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Do Not Sell Information
Understand how VRS protects personal information, why we do not sell personal information, and the limited circumstances in which information may be shared to support our services.
- Clause I: Purpose
- Clause II: Scope
- Clause III: Our Commitment
- Clause IV: What This Notice Means
- Clause V: VRS's Position on Selling and Sharing Information
- Clause VI: Categories of Personal Information Covered
- Clause VII: Permitted Disclosures of Personal Information
- Clause VIII: Service Providers and Technology Platforms
- Clause IX: Marketing, Analytics and Website Technologies
- Clause X: Your Privacy Choices
- Clause XI: Identity Verification
- Clause XII: Non-Discrimination
- Clause XIII: Relationship with Other Privacy Documents
- Clause XIV: Review of this Notice
- Clause XV: Contact Information
Purpose
Virtual Recruitment Solutions ("VRS", "we", "us", or "our") is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us by our customers, prospective customers, candidates, independent contractors, suppliers, business partners, website users, and other individuals who interact with our business.
The purpose of this Do Not Sell or Share Personal Information Notice ("Notice") is to provide transparency regarding VRS's approach to the collection, use, disclosure, sharing, and protection of personal information, and to explain our position regarding the sale or commercialisation of personal information.
As privacy legislation continues to evolve internationally, individuals increasingly expect organisations to clearly explain whether personal information is sold, shared for commercial purposes, or otherwise disclosed to third parties. VRS supports these expectations through a commitment to openness, responsible information governance, and transparent communication regarding our information handling practices.
This Notice explains the circumstances in which VRS may disclose personal information to trusted third parties in order to operate its business or deliver agreed services, while making it clear that such disclosures are fundamentally different from selling personal information for financial gain or commercial exploitation.
This Notice forms part of VRS's broader privacy and governance framework and should be read together with our Privacy Policy, GDPR Policy, Data Protection Policy, Cookie Policy, Terms of Use, and any applicable customer agreements governing the processing of personal information.
Nothing contained within this Notice limits any rights that individuals may have under applicable privacy legislation or any contractual obligations entered into between VRS and its customers.
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Scope
This Notice applies to personal information collected, used, stored, processed, disclosed, or otherwise handled by VRS in connection with its business operations, recruitment support services, website, marketing activities, customer relationships, supplier relationships, and other legitimate business activities.
The Notice applies to personal information relating to customers, prospective customers, recruitment agencies, staffing businesses, candidates, independent contractors, website visitors, suppliers, business contacts, marketing subscribers, event participants, consultants, technology providers, and any other identifiable individual whose personal information is processed by VRS.
This Notice applies regardless of whether personal information is collected directly from an individual, provided by a customer, obtained through publicly available professional sources, received through recruitment platforms, submitted through our website, or otherwise processed in connection with the legitimate operation of our business.
The principles described in this Notice apply irrespective of the country in which an individual resides and are intended to support transparency across VRS's international operations. Where local privacy legislation provides additional rights or imposes additional obligations, those legal requirements will apply alongside this Notice to the extent required by applicable law.
This Notice does not replace the more comprehensive information contained within VRS's Privacy Policy or GDPR Policy, which explain in greater detail how personal information is collected, processed, retained, protected, transferred, and managed throughout its lifecycle.
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Our Commitment
VRS believes that personal information should be treated as information entrusted to us rather than as a commercial asset to be bought, sold, or traded.
Accordingly, VRS is committed to protecting personal information through responsible governance, appropriate technical and organisational safeguards, transparent business practices, and compliance with applicable privacy legislation.
We believe that customers should have confidence that information entrusted to VRS for the purpose of delivering recruitment support services will be handled only for legitimate business purposes and not commercialised for unrelated financial benefit.
Our commitment extends beyond legal compliance. We seek to maintain high standards of integrity, confidentiality, accountability, and professionalism in the way personal information is collected, accessed, processed, disclosed, retained, and protected across every aspect of our business.
Where personal information is disclosed to trusted service providers or technology platforms, such disclosures are made solely to support the operation of our business, fulfil contractual obligations, provide agreed services, maintain information security, comply with legal obligations, or improve operational efficiency. Such disclosures are not undertaken for the purpose of selling personal information or allowing unrelated organisations to commercially exploit that information.
