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1. Introduction

This Privacy Policy contains the policies and procedures to which Real Talent Management, hereinafter referred to as “Real Talent Management”, “we” or “our”, is subject to in the collection, use, and disclosure of the information you provide when using our services, websites, widgets, and applications (collectively, our “Services”). Your privacy is important and we strive to protect the personal and confidential data of our website visitors and registered users of our website (“Members”) to the best of our ability. The effective date of this Privacy Policy is [insert date]. By using the Services, you consent to the collection, use, processing, transfer, manipulation, storage, disclosure, and other uses of your information as described in this Privacy Policy. Regardless of which country you live in, you authorize us to use your data in, and as a result to transfer it to and store it in, the United States and any other country where we operate. Privacy and data protection laws in some of these countries may vary from the laws in the country where you live. From time to time, our Privacy Policy may change and shall be effective upon publication on our website. The new version of our Privacy Policy will be posted on our website ( We encourage you to periodically review this page for the latest information on our privacy practices. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy. Real Talent Management strives to use current industry standard information security best practices to maintain the security of the sensitive information we collect from and on behalf of individuals, including website visitors. We will review these practices from time-to-time against new and emerging standards to guarantee the required security of your data. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website, widgets, or applications. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website, widgets, or applications.

2. Types of Data

Data that we collect may include contact information names, address, phone number, and email address; information about products and Services ordered or provided; payment information, passwords, and information collected through Internet-based and e-commerce activities, images, and other transaction-related data. We distinguish between the following types of data: (i) Personally Identifiable Data and (ii) Non-Personally Identifiable Data (collectively referred to as “Data”). We may collect, store and/or handle one or more of the stated types of data according to the program, product or service you choose (to access or participate in). We may also share certain aggregated or otherwise de-identified data after we have removed any private Personally Identifiable Data (such as your name or email address).

2.1 Personally Identifiable Data

2.1.1 Definition

For the purpose of this Policy, Real Talent Management defines Personally Identifiable Data as “Personally Identifiable Information.” “Personally Identifiable Information” means all information that can be used to identify you, such as your first and last name, your address, your phone number and/or your email address. 

2.1.2 Ownership and License

Your Personally Identifiable Data belongs to you, and you retain, at all times, complete ownership of all personal data collected during your use of Real Talent Management Services. We will retain your Personally Identifiable Data for as long as your account is active or as needed to provide you Services. We will retain and use your information as reasonably necessary to conduct our business, comply with our legal obligations, resolve disputes, and enforce our agreements. As you are the owner of your Personally Identifiable Data, at any time, you may request Real Talent Management to deactivate your account by following the process in Section 2.1.4 below, and we will delete your Personally Identifiable Data.


2.1.3 Storage and Protection

We will store Personally Identifiable Data securely while using security methods that are current industry standards for the protection of personally identifiable information. Our clients may update, access, delete inaccuracies, or correct certain Personally Identifiable Data by contacting us at You should also contact to deactivate your account and request deletion of your Personally Identifiable Data from our servers, although such request may impact our ability to continue performing purchased Services on your behalf. We will respond to your requests within 60 days.

2.2 Non-Personally Identifiable Data

2.2.1 Definition

Real Talent Management defines “Non-Personally Identifiable Data” as information that enables Real Talent Management to track site, service and application usage such as access date and time, the specific application service used, frequency and duration of access, and other users contacted or collaborated with via Real Talent Management Services. This information will be used to recognize repeat information, estimate usage patterns, analyze bounce rate, pages per visit, search engine referrals, etc. We may link this automatically collected data to other information we collect about you. The technology used to collect this information will be via Google Analytics, Facebook Pixel, and HTTP cookies. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online Services (behavioral tracking). See the Do Not Track Disclosure, Section 2.2.4, for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

2.2.2 Collection

We collect Non-Personally Identifiable Data from website visitors and all Members.

2.2.3 Storage and Protection

We will store Non-Personally Identifiable Data in the United States, or any other countries while using security methods that are current industry standards for the protection of non-personally identifiable information.

2.2.4 Legal Basis for Processing Information (EEA users only)

If you a user located in the European Economic Area, our legal basis for collecting and using the information described above depends on the type of information concerned and the specific context in which we collect it.

We may rely on our legitimate interest to collect information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to collect and process information about you, they include the interests described herein.

