TalentSage, LLC is a survey company that designs surveys and analyzes survey results for academic, business and non-profit organizations, which utilize survey results to improve individual and organizational performance.

Software for our surveys is provided by TalentDOC, a UK based company with its own GDPR-compliant privacy policy, https://app.talentdoc.co.uk/privacy.jsp.  All personal data utilized to produce survey participation invitation and reminder emails, aggregate survey response data and produce survey feedback reports is managed by TalentDOC.

What personal data do we collect?

Our clients in Europe and elsewhere provide the names and email addresses of individuals who are to be sent survey invitation emails.  In some cases, the individuals receiving survey invitations provide additional names and email addresses for individuals who are also to be sent survey invitations emails.  Some, none, or all of the individuals for whom TalentSage, LLC has received names and emails addresses may be located in Europe.  Accordingly, TalentSage, LLC treats their names and email addresses as if they were located in for the European Union for data privacy purposes.

Additional demographic data is collected and retained by TalentDOC during the survey process, which can be viewed by TalentSage in a given survey subject’s report.  Survey participants may submit inquiries pertaining to the demographic data that can be viewed by TalentSage, LLC on the TalentDOC website.  TalentSage, LLC maintains a log of those inquiry emails, including any personal demographic data discussed therein.

How do we use and share collected data?

TalentSage, LLC utilizes the names, email addresses and demographic data of survey subjects provided by our clients to send out survey participation invitation emails with a secure software system provided by TalentDOC..  In some instances, we also use the names and email addresses provided by survey subjects to send out additional survey participation invitations. We use the responses to survey questions to produce feedback reports about the survey subjects.  Such reports are made available to be viewed by only the subject of a specific report, who, in turn, may or may not choose to allow their report to be viewed by others.  Report subjects may choose to rescind their decision to allow their report to be viewed by others at any time.  Access to surveys by subjects and anyone they nominate to complete a survey about the subject is accomplished by logging onto a secure software system with a combination of the subject’s or nominee’s email address and unique password.  Access to view feedback reports by subjects and any individual a subject has authorized to view that subject’s report is also accomplished by logging onto that secure software system utilizing the subject’s or authorized viewer’s email address and unique password.

A survey report can not be viewed without the sole permission of a survey participant.  Thus, a survey report, including any demographic data contained in the report, can only be viewed on the TalentDOC website by a survey participant, the person(s) the survey participant has given revocable permission to view the participant’s report, and TalentSage, LLC.  The reports cannot be downloaded, only viewed, which renders them unavailable to be shared with anyone else.  The names, email addresses and personal demographic data discussed in survey-related emails are not shared with anyone except the relevant client or the survey participant.

Privacy Shield Policy

TalentSage complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (and Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield.  TalentSage has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

TalentSage, LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission.

TalentSage, LLC may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

In the context of an onward transfer of personal data, TalentSage, LLC has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. TalentSage, LLC shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless TalentSage proves that it is not responsible for the event giving rise to the damage.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to the contact information listed below.  If requested to remove data, we will respond within a reasonable timeframe.

If you want to know what personal data we have about you, you can:

Ask us for details of all your personal data and/or a copy of your personal data held by us (where any such personal data is held). This is known as a “Subject Access Request” (SAR).

All SARs should be made in writing and sent to our DPO by one of the following 2 addresses to the Attention of the Data Protection Officer, David Hallett:

  1. Email address: david@talentsage.com
  2. Business Address:  10720 Mississippi Blvd., Coon Rapids, MN, USA, 55433

We will respond to your SAR within one (1) calendar month from the date of your request or the date of any additional information we need from you to process your request. We will aim to provide a complete response, including a copy of your personal data within that time

In some complex cases, however, more time may be required. In these cases we commit to providing your information within three (3) calendar months from the date we receive your request or from the date of any additional information we need from you to process your request. You will be kept informed of our progress.

There is not any charge for a SAR, unless your request is deemed ‘manifestly excessive’ (e.g. repetitive). In this case, we may require a fee to cover our administrative costs in responding.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to david@talentsage.com

In compliance with the Privacy Shield Principles, TalentSage, LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact TalentSage, LLC  at: David Hallett, Data Protection Officer (DPO), david@talentsage.com, 10720 MISSISSIPPI BLVD. COON RAPIDS, MN, USA,  55433

TalentSage, LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield 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 Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction