Information and Sensitive Information of individual users, and Personal Information of the individuals who use Organization Accounts, that we collect through the Magnet Platform (https://poweredbymagnet.ca) and through our service and support interactions and communications with users (collectively, our “Services”).

1. WhoPlusYou and the Magnet Network - Introduction

We recognize that you are entrusting us with a lot of personal and sensitive information. This policy explains how we collect, use, disclose and protect your information.

In this Privacy Policy, “we” “us” and “our” means WhoPlusYou Inc., the technology that powers the Magnet Network. Magnet is a social initiative of Toronto Metropolitan University that is committed to advancing careers, businesses and communities. Magnet collaborates with us and with Magnet Community Partners to serve individuals, employers, recruiting agencies and businesses. WhoPlusYou provides the Magnet™ targeted opportunity and communications matching platform (the “Platform”) that connects network participants to jobs, opportunities, services and people based on participants’ needs, interests and preferences.

2. Definitions

“Affiliate” or “Affiliation” is a relationship status inside the Platform between a user and a Magnet Community Partner.

For Individual Users, see section 3 (b) (iii), Information Sharing with Affiliated Community Partners for details.
For Organization Accounts, see section 4 (b) (ii), Information Sharing with Magnet Community Partners for details.
For Collaborators, see section 5 (b) (iv) Information Sharing with Magnet Community Partners for details.

"Collaborators" are users with Collaborator-type accounts on the Platform.

"Fit Information" means information as described in section 3 a) derived from a personality assessment taken through the Platform.

"Individual Users" are Job Seeker accounts on the Platform (including accounts which provide personality assessment for matching the user with employment and training opportunities based on Fit Information.

“Landing Pages” are webpages we provide for Magnet Community Partners where Individual users, employers and recruiting agencies can sign up for accounts or sign in to their accounts on the Platform.

“Magnet Community Partners” are organizations (such as employment service providers, schools, government and related entities), that have joined the Magnet Network and are collaborating with Magnet to achieve their shared objectives.

“Organization Accounts” are accounts for organizations (businesses, not-for-profits, schools, government and related entities). This includes employer, recruiting agency, business (exporter) and Magnet Community Partner accounts.

"Organization Users" are the individuals who are authorized to use an Organization Account.

“Personal Information” is information that identifies an individual, and information that could be combined by us, our partners or service providers with other information to identify an individual.

“Profile” means the information contained in the “My Profile” tab in an Individual User’s account.

“Sensitive Information” is information that does not personally identify an individual by itself, but which in the context of an Individual User’s account is or may be private and sensitive (for example, an individual’s opportunity preferences, an application to a job posting, Affiliation with a Magnet Community Partner, a diversity self-declaration).

“You” means an Individual User, a Collaborator, an Organization User or all, as the context indicates.

3. Individual Users: Collection, Use and Disclosure of Personal and Sensitive Information

a) Personal and Sensitive Information That We Collect

We collect information that you provide to us by entering it into the Platform or uploading it, or that arises from your activity on the Platform. Some of this information is used to create your Profile. Examples of information that we collect are:

your name, email, address, phone and other contact information
your photo
information about your career and professional background such as your education, work history, languages, skills, achievements and personal qualities
documents and media uploaded by you including letters and presentations
your professional and career interests and preferences
if applicable, your self-declaration as a member of a diversity group
your “Affiliate” status with one or more Magnet Community Partners
if you take a personality assessment through the Platform, your Personality Profile document provided by the assessor together with “Fit Information” from the assessment about your fit for certain employment and training opportunities
your preferences and settings
your viewing of communications to you from us and from other users inside your account, such as invitations to apply for job opportunities, invitations to events, targeted messages and other content sent to you
details of jobs you are interested in that you have bookmarked on the Platform
your communications with employers/recruiting agencies and other users of the Platform, including applications to opportunities
the Landing Page you used to sign up for your account, and the Landing Pages you have used to sign in to your account

You can change your Profile information and your settings, preferences, self-declarations and Affiliations at any time. However, even after you change information, copies of your previous information may still be available if it has been shared with others as described below and they have copied or stored it. The previous versions of your information will also remain on our backups for a period of time.

Please also see section 6, All Users, for other types of information that we collect from all types of users and how that information is used and disclosed.

b) How We Use and Disclose Your Personal and Sensitive Information

i) Matching, Targeted Messages, Applying and Connecting to Opportunities

We use your Profile information to match you to opportunities, and to notify you and provide information to you about opportunities that might be appropriate for and interesting to you, based on the preferences that you have indicated. These may be job opportunities, events, learning opportunities and other career or professional development opportunities.

