Privacy Policy

Effective: October 22nd, 2024

We at Culinary Agents Inc. have created this privacy policy (this “Privacy Policy”) because we know that you care about how the information that you provide to us is used and shared.

This Privacy Policy describes how Culinary Agents Inc, including its affiliates and subsidiaries (collectively “Culinary Agents,” “we,” “our,” or “us”), collect, use, disclose and safeguard your information. This Privacy Policy applies to individuals who access our sites located at www.culinaryagents.com, www.hospitalitycareerpaths.com, and our mobile applications (collectively “Sites”) through which we provide a gateway to our services. In this Privacy Policy we will refer to our websites and mobile applications as our "Platform".

Parents and guardians of children and teenagers under the age of 18 who wish to use the Platform must read this policy.

INFORMATION WE COLLECT

For the purposes of this Policy, personal information is any information about an identifiable individual.

Information You Provide to Us

When you use our Platform, you may provide us with your personal information through a variety of means, including when you:

• Create an Account. When you sign up to our Platform, you will provide us with your name, email address, preferred city, and you will create a password for future logins.
• Talent Profile. Your Talent Profile is customizable however the more complete it is, the more information recruiters or our business partners have. In addition to your name, you can provide your education, language(s) you speak, work experience, skills, city or area, photo, and a summary of who you are. We do not recommend sharing sensitive personal information on your Talent Profile and please do not post or add information that you would not want to be viewed publicly.
  • If you get a conditional job offer through our Platform, we may collect from you, your Social Security number and share it with your potential employer. Please note, we will contact you directly if this is required to ensure it is securely transmitted.
• Our Business Entities. In order to create a Business Entity Account, we will collect your name, company address, company email address, telephone number, and payment information. We use a third-party payment processor, Stripe, to process your payment and therefore we do process or store any payment information. To learn more how Stripe handles the data it collects from you, please refer to Stripe’s Terms and Privacy Policy.
• Use of Artificial Intelligence. We use AI to recommend job postings that match your skills, location, and preferences. Your personal information is shared with our AI system to ensure relevant opportunities are provided. Please note, AI is not used to exclude you from potential employment nor is used in any hiring decision.
• Subscribe to our Newsletter. You can subscribe to our newsletter by providing us your email address. You can unsubscribe at any time by clicking on the ‘unsubscribe link’ or updating your Profile.

Information We Collect Automatically

In addition to the personal information, you provide directly to us, we automatically collect personal information from you as you use our Platforms via “cookies” and similar tracking technologies. These tracking technologies collect information related to your internet and electronic network activity, which may come from your operating system, mobile device, IP address, browser type, and universally unique ID (“UUID”).

We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information when you interact with the Services. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; (v) diagnose and repair Services errors, and, in cases of abuse, track and mitigate the abuse; and (vi) market to you more effectively across different web pages and social media platforms based on your browsing habits and history.

A particular third-party cookie on our Sites is Google Analytics. In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent. Please note, if you opt out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out of each browser or device that you use.

• Google Analytics. We use Google Analytics to collect information on your use of the Services for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there. Google Analytics also receives information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to our Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here.

Culinary Agents will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in

HOW WE SHARE YOUR PERSONAL INFORMATION.

Information from Third Parties

We also use one or more third-party remarketing and conversion tracking services to advertise to users of our Platform on third party websites. These third-party service providers use cookies to serve ads based on a past visit to our Platform. Any data collected by such third-party service providers will be used in accordance with their Privacy Policies. The third parties that are currently providing us with these services are listed below:

• For Twitter, please visit: https://support.twitter.com/articles/20171365
• For Facebook, please visit: https://www.facebook.com/privacy/explanation
• For Indeed, please visit: http://www.indeed.com/legal
• For LinkedIn, please visit: LinkedIn Privacy Policy
• For ZipRecruiter, please visit: Privacy Policy and Terms of Use | ZipRecruiter

Aggregate Data

In an ongoing effort to better understand our visitors, Talent, and the Platform, we may analyze personal information in aggregate form to operate, maintain, manage and improve our Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners, including, without limitation, Businesses. We may also disclose aggregated user statistics in order to describe the Platform to current and prospective business partners and to other third parties for other lawful purposes.

