Privacy Policy

Effective Date: August 2023

LevelUP HCS, LLC (“LevelUP”, “we”, “us” or “our”) is committed to protecting and respecting your privacy. This notice informs you of our practices regarding the collection, use and disclosure of personal information we receive from users of our online presences and services.


1.      Scope of this Privacy Notice 

This Privacy Notice applies to anyone who visits our online presences and interacts with our services and respective brands – LevelUP HCS and Upward Talent. This Privacy Notice provides details about the personal information we collect about you including how we use it as a personal information controller, how we protect it, and your rights as an individual in relation to its collection, storing, and processing. We also provide you with further legal information and/or privacy notices as necessary, depending on the way we interact with you and the services we provide to you. 


2.      How We Collect Personal Information 

We may collect personal information about you from various sources including when you use or interact with our online presences and services. This includes contact by phone, by email, through interactions with and use of our Website and any other online presences, including but not limited to any online web forms you complete and submit, by physical mail, by filling out an application or other forms relating to our services, or through your contact and interaction with us on social media, forums, or through surveys we send you.  

We may also collect personal information from our clients in relation to employment/job placements, or feedback on our services. 

Sometimes we may also require you to provide us with relevant personal information for contractual or legal reasons related to our services, or in relation to employment or a job placement. We will provide you with proper notice when such information is required. If you do not provide personal information when requested, you may not be able to use our services if that information is necessary to provide you with the service or if we are legally required or have other legal grounds to collect it. 

We collect information during your interactions with our website and this information may be shared with our website service providers.  Please see “Cookie Notice” below for more information. 


3.      Categories of Personal Information We Collect 

We may collect various categories of personal information from you, which may include: 

  • Contact information, such as your name, address, email address, and phone numbers; 
  • Professional or employment-related information, which may include, for example, employment and educational history, qualifications and skills, reference information, background check information, compensation or compensation expectations, ability to work in the United States or other countries, languages spoken, and other information contained in your resume; 
  • Any personal information in emails, attachments, and other communications that you send us or otherwise contribute (such as resumes or posts to forums); 
  • Relevant personal information for contractual or legal reasons when you are using our services or in relation to employment. For example, we may ask you for details of social security numbers, or locations/jurisdictions to determine if, and how much, tax we need to collect from you.  
  • Due to the nature of our business, we may collect personal such as email and contact information considered to be sensitive under some jurisdictions.  We take appropriate measures to protect your sensitive information through technical controls like encryption, limiting user access, and sticking to specific data retention schedules. 
  • Data used by our Website service providers or for Website analytics and research, that is used to evaluate, provide, protect, or improve our Website and service offerings. This combined personal information may include but not limited to IP addresses, preferences, web pages visited prior to coming to our Website, information about browser, network, or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), and information about how you interact with our Website (such as timestamps, clicks, scrolling, browsing times and load times).  
  • Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Account (based on your privacy settings with such Third Party Service). 

4.      What We use Personal Information For

We use the personal information we obtain about you to perform our principal businesses purposes, which may include, but are not limited to: 

  • Communicate with you, including, but not limited to, sending you emails related to employment, marketing, and service-related announcements. 
  • Evaluate job applications and communicate with applicants. 
  • Perform our services and principal business purposes, including, but not limited to, maintaining accounts and contracts, providing customer service, fulfilling transactions, performing background checks, or verifying information.  This may also include, but not be limited to, performing job interviews, providing candidate feedback, or performing placement of job candidates and contractors. 
  • Perform marketing or offer relevant details and informational updates related to our services. 
  • Administer surveys, contests, and other promotions. 
  • Manage our partner, service provider, or customer relationships. 

We also use personal information we obtain from you to perform other services where we have legal basis to do so, including, but not limited to: 

  • Analyze your interactions with our services so we can advertise or promote additional service offerings to you where we have legal basis to do so. 
  • Undertake activities to verify or maintain the quality of the services being provided, including to handle and respond to complaints or questions. 
  • Detect, investigate, and prevent activity we think may be potentially illegal, unlawful, or harmful and to enforce our Privacy Policy and/or our terms or any other purpose referenced herein or therein. 
  • Act in the public interest, in line with any laws that apply. 
  • Comply with applicable legal requirements, such as other government regulations and industry standards, contracts, and law enforcement requests.


5.      Legal Basis for Collecting and Using Your Personal Information 

We process your personal information for the above purposes when we have a legal basis to do so. This includes: 

  • You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time. Details of how to exercise your rights are set out in the “Your Privacy Rights” section below.   
  • We need your personal information to provide you with our core business services and products requested by you, or to respond to your inquiries. 
  • We have a legal obligation to collect and/or use your personal information, such as to comply with applicable government regulations or to comply with a court order or law enforcement request. 

Considering applicable laws as well as your individual interests, rights, and freedoms, we may also collect or use personal information for a number of legitimate interests. These legitimate interests may include, but are not limited to: 

  • To manage our relationship with you, and any service providers who provide products or services for us (for example, to check that you have received a service, to validate payment for invoices, to provide any relevant marketing, etc.). 
  • For research and analysis so that we can monitor and improve our services and Website. 
  • To enforce or apply our policy terms and conditions or other contracts, or to protect our (or our customers’ or other people’s) rights, property, or safety. 
  • To exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with. 
  • To take part in, or be the subject of, any sale, purchase, re-structuring, merger or takeover of all or part of our business. 

Sometimes we require you to provide us with information for contractual or legal reasons when you are using our services. For example, we may ask you to select your jurisdiction to determine the tax collection amount, if any, needed from you. This is a typical business purpose and we will typically provide you with reasonable notice when such information is required. If you do not provide personal information when requested, you may not be able to use our services if that information is necessary to provide you with the service or if we are legally required to collect it. 


6.      Collection of Personal Information from Minors 

Our online presences are not designed or intended to attract children under 16 years of age, and we do not knowingly collect information from minors. By using our Websites, you hereby represent that you are at least the age of legal majority in your place of residence. 


7.      Links to Third-Party Websites  

Our online presences may also contain links to and marketing from the websites of third-parties. We have no control over the content or operation of these websites, nor do we control the confidentiality or privacy practices of the website operators. Consequently, any personal information you submit through such website is governed by the privacy policies of the website in question. It is therefore your responsibility to find out about the third-party policies to protect your personal information when visiting these third-party websites.  By using our online presences in accordance with this privacy policy, you release LevelUP HCS from liability for actions of third-parties and/or social media platforms linked to our online presences. 


8.      Third-Party Processors 

Our carefully selected partners and service providers may process personal information about you on our behalf as described below: 

  • Digital Marketing Service Providers
    • We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:
      • (i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here:  
      • (ii) Sopro is registered with the ICO Reg: ZA346877. 
      • (iii) The Sopro Data Protection Officer can be emailed at: 

9.      Marketing and Preferences 

We may use your personal information to send you marketing through various channels (mail, phone, social media, email, or text). However, we only use your personal information to send you marketing material if we have your consent or a legitimate interest, as described above in the “Legal basis for Collecting and Using Your Personal Information” section. If you do not want to receive direct marketing from us, you have the right to object - for example opting out by clicking on any ‘unsubscribe’ links that appear in emails we send or contacting us at to update your contact and marketing preferences. 


10.  Sharing Your Information 

We may disclose to third parties, including our clients and service providers, any of the categories of personal information outlined in the “Categories of Personal Information We Collect” section above, where we have legal basis to do so. However, we normally share only the minimum relevant personal information that is required to fulfill the business purpose for sharing. 

We may disclose, or may have disclosed, personal information to the following categories of third parties: 

  • Clients and prospective clients - for example, clients may request professional and employment-related information for purposes of evaluating our consultants’ skills, qualifications, and experience. Clients may also need to approve and process timesheet information for consultants and contractors and collect other personal information relevant to the client project. 
  • Service providers who perform business functions and services on our behalf such as the provider of our customer relationship management software, or our Website; 
  • Business partners - for example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing. 
  • Payment Processors. We transmit your personal information via an encrypted connection to our payment processor.   
  • Regulatory authorities, government authorities, courts, or other third parties wherever legally required of us or if we reasonably believe that such action is necessary and can be taken legally to protect the safety, rights, or property of LevelUP, our employees, our clients and service providers, any other third-party affiliates, national security, or the general public; 
  • Advertisers, with appropriate consent, so they and we can provide you with tailored advertising and measure and monitor its effectiveness.  
  • Any third parties who are involved in or the subject of any sale, purchase, re-structuring, merger or takeover of all or part of our business. 

Please note that LevelUP does not sell your personal information and has not sold any personal information. 