If there is Fit Information in your account from a personality assessment, we use the Fit Information to match you to certain employment and training opportunities.

When you choose to apply to a job posting through the Platform, we share your Profile information with the employer or recruiting agency who posted the job together with any documents or media that are attached to your Profile or that you include with your application, such as a cover letter or traditional resume document. When you update your Profile information, the updated information is what is visible. The employer or recruiting agency can share your Profile information with others by means of an “Applicant Queue” containing a link to your Profile and other information about and contained in your application. If you change your Profile information while the link is active, the updated information is what is visible to the recipient. An application to a posting expires after 90 days if the employer has not contacted you through the Platform. After an application expires, the employer will no longer be able to view your Profile. You may withdraw your application from a posting even after communicating with the employer through the Platform. In that case, the employer will no longer be able to view your Profile.

In all cases where your Profile is visible to a third party from the Platform, this does not include information that is marked on your Profile on the Platform as “not shared”, “private”, “not visible to employers” or with similar language. For example, Opportunity Preferences and Affiliations can be kept private or made visible to third parties viewing your Profile, at your discretion.

ii) Information That You Choose to Share

Inside the Platform, we provide a Communications channel for employers and recruiting agencies to contact you in relation to applications that you have made through the Platform. The channel allows you to share information, such as chat messages, documents and media, with these employers and recruiting agencies. You may choose to stop sharing documents and media that you shared through the Shared Media channel.

In addition to sharing your Profile by applying to a job posting, you may choose to share your Profile with anyone you choose, by email from the Platform, using the “Share My Profile” button. This generates a link, valid for 60 days, which the email recipient can use to view your Magnet Profile. If you change your Profile information while the link is active, the updated information is what is visible to the recipient.

iii) Information Sharing with Affiliated Community Partners

We designate you as “Affiliated” with a Magnet Community Partner if you signed up for your account, or signed in to your account, through that Partner’s Landing Page, or if when you signed up for your account you chose that Partner as how you heard about Magnet. In your Profile, you can turn off your status as an Affiliate of any Magnet Community Partner at any time by using the controls in the “Affiliations” portion of your Profile. Affiliations can be kept private or made visible to third parties viewing your Profile, at your discretion. The default setting is for Affiliations to be private.

Affiliations are used to target some opportunities and communications.

Some Magnet Community Partners that provide services to individuals related to job readiness and job search (for example, career counselling) have the capability to view Personal Information and Sensitive Information about you if you are one of their Affiliates and if you have expressly consented to your information being shared with them. This express consent is given through a “Consent Required” pop-up on the Platform. If you consent, the Magnet Community Partner will be able to see:

your name
your email
your Profile
your Fit Information if applicable
information about jobs that you have been invited to apply to through the Platform
the date on which you applied to any job posting on the Platform, and
the date on which the employer or recruiting agency first initiated contact with you inside the Platform as a result of an application you made.

These Magnet Community Partners may require additional steps to verify or confirm you as an Affiliate, and/or may be able to turn off your Affiliate status.

You can withdraw or provide consent to sharing information with a Magnet Community Partner by using the controls in the “Affiliations” portion of your Profile, using the “Disclose Personal Info” toggle. If you withdraw your consent, your name and information about job invitations, applications and the initiation of contact with you, as well as Fit Information if applicable, that was made available to the Magnet Community Partner during the period your consent was in effect will remain available to the Magnet Community Partner as part of their records. In some instances, withdrawal of consent may result in you ceasing to be an Affiliate of the Magnet Community Partner.

iv) Diversity Self-Declaration

If you have self-declared as identifying with one or more Diversity Target Groups, we use your self-declaration to match you with opportunities or communications that request applicants or audiences from those Diversity Target Group.

When you receive a job opportunity that requests applicants from one or more Diversity Target Groups, you will be notified that the posting was targeted to individuals who have self-declared as identifying with at least one of the Diversity Target Group(s) specified in the opportunity posting. Where an opportunity requires that applicants have such a self-identification, you will be alerted before applying to the opportunity that by applying you will be implicitly identifying yourself as having self-identified with at least one of the required groups. Where an opportunity requests (without requiring) that applicants have such a self-identification, you will be asked for your consent to disclose as part of the application that you have self-identified with at least one of the requested groups. In both cases, the specific group or groups that you have self-declared as identifying with will not be made visible to the employer or recruiting agency posting the opportunity; however, please note that if the employer or recruiting agency has specified only one Diversity Target Group they will know by implication that you have self-declared as identifying with that group.