VRS continually reviews its privacy governance framework to ensure that our information handling practices remain consistent with recognised international privacy principles, evolving legislation, customer expectations, and responsible business practices.
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What This Notice Means
The terms "sell" and "share" may have different meanings under different privacy laws and regulatory frameworks. For the purposes of this Notice, these concepts are intended to distinguish between the commercial sale of personal information and the legitimate disclosure of information necessary to operate a business or deliver agreed services.
In general terms, selling personal information involves transferring or making personal information available to another organisation in exchange for money, commercial value, or another form of consideration where the recipient is entitled to use that information for its own independent commercial purposes.
Sharing personal information may refer to making personal information available to another organisation for purposes beyond those reasonably necessary to deliver the requested services, including certain forms of advertising, marketing, behavioural profiling, or other commercial activities depending on the applicable legal framework.
By contrast, organisations frequently disclose personal information to trusted service providers, cloud platforms, payment providers, communication platforms, legal advisers, technology vendors, recruitment systems, customer-authorised platforms, and other operational providers solely for the purpose of supporting legitimate business operations. These types of operational disclosures are generally not regarded by VRS as the sale of personal information because the information continues to be used only for authorised business purposes and remains subject to appropriate contractual, confidentiality, and privacy protections.
The purpose of this Notice is therefore to explain the distinction between commercial sale or commercial sharing of personal information and the legitimate operational disclosures required for VRS to deliver its services effectively and securely.
VRS's Position on Selling and Sharing Information
VRS does not sell personal information as part of its business model.
We do not sell customer databases, candidate databases, curriculum vitae, resumes, recruitment records, applicant information, contractor information, contact lists, email addresses, telephone numbers, customer relationship information, commercial information, website user information, or any other personal information to data brokers, advertising companies, marketing organisations, or other third parties for their own independent commercial purposes.
Similarly, VRS does not permit unrelated organisations to purchase access to personal information collected through our website, marketing activities, recruitment support services, or business operations.
Where VRS discloses personal information to trusted third parties, such disclosures occur solely to support legitimate business functions, fulfil contractual obligations, deliver agreed recruitment support services, operate technology platforms, maintain business systems, comply with legal obligations, process payments, protect information security, or obtain professional services necessary for the operation of our business.
These disclosures are carefully controlled through contractual arrangements, confidentiality obligations, privacy safeguards, and appropriate governance measures designed to ensure that personal information is used only for authorised purposes consistent with the services being provided.
VRS also does not monetise personal information by licensing, renting, leasing, trading, or otherwise commercially exploiting information entrusted to us by customers, candidates, suppliers, or other individuals.
Protecting the confidentiality and integrity of personal information is fundamental to maintaining the trust placed in VRS by recruitment agencies and other stakeholders. Accordingly, our business is built upon delivering high-quality recruitment support services rather than generating revenue through the commercial sale or exploitation of personal information.
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Categories of Personal Information Covered
This Notice applies to personal information collected, processed, accessed, stored, disclosed, or otherwise handled by VRS in connection with the legitimate operation of its business and the delivery of its recruitment support services.
Depending on the nature of an individual's interaction with VRS, the categories of personal information that may be covered by this Notice include identification information, business contact information, professional information, employment and recruitment-related information, communication records, customer account information, supplier information, website usage information, device and browser information, marketing preferences, billing information, contractual information, recruitment documentation, interview scheduling information, and other information reasonably required to deliver the services requested or operate our business.
Where VRS provides recruitment support services on behalf of customers, personal information processed may also include information contained within customer-owned applicant tracking systems (ATS), customer relationship management (CRM) systems, recruitment platforms, communication systems, scheduling tools, document repositories, and other business systems to which customers have authorised VRS to access.
The categories of information described within this Notice are not exhaustive and may evolve as VRS introduces new services, technologies, operational processes, or customer solutions. Where material changes occur to the categories of personal information processed, VRS will review and update its privacy documentation as appropriate.
Regardless of the category of information involved, VRS remains committed to handling personal information responsibly, limiting access to authorised individuals, and ensuring that information is processed only for legitimate and authorised business purposes.
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Permitted Disclosures of Personal Information
Although VRS does not sell personal information, there are circumstances in which personal information may be disclosed to trusted third parties where such disclosure is reasonably necessary to operate our business, fulfil contractual obligations, deliver agreed services, comply with legal requirements, or protect legitimate business interests.
