Privacy Policy | Tradewind Subs

PRIVACY POLICY

Last updated [29^th January 2025]

This Privacy Policy describes the personal information Tradewind Recruitment, Inc. (“Tradewind”, “we”, “our”, or “us”) collects when you use the Tradewind website at www.twsubs.com (the “Website”) and our app Tradewind Subs (the “App”), or interact with us, how we use this information, with whom we share it, and the choices you have in connection with this. This Privacy Policy does not apply to third-party websites that may be linked from our Website and App. If you want more information on how those third-parties collect, use, and share your information, as well as your choices regarding your personal data, please refer to their privacy policies.

1. INFORMATION WE COLLECT, WHY, AND FOR HOW LONG

When you interact with our Website or App, we collect your personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. We retain personal information for as long as necessary to achieve the purposes for which it was collected. We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for such purposes or a service provider or contractor’s operational purpose(s): (1) whether there is a retention period required by statute or regulations; (2) the existence of actual or threatened litigation for which we are required to preserve the information; (3) the statutes of limitations for potential legal claims; and (4) generally accepted best practices in our industry, including related to safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete your Personal Information.

A. If you are an applicant for a position:

As you use the Website or App, Tradewind will collect personal information when you:

Sign up using our Get Started form or Apply for a job: When you sign up with our Get Started form or Apply for a Job, we collect, from you, your personal identifiers (name, email address, address, and phone number), professional or employment-related information (current job title and work history contained in your resume), and any other information you choose to include in your resume you upload. We use this personal information to assess and evaluate your fitness for positions at educational institutions listed with us. We share your information with our online contact vendors, who facilitate your communication with us. If we assess you for placement with an educational institution, we will also share your information with that educational institution. With your consent, Tradewind will keep your personal information on hand to share with additional educational institutions for future teaching opportunities.

Contact Us by email form: When you contact us by email for inquiries, we collect, from you, your personal identifiers (name, email address, phone number, and general location), internet or other electronic network activity information (Source IP) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any topics you inquire about. We share your information with our email and online contact vendors, who facilitate your communication with us.

Refer a Friend: When referring a friend, you must obtain their consent to provide us with their information. When you refer a friend, we collect, from you, your personal identifiers (name, email address, and phone number) and your professional or employment-related information (job title). We also collect, from you, your friend’s personal identifiers (name, email address, and phone number) and their professional or employment-related information (job title and professional experience) and any other information you choose to include regarding their experience. We use this information to assess and evaluate your friend’s fitness for positions at educational institutions listed with us. We also use this information to qualify you for a potential referral bonus after your friend completes their first teaching placement. We share your information and your friend’s information with our email and online contact vendors, who facilitate gathering the information to provide to Tradewinds for our use. We may also share your information and your friend’s information with educational institutions for potential placement.

Subscribe to Tradewind’s Email Newsletter: When you subscribe to our email Newsletter, we collect from you, your personal identifiers (name, email address), and contact preferences. We use this personal information to fulfill your request to receive email alerts with our company newsletter, and to communicate with you via email about updates and teaching opportunities. We will share your identifiers (name and email address) with our email marketing provider to send you the marketing emails and with third parties with which we partner with for promotions, events, sweepstakes, contests, and other similar activities (“Promotion Partners”) for them to send you information regarding events, sweepstakes, promotions, and contests that may be of interest to you. To opt out of this sharing, please visit Do Not Sell or Share My Personal Information www.twsubs.com/Do-Not-Sell-My-Personal-Information. You can unsubscribe from marketing emails at any time by clicking on the “unsubscribe” link in each email. You can opt out of all communication by emailing marketing@twsubs.com and changing your contact preferences. Please note that we will continue to send you notifications necessary to the services or requested products or services. Our communications contain tracking technologies, like pixels, to analyze whether a predefined action took place by a recipient, such as opening our communications and other engagement metrics such as timestamps, delivery status, the IP address of your computer. whether an email was forwarded, clicks within an email, as well as sender and recipient addresses. We use this information to send you additional email communications which may be of interest to you based on your interaction with our emails and/or website and to better adapt, personalize and distribute our communications. You can avoid downloading the pixel by rejecting the download of images in the email.

