Nakupuna Website Privacy Policy

 

The Nakupuna Family of Companies[1] (collectively referred to as “Nakupuna”, “we”, “us”, or “our”) are committed to protecting your privacy, securing your information, and earning your trust through our compliance with this Privacy Policy (“Policy”). The purpose of this Policy is to explain how Nakupuna collects information through our website (“Website”) and any services, materials, and communications provided to you in conjunction with the Website (collectively the “Services”). This Policy also describes how we safeguard your Personal Information, and comply with applicable data privacy laws and regulations.

This Policy applies only to Personal Information we collect via the Website and in electronic communications sent through or in connection with the Website and the Services.

This Policy does not apply to information that:

• We collect offline or on any other Company applications or websites, including websites you may access through our Website.
• You provide to or is collected by any third party.

These other third parties have their own privacy policies, which we encourage you to read before providing information on or through them.

Please carefully read this Policy to understand our policies and practices regarding your information and how we will manage it. By accessing and using this Website and/or the Services, you agree to be bound by this Policy. If you do not agree, please do not access or use this Website or the Services.

 

Types of Information We Collect

Personal Information

“Personal Information” is information that relates to an identified or identifiable individual. It does not include de-identified, publicly-available, or aggregated information. As used in this Policy, “Personal Information” is limited to information that we collect through the Website or when you otherwise use the Services.

For example:

• Contact Information: Names, addresses, email addresses, and telephone numbers
• Employment-Related Information: Job applications, employment history, education, and resumes
• Technical or Device Information: Browser and device information, application usage, and geographic/geo-location information

Other Information

We collect other information that is not directly related to a specific individual. For example, we may collect statistical or aggregated data.

 

How We Collect Your Personal Information

When you use the Website, we collect Personal Information from you directly or indirectly. For example, when you complete our contact us form you provide your personal information to us directly. In addition, we may receive your personal information automatically as you use our Website.

Personal Information You Voluntarily Provide To Us

Nakupuna records details you provide to us voluntarily, such as when sending an email that includes your contact information, or filling out our contact us form.

Personal Information Collected Through Automatic Data Collection Technologies

When you use the Website, it may use technology to automatically collect:

• Details of your access to and use of the Website, including communication data and the resources you access or use on or through the Website.
• Information about the mobile or other device you use to access the Services (your “Device”) and internet connection, including IP address or other unique identifier, operating system, browser type, mobile network information, and telephone number.
• Metadata and other information associated with other files stored on your Device.

The Website does not collect real-time information about the location of your Device.

The technologies we use for automatic collection may include “Cookies.”

 

How We Use Cookies

“Cookies” are small pieces of data that may be stored on your computer or browser when you visit a website. Like many other websites, Nakupuna automatically collects information through cookies, to analyze trends, administer the Website, and track users’ movements. Information that could be collected through cookies includes, but is not limited to, your IP address, browser type, device ID, computer platform, web pages visited, and state/country you accessed the site. While cookies alone do not provide personally identifiable information, once you provide such information it may be associated with the data stored in a cookie.

We use the following types of cookies:

• Strictly Necessary Cookies – These cookies are required for the operation of our Website, including distinguishing between humans and bots and making valid reports on the use of our Website.
• Performance Cookies – These cookies help us improve the Website’s performance and visitor experiences.

Nakupuna’s Website also uses Google Analytics, a web analysis services provided by Google, Inc., to help us collect and analyze information regarding visitor use of our site.

You have the option to configure your browser settings to enable or disable cookies, including on your Device, though this may limit access to certain features on our Website. For more information about cookies and how to adjust your browser settings, you can visit www.allaboutcookies.org.

 

Do Not Track

Please note that, while your browser settings may transmit a “Do Not Track” (“DNT”) signal to websites, Nakupuna currently does not commit to responding to such signals as there is no general consensus on how DNT signal should be interpreted. Nakupuna will continue to monitor developments in DNT technology and standards, and if appropriate, revise our approach accordingly.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

 

Children

Our Website is not directed at children, nor do we knowingly solicit or collect Personal Information from children under the age of 18. Please contact us using the contact information below, if you have knowledge that a child under the age of 18 has submitted information to us, so that we may delete the information.

 

How We Use Your Information

The information we collect may be utilized to:

• Respond to your inquiries or requests.
• Provide you with information that you requested from us.
• Process employment applications, including qualification assessments, and reference and security clearance checks.
• Perform industry analysis, benchmarking, analytics, marketing, and other business operations.
• Protect against cybersecurity threats, fraud, and other unlawful activities.
• Maintain the safety and integrity of our website.
• Provide, maintain, personalize, and improve the Services.
• Send administrative communications.
• Create aggregated, pseudonymized, or anonymized information for analytical and statistical purposes.
• Engage in corporate transactions requiring review of user records.
• Maintain insurance policies and coverage.
• Comply with legal obligations and relevant policies.
• Fulfill any other purpose for which you provide it.
• For any other purpose with your consent.

Please note that we might use your information for other purposes, for which we will provide you specific notice at the time of collection.

Nakupuna’s career portal is managed by iCIMS – a third-party vendor that collects Personal Information when you apply for a Nakupuna position. The information provided in our career portal is used solely for evaluating your employment application and for human resources processing. Please review iCIMS privacy policies as it may differ from Nakupuna’s.

 

How We Share Your Information With Others

Nakupuna does not sell, loan, or lease the information it collects to third parties. Nakupuna may share information in the following situations:

• Internally within Nakupuna to provide you with our Services, to manage business operations, or for human resources and security purposes.
• To submit proposal and contract information to government and commercial customers.
• To facilitate services provided by third-party vendors, such as payroll processors, background check providers, tax providers, or auditors.
• To assist with security investigations, including cybersecurity, security breaches, fraud, or other illegal activities.
• To comply with requests from law enforcement or other government authorities.
• To adhere to legal obligations, including those stipulated by law, regulation, court order, or other legal processes or purpose.
• In the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other business disposition, including during bankruptcy proceedings.
• For any other purpose we disclose when you provide it.
• With your consent.

Nakupuna may disclose aggregated and/or de-identified information about our users to third parties without restriction.

 

How You Can Access Your Personal Information

At your verifiable request, and as permitted or required by and consistent with applicable law, we will confirm whether we are processing Personal Information about you, and provide copies of the Personal Information we have collected about you over the past twelve (12) months. We may limit your access requests to a reasonable number per year. Unless prohibited by applicable law, we may charge a fee for responding to access requests. We will notify you in advance of any fee.

We may refuse or delay an access request under certain circumstances, such as to protect legal privilege, to safeguard proprietary information, to protect the privacy rights of others, at the request of law enforcement, or to prevent undue burden or expense. If we determine that we cannot fully and promptly respond to an access request, we will tell you why and, if possible, work with you to modify the request so we can respond.

 

How We Protect and Retain Your Information

Nakupuna employs technical and organizational security measures to prevent unauthorized access or disclosure of information we collect and process about you. For example, information is stored in secure servers and access to information is restricted to authorized personnel who require such access for business purposes. We have established protocols to address any suspected data breaches and will inform you and any applicable regulator of such breaches in accordance with legal requirements.

Please be aware that, while we employ commercially reasonable and industry-accepted methods to safeguard your information, no method of transmission over the Internet or electronic storage is entirely secure, and therefore, we cannot guarantee its absolute security. Additionally, we are not responsible for circumvention of any privacy settings or security measures on the Website or the Services. All transmission of Personal Information is at your own risk.

We will retain your information for a length of time that is reasonably necessary to fulfill the purposes for which it was collected or you subsequently authorized, and in accordance with applicable law. In certain cases, we may retain your information for extended periods, if mandated by legal, regulatory, tax, or accounting obligations.

We may also collect and/or create aggregated, anonymized, or pseudonymized information, which we may keep indefinitely.

 

Your Privacy Rights

There are various data protection or privacy laws that may provide you with privacy rights regarding your Personal Information, including the right to access your Personal Information we may collect or retain, or the right to correct information you think is inaccurate. If you would like to exercise data protection rights granted by applicable law, please contact us at 1-877-264-2741  or via email at privacy@nakupuna.com. Please include “Privacy Rights” in the subject line of your email.

 

California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights, which are outlined in this section. In addition to all other information and rights contained in this Policy, under California law, you have the:

• Right to Know – Depending on the circumstances, you have a right to know:
  • Whether we collect and use your Personal Information;
  • The categories of Personal Information that we collect;
  • The purposes for which the collected Personal Information is used;
  • Whether we sell or share Personal Information to third parties;
  • The categories of Personal Information that are sold, shared, or disclosed for a business purpose;
  • The categories of third parties to whom the Personal Information was sold, shared, or disclosed for a business purpose;
  • The business or commercial purpose for collecting, selling, or sharing Personal Information; and
  • The specific pieces of Personal Information we collected about you.
• Right to Access – You have the right to request, up to twice a year, access to your Personal Information that we collect, use, disclose, and share.
• Right to Delete – You have the right to request we delete certain Personal Information we collected from you, subject to applicable legal exceptions, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
  • In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
• Right to Correct – You have the right to request that we correct your inaccurate Personal Information that is inaccurate.
• Right to Opt-Out – Although we do not sell your Personal Information and only share your Personal Information as described in this Policy, you have the right to “opt-out” of the “sale” of your Personal Information (as those terms are defined in the CCPA). You may opt out of “sales” or “sharing” of PI (as defined under applicable law) as follows:
  • Click on “Cookie Settings” at the bottom of the relevant website and deactivate cookies.
  • Exercising opt-out choices offered by the Digital Advertising Alliance at http://www.aboutads.info/choices, or by the Network Advertising Initiative at http://www.networkadvertising.org/choices/.
• Right to Non-Discrimination – You have the right to be free from discrimination and/or retaliation because you exercised your rights under California law.
• Right to Limit Use and Disclosure of Sensitive Personal Information – We do not process consumer’s Sensitive Personal Information.

You may access, delete, or correct Personal Information (as defined under applicable law) by referring to the contact details listed in “Your Privacy Rights” and “Contact Us.”

 

How We Verify and Respond to Your Data Requests

As required by the CCPA, any data related request you submit to us is subject to a verification process. To verify your request, you must provide your name, email, and state of residence, along with any other information we may require to verify your identity or your request.

We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

We may not fulfill your CCPA request unless you have provided sufficient information for us to appropriately verify you and your request.

 

Authorized Agents

If you are a California resident, you may authorize an agent to make a request on your behalf. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us as described in the “Contact Us” section below.  As part of our verification process, we may request that you provide, as applicable:

For an individual (“Requestor”) making a request on behalf of a California resident:

• The Requestor’s name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card.
• The name; contact information; social security or individual taxpayer identification number; date of birth; and Driver’s License, State ID, or Matricula Card of the California resident on whose behalf the request is being made.
• A document to confirm that the Requestor is authorized to make the request. We may accept, as applicable, a signed permission by the California resident on whose behalf the request is made, copy of a power of attorney, legal guardianship or conservatorship order, or a birth certificate of a minor if the requestor is the custodial parent.

For a company or organization (“Legal Entity Requestor”) making a request on behalf of a California resident:

• The Legal Entity Requestor’s active registration with the California Secretary of State.
• Proof that the California resident has authorized the Legal Entity Requestor to make the request. We accept as applicable, a signed permission by the California resident on whose behalf the request is made, copy of power of attorney, or legal guardianship or conservatorship order.
• The name; contact information; Social Security or individual taxpayer identification number; data of birth; and driver’s license, state ID, or Matricula Card of the California resident on whose behalf the request is being made. From the individual who is acting on behalf of the Legal Entity Requestor, proof that the individual is authorized by the Legal Entity Requestor to make the request. We accept a letter on the Legal Entity Requestor’s letterhead, signed by an officer of the organization.

 

Third Party Sites

Some content or applications on our Website are served by third parties.  This Policy does not extend to third party sites, including any applications or content accessible via links on our Website.

These third parties may use cookies, alone or together with web beacons or other tracking technologies, to collect information about you when you use our Website and Services. The information they collect may be associated with your Personal Information, or they may collect information—including Personal Information—about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.  We do not control these third parties’ tracking technologies or how they may be used.  As such, we encourage you to read the privacy policies and other notices posted when you leave Nakupuna’s Website and go to  third party websites.

 

Changes to our Privacy Policy

Nakupuna reserves the right to amend this Policy from time to time, consistent with applicable law. When changes are made, the modified policy will be posted on our Website with an updated effective date.

 

Contact Us

If you have questions or concerns regarding this Policy or Nakupuna’s practices concerning your personal or other information, or if you wish to exercise your privacy rights under law, please contact us at 1-808-731-8956 or via email at privacy@nakupuna.com. Please include “Privacy Rights” in the subject line of your email.

Privacy Notice | iCIMS

 

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[1] The Nakupuna Family of Companies refers to the Nakupuna Foundation and its subsidiaries, including Na Alii Consulting & Sales, LLC, Nakupuna Solutions, LLC, Nakupuna Consulting, LLC, Nakupuna Services, LLC, Nakupuna Federal, LLC, Nakupuna Resources, LLC, Nakupuna Technologies, LLC, and Nakupuna Prime, LLC.