However, in some cases, we may rely on your consent or have a legal obligation to collect the information from you, or may otherwise need the information to protect your and/or our vital interests or those of another person or entity. If we rely on your consent to collect and/or process information about you, we will obtain such consent in compliance with applicable laws.

If you have questions about or want further information concerning the legal basis on which we collect and use information about you, please contact us at

2.2.5 European Data Subject Rights 

If you are a resident of a country in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the collection, processing, and use of information about you. As set forth above, the information that we collect about you when you use the Service may include certain digital identifiers that are considered “personal data” under European law. We process this data either as it is necessary to further our legitimate interest and/or pursuant to your consent.

As a resident of a country in the EEA, you have the right to: (i) request access and obtain a copy of the information we collect about you; (ii) request rectification or erasure; (iii) restrict the processing of such information; and (iv) if applicable, data portability. In certain circumstances, you may also have the right to object to the processing of such information.

If you would like to exercise any of these rights, please contact us at Please note that because most of the information we collect and maintain about you can only identify a particular browser or device, and cannot identify you individually, you may need to provide us with additional information to enable us to identify the information we have about you and ensure that we accurately fulfill your request. Although we use good faith efforts to respond to your request, we may not be able to provide and/or correct the requested information in all situations. For example, we may not be able to provide the information requested if it imposes an undue burden or expense, requires us to release confidential commercial information, or requires the disclosure of information relating to another person.

As a resident of the EEA, you have the right to file a complaint about our processing of personal data with a European Data Protection Authority. For contact details of your relevant local Data Protection Authority, please be referred to:

2.2.6 Do Not Track Disclosure

We support the Do Not Track browser setting. Do Not Track (DNT) is a preference you can set in your browser to let the website you visit know that you do not want them collecting certain information about you. 

3. Data stored on local devices

By using our Services, some or all of your Personally Identifiable Data may be stored on your local device, depending on the device you are using (for example your smartphone, tablet or computer), and/or uploaded to our cloud servers. As you handle the data on your local device, we urge you to take measures to protect your Personally Identifiable Data. One possibility might be to save the Personally Identifiable Data via application password. We also recommend additional protection such as local data encryption, optionally chosen by the user (offered on both Google® Android(™) and Apple® iOS(™) devices). Alternatively you can also delete your locally stored Personally Identifiable Data. 

4. Sharing with other users on social media

Members will be able to share their Real Talent Management data with other users via Real Talent Management Services. Within the application, we will use either a confirmation mechanism or a notification to solicit and confirm your consent. However, information shared by our Members through channels such as e-mail, chat or any other social media cannot be controlled by Real Talent Management. You share your information at your own risk. We urge you to think carefully about the data you share with others in or through the Services. Your interactions with these features are governed by the privacy statement of the company providing it.

5. Situations requiring the disclosure of data

Real Talent Management may disclose data to business partners as appropriate in connection with a legitimate business need in the United States, or other countries. In addition, Real Talent Management discloses data to service providers as needed for such service providers to perform services on behalf of Real Talent Management. Service providers may not use data for other purposes. We share your payment information with payment services providers to process payments; prevent, detect and investigate fraud or other prohibited activities; facilitate dispute resolution such as chargebacks or refunds; and for other purposes associated with the acceptance of credit or debit cards.  Special situations may require the data to be disclosed to: (1) conform to existing law or comply with legal process served on Real Talent Management, (2) protect and defend the rights or property of Real Talent Management, or (3) in urgent circumstances to protect the personal safety of users of Real Talent Management, Real Talent Management Services or the public.

6. Ethical aspect

Real Talent Management will act in a socially responsible manner when collecting, storing, processing, transferring, disclosing and/or using any information from you. 

7. Product information

Subject to conformity with applicable law, we may send you product or service-related information, and/or invitations to participate in surveys, research programs, etc. We recommend reading any notice belonging to such communication before you consent to participate.


8. Maintenance related Announcements

We will send you maintenance related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

9. Our Policy Towards Underage Persons

9.1 Definition


Our Services are not directed to persons under 21 (“Underage Persons”). We do not knowingly collect personal information from persons under 21. If we become aware that a person under 21 has provided us with data, we take steps to remove such information and terminate that underage person’s account.

10. Links to Other Sites

If you click on a link to a third party site, you will leave the Real Talent Management website that you are visiting and be redirected to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal data by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as Real Talent Management. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to the Real Talent Management website, you should read that site's privacy statement before providing any personal data.

11. Contact

If you have any thoughts or questions about this Privacy Policy, please contact us at:

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