B. If you are an employer:

Request a Substitute Teacher: If you are a school educator looking for substitute teachers to use at your educational institution and fill out our webform to request a substitute teacher, we collect, from you, your personal identifiers (name, email address, and phone number), professional or employment-related information (school employer), and any other information you choose to include regarding the teacher vacancy to be filled. We use this information to contact you regarding the details of the teacher vacancy and place substitute teachers with your educational institution. We share the position, school, location, pay rate, and requested schedule with potential substitute teachers to help place them at your educational institution.

C. If you are an employee:

Use the Onboarding Portal or Candidate App: When you login to the Website onboarding portal or App to submit timesheet data and compliance documentation, we collect, from you your personal identifiers (name, email address, and phone number), professional or employment-related information (teaching credentials/qualifications/permits, the school you worked at, number of days, and hours worked), sensitive medical information (vaccination or other medical requirements), and internet or other electronic network activity information (IP address, Source IP, successful and unsuccessful login attempts). We use your personal identifiers and professional or employment-related information to confirm your placement and time worked at an educational institution for your pay. We also use your professional or employment-related information to comply with legal requirements for teacher qualification and your medical information to abide by health and education regulations. We share your personal information listed here with the educational institution you are seeking placement at or the institution at which you are working.

D. If you interact with us through Text, website, or social media:

Sign up to receive SMS Messages: If you consent, we may send you promotional, applicant, and employment-related SMS messages. SMS Terms and Conditions: By consenting to SMS messages, you agree to allow Tradewind and its agents contacting you with recurring marketing offers and promotions and transactional messages at the phone number you provided, including by autodialed text messages even if your number is listed on a state or federal Do Not Call list. You understand and agree that messages may be sent to you earlier and/or later than the time restrictions set by state or federal law. Consent to receive texts is not a condition of purchasing any goods or services or necessary to apply to any job. You may opt-out at any time by replying “STOP” or texting “HELP” to get assistance to the number sending the message. After replying STOP, you may receive additional communications confirming that your request has been received and processed, and you may continue to receive text messages for a short period while Tradewind processes your request. Standard message and data rates may apply. Message frequency may vary based on the texting program. You agree to update Tradewind if you discontinue use of that telephone number or obtain a different number.

Interact with us on social media: When you interact with our social media pages on social networking websites, such as Meta (i.e. Facebook and Instagram) and LinkedIn (each a “Social Media Page” and collectively, “Social Media Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Meta and LinkedIn use your personal information, please see Meta’s Privacy Policy (for Facebook and Instagram) and LinkedIn’s Privacy Policy.

Social Media Pages: When interacting with our Social Media Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Social Media Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit. The content posted on our Social Media Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to us at marketing@twsubs.com.

Community Management. We collect, from you, your contact, including "likes", shares, messages and other interactions with the content, to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts.

Page Insights. When you visit our Social Media Page, the applicable Social Network records your IP address and other information about your usage behavior on our Social Media Page. The Social Network collects this information through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Social Network app through your mobile device (e.g., smartphone or tablet). The Social Network uses this information to provide us with statistical evaluations of the use of our Social Media Page. We receive this information directly from Social Network, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Social Media Pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, "likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Social Media Pages. We do not collect or process any other personal information in connection with Social Network “Page Insights” function. We do not retain this information independently. For information on data protection and the storage period on the Social Network in relation to its Insights function, see the Social Network privacy policy linked above. It has been contractually agreed with the Social Network that the Social Network is responsible for providing you with information about the processing for Page Insights.

Information Processed Solely by Social Networks. We do not know how the Social Networks use Personal Information for its own purposes, how long the Personal Information is stored on the Social Network or whether the Social Network data is passed on to third parties. If you are currently logged in to a Social Network as a user, the Social Network automatically collects, through trackers on your device, your Social Network ID or a link between the Social Network ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Social Network app through your mobile device (e.g., smartphone or tablet). This enables the Social Network to understand that you have visited our Social Network Fan Page along with other Social Network Pages that you have clicked on, whether you clicked on Social Network buttons integrated into websites that partner with the Social Network, and other online interactions that report user data to the Social Network. Based on this data, content or advertising tailored to you can be offered. You can find more information about the Personal Information collected by Social Networks, how it is used and how long it is stored by visiting the Social Network’s privacy policies, linked above.