Your self-declarations will not be disclosed to employers when you are applying to jobs that are not marked as Diversity Employment Postings. Your self-declarations are not part of your Profile and are stored only in your account information.

v) Information Use and Disclosure for Support, Service and Communications

We use your contact information to contact you via email, subject to any “unsubscribe” instructions you have provided to us, and we may contact you by phone or ordinary mail. We may share your information with third parties, including Magnet, which provide services to Platform users and to us in our operations, including customer support and communications services. Where we do share Personal Information with third parties for these purposes, they are obliged to treat the information as confidential and use it only in connection with the services they and we are providing to you.

If you have self-declared as identifying with the “Persons with Disabilities” Diversity Target Group, you may choose to indicate particular types of disabilities about which you would like to receive communications from us. This indication is not part of your Profile and is stored only in your account information. We do not share this information with employers, Magnet partners or any other third parties.

Be aware that information that is shared with other users can be copied by them and shared by them with others.

Please also see section 6, All Users, for other types of information that we collect from all types of users and how that information is used and disclosed.

4. Organization Users: Collection, Use and Disclosure of Personal Information

(a) Personal Information We Collect

We collect information that users provide to us by entering it into the Platform or uploading it, or that arises from users’ activity on the Platform.

When creating an Organization Account, the individual creating the account on behalf of the organization will provide their own contact information (name, email address) and will become the first "Administrative User" of the account. The Administrative User may add other individuals as users of the account by providing their names and emails, and may transfer Administrative User status to another Organization User. Organization Users may also choose to provide Personal Information about themselves in communications with other users through the Platform, and in documents, media or other information they upload to the Platform.

(b) How We Use and Disclose Your Personal Information

i) Information Use and Disclosure for Support, Service and Communications

We use your contact information to contact you via email, subject to any “unsubscribe” instructions you have provided to us, and we may contact you by phone or ordinary mail. We also share your contact information with Magnet. We may share your contact information with third parties who provide services to us in our operations, including customer support, billing and communicating with you. Where we share contact information with third parties for these purposes, they are obliged to treat the information as confidential and use it only in connection with the Services we are providing to you.

If you use the Platform to post jobs to students through Campus Connect, we may share your contact information with the educational institutions which distribute the postings to their students. The educational institutions may use the information to contact you about your organization's job posting.

Some account types have the option of making a "Diversity Declaration" in their Organization Profile. If you make a Diversity Declaration, we will use that declaration to match you to communications and content targeted to audiences in that Diversity Target Group. Your Diversity Declaration is not visible to the viewers of your Organization Profile and is only stored in your account information. We do not share this information with other organizations, individual users, Magnet Community Partners, or third parties.

ii) Information Sharing with Magnet Community Partners

We designate an employer or recruiting agency account as “Affiliated” with a Magnet Community Partner if the employer or recruiting agency signed up for their account, or signed in to their account, through the Magnet Community Partner’s Landing Page, or if when they signed up for their account they chose that Partner as how they heard about Magnet. Where an employer or recruiting agency account is Affiliated with a Magnet Community Partner, we may share contact information of Organization Users for that account with the Magnet Community Partner.

iii) Information That You Choose To Share

Inside the Platform, we provide a Communications channel and a Shared Media channel for you to share information, such as chat messages, documents and media, with Applicants that you have contacted through the system. You may choose to stop sharing media that you shared through the Shared Media channel at any time.

5. Collaborators: Collection, Use and Disclosure of Personal Information

Collaborators create accounts within the context of a Collaborator Community of Practice which is founded and led by a Magnet Community Partner (the "Community Sponsor").

(a) Personal Information We Collect

We collect information that you provide to us by entering it into the Platform, uploading it, or as it arises from your activity on the Platform. Some of this information is used to create your Profile. Examples of information we collect are:

your name, email, phone number, and other contact information
your photo
information about your career and professional background and your publications
your interests and expertise as related to the Communities that you join
your Affiliation status with one or more Magnet Community Partners
your preferences and settings
your Contact records that you create through the Platform
your Community Forum profile and anything that you share through your posts, questions, answers, or discussions in the Forum
your viewing of communications inside your account to you from other users, such as invitations to events, targeted messages, other targeted content, and Community Forum messages
the Landing Page you used to sign up for your account and the Landing Pages you have used to log in to your account

You can change information in your Magnet Profile and your settings, email preferences, Community interests and expertise, and your Affiliations at any time. However, even after you change your information, copies of your previous information may still be available if it has been shared with others as described in section 5 (b) and they have copied or stored it. The previous versions of your information will also remain on our backups for a period of time.