HOW DO WE USE YOUR INFORMATION

We use the personal information we collect to improve our Platforms and to protect our legal rights. In addition, we may use the personal information we collect to:

• Process your account registration;
• Send you our newsletter;
• Connect you with our Business Partners
• Communicate with you about our Platforms or to inform you of any changes to our Platform
• Operate and improve the Platforms, including to analyze visits to the Platforms and learn about our visitors so we can operate the Platforms and improve our services and deliver the best user experience;
• Create audiences for our advertisements, target our advertisements, and generate reports about the performance of our advertisements;
• Communicate with you, including responding to your inquiries;
• Comply with the law and to maintain the integrity and security of our Platforms;
• Defend our legal rights and the rights of others;
• Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use and to otherwise fulfill our legal obligations;
• Fulfill any other purposes for which you provide it, or any other purpose we deem necessary or appropriate.

HOW WE SHARE YOUR INFORMATION

Culinary Agents may share personal information in the following instances:

Within Culinary Agents. We may share your personal information among our affiliated entities for the legitimate business purposes of efficiently and effectively providing the Services. Access to your personal information is limited to those on a need-to-know basis.

With our Business Partners. We may share your personal information with our Business Partners who use our Platforms to acquire talent.

With Service Providers. We share your personal information with our service providers who help us provide you, our Services. These service providers include our marketing and advertising providers, IT/web hosting providers, customer service providers, payment processor providers, market analytical providers, and our cloud storage provider.

In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

With Third Parties. We may need to disclose your personal information to third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations.

For legal purposes. We share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information.

Correct or View Your Information. You may access your account or Talent Profile to correct or view certain personal information you have provided to us and which is associated with your account.

Opt Out of Advertising Cookies. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

• Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/
• Network Advertising Initiative (NAI)
  Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
• Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
• European Union (EU) /European Economic Area (EEA)
  Opt-Out: http://www.youronlinechoices.eu

Opt Out of Marketing Communications and Newsletter. You may opt out of receiving marketing emails and the Newsletter from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the Platform.

Opt Out of Email Tracking. We use technology that tracks whether or not an email is opened. You can unsubscribe to this tracking by clicking on the icon in the email.

Opt Out of Push Notifications. You may opt out of receiving push notifications from us by updating the Settings on your mobile phone.

NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to [email protected].

NOTICE TO CALIFORNIA RESIDENTS

California Shine the Light Law grants California residents the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Shine the Light, please contact us via email at [email protected].

IMPORTANT NOTICE TO NON-US RESIDENTS

Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Data Privacy Framework, your decision to provide such data to us, or to allow us to collect such data through our Platform, constitutes your consent to this data transfer.

DATA PRIVACY FRAMEWORK

We comply with the EU-US Data Privacy Framework (EU-U.S. DPF) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway) as well as the UK Extension to the EU-U.S. DPF regarding the collection, use and retention of personal information from the United Kingdom and Gibraltar. We have certified that we adhere to the Data Privacy Framework Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “DPF Principles”). If there is a conflict between this Privacy Policy and the DPF Principles, the DPF Principles shall govern.

To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov/.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the Data Privacy Framework Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. EU and UK individuals with inquiries or complaints regarding this Privacy Policy should first contact us at [email protected].

We have further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.

See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

INFORMATION SECURITY

We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

DATA RETENTION

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves a purpose. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

CHILDREN’S PRIVACY

We do not knowingly collect any personal information from children under the age of 13 through our Platform. If you are under the age of 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected], and we will endeavor to delete that information from our databases.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on our Platform as soon as they go into effect. By accessing or using our Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer to this Privacy Policy on a regular basis.

Contact Us:

If you have questions about this Privacy Policy, please contact in one of the following ways:

• E-mail us at [email protected]

Or write to us at:

• Culinary Agents Inc.
• 500 7th Avenue, 8th Floor
• New York, NY 10018

Copyright 2024 Culinary Agents Inc. All rights reserved.