Interact with the Websites or App. In addition to the personal information you provide directly to us, we also collect information from you automatically as you use our Website or App via cookies, pixels, web beacons, and similar tracking technologies. This includes, but is not limited to, the following internet or other electronic network activity information (Source IP). We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information when you interact with the Website and App. We use this information to: (1) track you within the Website and App; (2) enhance user experience; (3) conduct analytics to improve the Website and App; (4) prevent fraudulent use of the Website and App; (5) diagnosis and repair Website and App errors, and, in cases of abuse, track and mitigate the abuse; (6) provide targeted advertising; and (7) capture and aggregate viewing and engagement metrics. Particular third-party cookies to note on our Website include: Google Analytics, and Google Tag Manager. 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 Website and App for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there (for more information about how Google collects and uses the information see here). Google Analytics also receives information about you from applications you have downloaded or services that you use that partner with Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites 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, adjust your Ad Settings or change settings in your Google My Activity if you are signed into your Google Account. Disclosure of personal information for some of the ways Google uses it may be deemed a sale or sharing or disclosure for targeted advertising under state data privacy laws. To opt out of this sharing, please visit www.twsubs.com and opening the cookie manager to manage these cookies. If you require assistance with this, please email marketing@twsubs.com.

Google Tag Manager. Google Tag Manager is a tag management system to manage tags used for tracking and analytics on our Website. Tags are small code elements that, among other things, are used to manage traffic and visitor behavior and to test and optimize websites. We utilize Google Tag Manager to manage and organize all third-party tags on our Website to control when those tags are triggered. You can view more information about Google Tag Manager’s privacy practices here.

Aggregate data. We aggregate the data we collect for benchmarking purposes and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

Tradewind may also use your personal information collected for the above purposes to efficiently maintain our business, to comply with the law, and for other limited circumstances as described below in Section 2 of this Privacy Policy HOW WE SHARE YOUR INFORMATION.

2. HOW WE SHARE YOUR INFORMATION

A. General Sharing

Tradewind may share the personal information identified in this Privacy Policy in the following instances:

Within Tradewind: Where necessary, Tradewind will share your personal information within Tradewind to efficiently carry out business and to the extent permitted by law.

With educational institutions: If you apply for a position, we share your information with the institution for which you applied. With your consent, Tradewind will keep the information you provided to us on hand for future teaching opportunities and we may share that information with additional educational institutions for other teaching opportunities.

In the event of a corporate reorganization: In the event that Tradewind enters into, or intends to enter into, a transaction that alters the structure of Tradewind, 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 assets, Tradewind would share your personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction.

For legal purposes: Tradewind will share your personal information where legally required, 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 by 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.

With your consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect going forward.

B. Sharing in the Last Twelve (12) Months

For Business Purposes. In the preceding twelve (12) months, Tradewind has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

We have disclosed your personal information with service providers that assist us in providing the Website and App. These services providers assist us with the following: information technology (IT) support; website hosting; data analysis; customer relationship management; mailing; email delivery; text messaging; auditing; and similar services. [we can just do service providers once in this section rather than in the general one]
We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Website and App errors.
We have disclosed your internet or other electronic network activity information to our IT support to update, improve, and maintain the Website and App.

C. Sale of Personal Information

In the preceding twelve (12) months, Tradewind has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics providers as described in INFORMATION WE COLLECT, WHY, AND FOR HOW LONG. Such sharing may be deemed a sale or sharing under the CCPA. To opt out, please visit Do Not Sell or Share My Personal Information. www.twsubs.com/Do-Not-Sell-My-Personal-Information

For clarity, all the above categories of information shared exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, unless you consented to such sharing.

3. YOUR INFORMATION CHOICES

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

Text Messages and Calls. If you previously provided consent, you can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of calls. For more information, please see the SMS Terms and Conditions listed above under Section 1 INFORMATION WE COLLECT, WHY, AND FOR HOW LONG.

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

Opt Out of Google Analytics. To prevent your personal information from being used by Google Analytics, you can download the Google Analytics opt-out browser, which can be accessed here, adjust your Ad Settings or change settings in your Google My Activity if you are signed into your Google Account. Disclosure of personal information for some of the ways Google uses it may be deemed a sale or sharing or disclosure for targeted advertising under the data privacy laws. To opt out of this sharing, please visit www.twsubs.com and opening the cookie manager to manage these cookies. If you require assistance with this, please email marketing@twsubs.com.

Opt Out of Email Tracking and Marketing Communications. You can disable this tracking by blocking automatic loading of images in your email. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. You may continue to receive marketing emails for a short period after unsubscribing as your request is processed. Please note that we will continue to send you notifications necessary for the Website and App.