(b) How We Use and Disclose Your Personal Information

i) Targeted Messages and Opportunities

We use your Profile information to provide information to you about opportunities, events, and content that may be appropriate for and interesting to you based on the preferences, interests, and expertise you have indicated. These may be events, learning opportunities, and other career or professional development opportunities.

ii) Collaborator Search

Inside the Platform, we provide a Collaborator Search that allows Collaborators to search for other Collaborators in their mutual Community based on their interests, expertise, and other Profile information. By default, your Profile will not appear in these results unless you make your Profile searchable by other Collaborators by setting it to "Public" inside your Profile. You can prevent your Profile from appearing in search results at any time by changing your profile visibility to "Private".

While your Magnet Collaborator Profile is "Public" and visible in Collaborator Search, other Collaborators who are in the same Community as you will be able to add you to their Contacts inside the Platform. When you are added to another user's contacts after being found through Collaborator Search, your information appears under the other user's "Contacts" menu and can be used for easy reference. Once you are in someone's Contacts list, they will be able to view your Contact information and your Magnet Profile event if your Profile is subsequently set to "Private".

In all cases where your Profile is visible to another user on the Platform, this does not include information that is marked on your Profile as "not shared", "private", or with similar language.

iii) Community Forums

When you become Affiliated with a Community Sponsor, you may be invited to participate in that Partner's Community Forum. If you choose to participate in a Community Forum, other users will be able to see:

your name
your email address
your Community Forum Profile
any content you post or share in the Community Forum, and
Groups you have joined or Topics you have followed.

There is no option to make your Profile in a Community Forum private or not visible to other users.

If you deactivate your Collaborator Account, your Profile in the Community Forum and any information in it will be removed, but any posts or materials shared in groups or to the main Community Forum feed will remain.

iv) Information Sharing with Affiliated Community Partners

We designate a Collaborator as "Affiliated" with a Magnet Community Partner if you signed up for your account, or signed in to your account, through that Partner's Landing Page, or if when you signed up for your account you chose that Partner as how you heard about Magnet. In "My Communities", you can turn off your status as an Affiliate of any Magnet Community Partner at any time.

Affiliations are used to target some opportunities and communications.

If you are Affiliated with a Community Partner or if you have an account in a Community Partner's Forum, the Community Sponsor and its service providers will have the ability to see information about you, including your name, email address, any interests or expertise you have selected to contribute to that Community, and other information in your Profile.

v) Information Use and Disclosure for Support, Services and Communications

We use your contact information to contact you via email, subject to any "unsubscribe" instructions you have provided to us, and we may contact you by phone or ordinary mail. We also share your contact information with Magnet. We may share your contact information with third parties who provide services to us in our operations, including customer support and communications services. Where we do share Personal Information with third parties for these purposes, they are obliged to treat the information as confidential and use it only in connection with the Services we are providing to you.

Be aware that information that is shared with other users can be copied by them and shared by them with others.