Such disclosures may occur in connection with the provision of recruitment support services, customer onboarding, technology services, cloud infrastructure, communication platforms, payment processing, accounting services, legal advice, regulatory compliance, cybersecurity services, website hosting, data backup, document management, marketing systems, analytics platforms, or other operational functions required to support the efficient operation of VRS.
Where VRS processes personal information on behalf of customers, information may also be disclosed within customer-authorised systems or to other parties expressly authorised by the customer in accordance with the applicable customer agreement or documented instructions.
VRS seeks to ensure that any organisation receiving personal information from VRS is subject to appropriate contractual, confidentiality, privacy, and information security obligations proportionate to the nature of the services being provided.
Personal information is disclosed only to the extent reasonably necessary for the relevant purpose, and VRS does not authorise recipients to use that information for unrelated commercial purposes or to independently commercialise personal information entrusted to them.
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Service Providers and Technology Platforms
Like many modern businesses, VRS relies upon carefully selected third-party technology providers and professional service providers to support the secure and efficient operation of its business.
These providers may assist with cloud hosting, customer relationship management, applicant tracking systems, communication platforms, productivity software, website hosting, payment processing, accounting services, cybersecurity, data storage, marketing platforms, scheduling systems, analytics tools, customer support software, document management, electronic signature platforms, and other operational services.
Where personal information is processed by these providers, VRS seeks to ensure that appropriate contractual arrangements, confidentiality obligations, technical safeguards, and organisational controls are implemented to protect the information throughout the processing lifecycle.
These providers process personal information solely for the purpose of providing services to VRS or supporting the delivery of services to our customers. They are not authorised to purchase, own, or commercially exploit personal information for their own independent purposes merely because they provide technology or operational services to VRS.
VRS periodically reviews its relationships with key service providers as part of its broader governance and vendor management framework to ensure that providers continue to maintain appropriate standards of privacy, confidentiality, security, and responsible information handling.
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Marketing, Analytics and Website Technologies
VRS may use website technologies, cookies, analytics platforms, customer relationship management systems, marketing automation platforms, and similar technologies to improve website functionality, measure website performance, understand visitor behaviour, improve customer experience, support legitimate marketing activities, and enhance the quality of our services.
These technologies may process certain categories of information relating to website usage, browser configuration, device information, referral sources, page interactions, marketing preferences, and similar technical information necessary to support website functionality and business analytics.
The use of these technologies should not be interpreted as the sale of personal information. Rather, they are used to operate, maintain, improve, secure, and optimise the VRS website and related business systems.
Where advertising, analytics, marketing, or tracking technologies are used, VRS seeks to implement them responsibly and transparently, and individuals may have choices regarding the use of certain non-essential technologies through browser settings, cookie preferences, or other privacy controls where available.
Further information regarding cookies, analytics technologies, and similar tools is provided within the VRS Cookie Policy, which should be read together with this Notice.
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Your Privacy Choices
VRS believes that individuals should understand how their personal information is handled and should be able to make informed choices regarding the use of that information where reasonably practicable and permitted by applicable law.
Depending upon the nature of an individual's relationship with VRS and the privacy legislation that applies, individuals may have the ability to request access to personal information, request correction of inaccurate information, request deletion of personal information in certain circumstances, object to particular processing activities, withdraw consent where consent has been relied upon, manage marketing preferences, request additional information regarding VRS's information handling practices, or enquire about the disclosures described within this Notice.
Because VRS does not sell personal information as part of its business model, requests to opt out of the sale of personal information will generally be satisfied by confirming that VRS does not engage in such activities.
Where an individual believes that personal information has been handled inconsistently with this Notice or wishes to exercise applicable privacy rights, VRS encourages them to contact us so that the matter can be reviewed promptly and professionally.
VRS is committed to responding to legitimate privacy enquiries transparently, respectfully, and in accordance with applicable privacy legislation, while taking reasonable steps to verify identity and protect the security of personal information before acting upon any request.
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Identity Verification
To protect the privacy, confidentiality, and security of personal information, VRS may take reasonable steps to verify the identity and authority of any individual submitting a request under this Notice before disclosing information or taking action in relation to that request.