Opt Out of Advertising Cookies. You can opt out of certain cookies by clicking the “Do not sell or share my information” link. 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.

- 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
- In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent.

4. RIGHTS OF CONSUMERS

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (collectively, “CCPA”) entitles California residents to certain rights. To the extent the CCPA applies to our processing of your personal information, you are entitled to the following rights:

Right to Access/Know. You have the right to request categories and/or specific pieces of personal information we have collected, used, disclosed, and sold about you, unless an exception applies. California residents may make a free request for access twice per calendar year.

Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.

Right to Opt Out of Sale/Sharing or use for targeted advertising. You have the right to opt out of the sale or sharing of your personal information to third parties or to opt out of the processing of your personal information for purposes of targeted advertising. Tradewind does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years old.

Right to Non-Discrimination. You have the right to not receive discriminatory treatment in the processing of your personal information as well as if you exercise your rights to access, delete, opt out, correct, or limit use of sensitive personal information. Tradewind will not deny you goods, services, charge you different prices or rates, or provide a different level or quality of goods or services for exercising your rights.

Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.

Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Website and App or certain other permissible purposes like fraud, customer service or quality control. Sensitive information depending on the state can include Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. Tradewind only collects and shares Sensitive Personal Information that is required for employment purposes.

Right to Appeal and File a Complaint. You have the right to appeal an action taken (or not taken) by Tradewind in response to your request. We will inform you of any action we have taken in response to your request without delay and, in any event, within forty-five (45) days after we receive your request. If you believe your privacy rights have been violated, you can submit a complaint, in California to the California Attorney General at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.

Right to Data Portability. You have the right to ask that we transfer the personal information you gave us, to you, or in certain cases, directly to another organization, in a format that is easily understandable and to the extent technically feasible, in a structured, commonly used, machine-readable format. California residents may make a free request for transfer twice per calendar year.

Right to Opt Out of Profiling. You have the right to opt out of profiling of your personal information in furtherance of decisions that produce legal or similarly significant effect concerning a consumer by fully automated means. Tradewind does not collect, process, sell, or share any personal information for the purpose of profiling.

B. Exercising your rights.

To exercise your rights, as applicable, you may submit a request by emailing privacy@twsubs.com. To opt out of the sale or sharing of your personal information via cookies, please visit www.twsubs.com and open the cookie manager to manage these cookies. If you require assistance with this, please email marketing@twsubs.com. If the browser or extension that you (or your authorized agent) are using supports Global Privacy Control (GPC) (see here for more information), you may utilize the GPC opt out preference signal to instruct us to not sell or share any of your personal information collected online. The GPC opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings. Please note that you must opt out of each device and each browser.

You must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information (which may include, but may not be limited to, your name and contact information, if applicable) and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

5. DO NOT TRACK

We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

6. INFORMATION SECURITY

Tradewind implements and maintains reasonable security measures to help protect the personal information that Tradewind collects and maintains, such as access controls, cloud-based processing, storage and backups, and encryption. Tradewind also maintains training and awareness programs on security and privacy for employees. However, unfortunately, we cannot guarantee that our security measures will prevent malicious attacks to our systems 100% of the time.

7. NOTICE OF FINANCIAL INCENTIVE

Tradewind may, on occasion, offer financial incentives, including payments as compensation, for the collection of personal information, the sale or sharing of personal information, or the deletion of information. Other financial incentives may include offering a different price, rate, level, or quality of goods or services to you if that price or difference is directly related to the value provided to you by the personal information. As required by the CCPA, Tradewind will notify you of incentives when offered. We will only enter you into a financial incentive program if you give us prior opt-in consent that clearly describes the material terms of the financial incentive program. Your opt-in consent may be revoked at any time by contacting us at privacy@twsubs.com.

8. AGE RESTRICTION

The Website and App are not intended for individuals under the age of eighteen (18).

We do not collect the personal information of anyone under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have the personal information on individuals under the age of thirteen (13), please contact us as the contact information below.

9. CHANGES TO THIS PRIVACY POLICY

Tradewind may change this Privacy Policy from time to time. We will post the changes to this page and indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If Tradewind make changes that materially affect your privacy rights, we will notify you with a prominent post on the Website and obtain your consent, if required.

10. CONTACT

Tradewind Subs

9229 Sunset Boulevard, 8^th Floor, Los Angeles, CA, 90069

If you have any questions about this Privacy Policy, please contact us at privacy@twsubs.com or call us at 1-(213)-289-7605