6. All Users: Collection, Use and Disclosure of Personal Information

We gather certain information automatically when you visit the Platform. This information includes interactions with the Platform and the date and time for each interaction. We use information collected from you and your activities on the Platform to administer and improve our Services, to investigate issues, provide user support, and for billing purposes when applicable.
We collect your email address when you sign up to receive alerts about new job postings ("job alerts"). We use the email address and the job alerts criteria you provide to send you relevant job postings until you unsubscribe. This information is not considered part of any account you may create and is managed independently, including its deletion.
We use a variety of cookies for different purposes. "Cookies" are small text files that are stored in your browser by the Platform when you visit it. We use login or session cookies (temporary files which are erased when you close your browser) to help manage your session and recover from interruptions while you are logged in. We use persistent cookies (which will remain on your hard drive until you erase them) so the Platform knows your Affiliations and can display related branding and content.
We use Google Analytics which sets its own cookies on users’ browsers to collect information on user activity such as pages visited, time spent on each page, click-throughs, unique users, browsers used, types of devices being used, locations (based on IP addresses), device operating systems and users’ internet service providers. For information on how Google treats personal information that it collects through Google Analytics, see Google Analytics security and privacy principles. The information that we receive back from Google Analytics contains no personally identifiable information.
We enable Facebook to use cookies, web beacons, or other storage technologies (“Facebook Tools”) to collect information about user activity on certain Landing Pages on our Platform. We identify the Landing Pages where Facebook Tools are used with the legend “This webpage uses Facebook Tools as explained here in our Privacy Policy”. Facebook is able to collect information about your activity on a Landing Page where Facebook Tools are used if you are logged in to Facebook on the same device when visiting the Landing Page. The information which Facebook may collect from a Landing Page includes your presence on the Landing Page, whether you completed sign-up for an account or signed in to your account, and whether you clicked on any links. Facebook will use that information to provide measurement services, and target ads to you. Please see Facebook’s Privacy Policy for their explanation of how they collect, share and use this information. Facebook may share the information that it collects, on an aggregated, anonymized basis, with us and with the Magnet partner from whose Landing Page Facebook collected the information. The information shared back by Facebook contains no personally identifiable information. You may opt out of the collection and use of information for ad targeting. Please refer to the following links for information about opting out: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.
Some features in the Platform are supported by third parties or provided through integrations with third parties. In order to provide access to the Service, Personal Information may be shared with or hosted by third parties. Where we do share Personal Information with third parties in order to provide the Service, they are obliged to treat the information as confidential and use it only in connection with the Services we are providing to you.
We collect information about how recipients of our emails engage with the emails, such as whether they open the emails, click through on links in the emails and/or unsubscribe or change their email preferences. Some of this information is collected via “web beacons” (objects embedded in the emails). We use this to understand what content is engaging and relevant to users, and to track unsubscribes and individuals’ email preferences.
We use information collected from users and users' activities on the Platform, other than Personal Information, on an anonymized basis to create and provide data for analytical purposes, for example aggregated labour market information, and we share this information with some Platform users and third parties.
We may disclose or transfer user information in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization or sale of stock.
We will disclose your information without your knowledge or consent if we are required to do so by law or to comply with a judicial proceeding, court order or legal process served on us; or we believe that disclosure is necessary to protect our rights or enforce your User Agreement with us. We also reserve the right to disclose your information when we believe that disclosure is necessary to protect the safety, rights or property of other users of the Platform or the public. We may disclose users’ Personal Information if it is necessary for us to collect a debt from the user, or where we have reason to believe that it is relevant to the investigation of a breach of laws and we are legally permitted to do so.
We reserve the right to review and disclose content that users share with other users of the Platform where we suspect that such sharing is a breach of the terms and conditions of use of the Platform.

7. Communications

We use your name and email address to contact you for administrative and transactional purposes and for promoting our Services to you. As previously noted, we use cookies to track responses to email and newsletters that we send to customers and potential users. You may opt out of receiving all or certain kinds of emails from us by using the “unsubscribe” feature in emails or in the “Site Preferences” tab under "Settings" in your account.

8. How We Protect Your Personal Information

We recognize the importance of the security of Personal Information and Sensitive Information. We take administrative and technical measures to safeguard Personal Information and Sensitive Information against unauthorized access, unauthorized disclosure, theft, misuse and loss. Although we take precautions against possible breaches of the security of your information, both during transmission and in storage, we cannot fully eliminate the risk of technical failure or security breaches that enable or cause unauthorized access, unauthorized disclosure, theft, misuse or loss of information.

9. Deletion of your Personal Information and Deactivation of your Account

You can request the deletion of your personal information by sending a message to data@whoplusyou.com. We will confirm within 15 business days that your personal information has been deleted. Some copies of your personal information may still remain in our system back-up files, which are deleted periodically.

In order to delete your personal information, we will need to deactivate your account. You can deactivate your account yourself at any time by selecting “Deactivate My Account” under your account Settings.

If you are an Individual User or a Collaborator and you deactivate your account, your Profile will not be searchable, we will not send you any communications, and we will delete information from your account that we do not need to maintain for purposes of audit, data integrity, or fulfillment of legal requirements, as soon as reasonably possible. Be aware that even after you deactivate your account, copies of your information may still be available if your information has been shared with others and they have copied or stored it. Your information will also remain on our backups for a period of time.

When you deactivate your Collaborator account, your Profile in the Community Forum and any information in it will be removed, but any posts or materials shared in groups or to the main Community Forum feed will remain.

10. Location for Collection, Processing and Storage of Information

At the date of publication of this policy our servers are located in Canada and therefore your Personal Information and Sensitive Information will reside on and be processed on servers located in Canada. We may choose to move the location of our servers at any time, and accordingly the location in which your information will reside and be processed may change in future without any prior notification to you.

11. We may change this policy and you will be bound by our changes.

We have the right to change our Privacy Policy at any time without your agreement. If we decide to change our Privacy Policy, we will post those changes on the Platform and we will also post a notice on the Platform about the changes. If you continue to use the Platform after the changes have been published on the Platform, you are consenting to the changes. If you do not agree with the changes, you should deactivate your account.

12. Links to Other Sites

Our Platform contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. This Privacy Policy applies only to information collected by us. We encourage you to be aware when you leave the Platform and to read the privacy statements of other sites to which you provide personal information.

Please contact us with any questions, concerns or suggestions at privacy@whoplusyou.com.

April 15, 2020