Verification procedures are intended to ensure that personal information is not disclosed to unauthorised individuals and that privacy rights are exercised only by the individual concerned or by a person who has appropriate legal authority to act on their behalf.
Depending on the nature of the request and the sensitivity of the information involved, VRS may request additional information reasonably necessary to verify identity, confirm authority, clarify the scope of the request, or obtain further information required to process the request accurately.
Where VRS is unable to reasonably verify the identity or authority of the individual making the request, VRS may decline to provide access to personal information or take the requested action until satisfactory verification has been completed.
Any information collected for identity verification purposes will itself be handled in accordance with VRS's Privacy Policy, GDPR Policy, Data Protection Policy, and applicable privacy legislation, and will only be retained for as long as reasonably necessary to complete the verification process and comply with applicable legal obligations.
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Non-Discrimination
VRS supports the principle that individuals should be able to exercise applicable privacy rights without fear of unfair treatment or disadvantage.
Accordingly, where an individual exercises rights available under applicable privacy legislation or submits a request under this Notice, VRS will not intentionally discriminate against that individual solely because they have exercised those rights.
Subject to applicable law and contractual obligations, VRS will not refuse to provide services, intentionally reduce the quality of services, impose unreasonable restrictions, or otherwise disadvantage an individual solely because they have requested information regarding VRS's privacy practices, exercised available privacy rights, or sought clarification regarding the handling of their personal information.
Nothing contained within this Clause prevents VRS from applying legitimate operational, contractual, commercial, security, or legal requirements that are reasonably necessary for the delivery of services, the protection of personal information, compliance with applicable legislation, or the operation of its business.
Where the exercise of a particular privacy right affects the ability of VRS to deliver certain services, VRS will seek to explain the practical consequences of that request and work constructively with the individual to identify an appropriate solution where reasonably practicable.
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Relationship with Other Privacy Documents
This Notice forms one component of VRS's broader privacy and information governance framework and should not be interpreted in isolation.
While this Notice specifically explains VRS's position regarding the sale and sharing of personal information, additional information regarding the collection, use, processing, disclosure, protection, retention, international transfer, and management of personal information is contained within the VRS Privacy Policy, GDPR Policy, Data Protection Policy, Cookie Policy, Terms of Use, and other governance documents published within the VRS Legal Centre.
Where a particular issue is addressed in more than one VRS policy, those documents should be read together so that they operate consistently and complement one another.
Nothing contained within this Notice limits, replaces, or overrides any rights or obligations established under applicable privacy legislation, contractual arrangements, Data Processing Agreements, customer agreements, Statements of Work, or other legally binding documents.
In the event of any inconsistency between this Notice and applicable legislation, the relevant legislation will prevail to the extent required by law.
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Review of this Notice
VRS may periodically review, update, amend, supplement, replace, or withdraw this Notice to reflect changes in privacy legislation, regulatory guidance, business operations, service offerings, technology platforms, information governance practices, customer requirements, or recognised industry standards.
As privacy expectations and legal obligations continue to evolve internationally, VRS is committed to maintaining a transparent and current approach to the handling of personal information and to ensuring that this Notice accurately reflects our business practices.
Material changes may be communicated through the VRS website, customer communications, contractual documentation, or other appropriate channels where considered necessary.
The most current version of this Notice will be published within the VRS Legal Centre and will become effective from the date specified in the published version unless otherwise stated.
Continued interaction with VRS following publication of an updated Notice may constitute acknowledgement of the revised Notice to the extent permitted by applicable law and any contractual arrangements between the parties.
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Contact Information
VRS welcomes enquiries regarding this Notice and encourages individuals to contact us if they have questions about how personal information is handled or wish to better understand the principles described within this Notice.
Individuals who wish to enquire about the collection, use, disclosure, or protection of their personal information, exercise applicable privacy rights, request further information regarding this Notice, or raise concerns regarding VRS's privacy practices are encouraged to contact us using the details below.
Privacy Enquiries
Legal & Compliance Enquiries
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Website: virtualrecruitment.solutions
VRS is committed to maintaining the trust placed in us by our customers, candidates, independent contractors, suppliers, and other stakeholders through responsible information governance, transparent privacy practices, and the ongoing protection of personal information. Our business is built upon delivering exceptional recruitment support services, not upon the commercial sale or exploitation of personal information entrusted to us.