11.  Protection of Personal Information 

We use reasonable administrative, technical, and physical safeguards to protect your personal information - taking care of the integrity and availability of the personal information and avoiding its damage, loss, alteration, destruction, or unauthorized use. Personal information collected about you will be handled only by authorized personnel and in compliance with applicable laws and regulations to ensure it is appropriately safeguarded. 

However, no safeguards can be guaranteed to be 100% effective in securing all personal information across all the environments, which includes LevelUP, our service providers, and our clients. If you have reason to believe that your or others’ personal information is no longer secured appropriately, please immediately notify us at 


12.  How Long We keep Your Personal Information 

Whenever we collect, use, or store your personal information, we keep it for as long as is necessary for the purpose for which it was collected, unless there are legitimate business, legal, or regulatory compliance reasons for retaining the personal information for a longer period of time. 


13.  Processing in the United States and Internationally 

We are headquartered in the United States and we will process your personal information in the United States. Your personal information will be transferred to and stored in the United States. 

If we transfer personal information outside of the European Economic Area (EEA) we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law, like data protection agreements, your express consent, and other devices. For further information as to the safeguards we implement please contact


14.  Cookies Notice 

This Cookies Notice applies when using our Website. 

A cookie is a small piece of data that a website, when visited by a user, asks your browser to store information on your device to remember you, such as your language preference. We do not use cookies on our Website with the intention to collect your personal information.  

Cookies set by us on our Website are called “first-party” cookies, used to help evaluate and enable website performance and functionality. We also use “third-party” cookies, which are cookies from a website domain other than our Website. These are used for our Website analytics, site functionality, marketing efforts, and to share data with the relevant third parties.  

The first time you visit our Website, a banner will display providing you with information about cookies used on our Website. Also, if you do not want cookies to be placed to gather data related to your Website usage, you are given the choice of declining or accepting cookies through the Website’s cookie notification banner. If, however, you do not accept cookies, you may experience some inconvenience or a loss of certain features in your use of our Website. 

We use the following types of cookies for the following purposes: 

  • Strictly Necessary Cookies: These cookies are necessary for our Website to function and cannot be switched off in our systems. They are usually only sent in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the site will not work. These cookies do not store any personal information. 
  • Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. 
  • Functional Cookies: These cookies enable the website to provide enhanced functionality. They may be set by us or by third parties whose services we have added to our pages (for example, adding maps to show our locations).  
  • Targeting Cookies: These cookies may be set on our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store personal information but are based on uniquely identifying your browser and internet device. 


15.  Your Privacy Rights 

Depending on the jurisdiction you reside in, you may have certain rights in relation to the personal information we have collected about you:  

  • Right of Access:  You may have the right to make a request for details of your personal information and a copy of that personal information.  
  • Right to Rectification:  You may have the right to have inaccurate information about you corrected or removed. 
  • Right to Deletion:  You may have the right to have certain personal information about you deleted from our records. 
  • Right to Restriction of Processing:  You may have the right to ask us to use your personal information for certain specified purposes only. 
  • Right to Object to Processing:  You may have the right to object to us collecting, using, sharing, or storing (collectively “processing”) your personal information in certain cases.  
  • Right to Portability:  You may have the right to ask us to transfer your personal information to another company or individual in a computer-readable format. 
  •  Right in relation to Automated Decision Making:  You may have the right to not be subject to automated decision making, or the right to have a manual review of the decision, as well as be informed of information regarding the logic used to make any automated decisions. 

These rights are not absolute and do not always apply in all cases, for example residents of non-EU countries may not be entitled to certain rights. We will let you know in our correspondence with you whether and how we will be able to meet your request relating to your rights and will never discriminate against or provide discriminatory treatment to any individuals exercising their privacy rights under applicable regulations. If we are not able to meet your privacy rights request, we will explain why, and provide details of any further action you may take, for example how to appeal against a decision or contact a relevant data protection supervisory authority. 

To make a request related to the above privacy rights, please contact us using the information below. When submitting a rights request, please include your name, the rights you are wishing to exercise, any action you would like HCS to take to address your rights, and the best mode of communication for us to contact you at. 
LevelUP HCS Headquarters
90 Broad Street, Suite 901
New York, NY 10004

After we receive your request, we will review it within the time frame required by applicable law.  We will use the preferred mode of communication you noted in your rights request to contact you regarding request status or if any further information is needed to complete your request.

EU Residents have the right to lodge a complaint with the relevant data protection authority where you think we have not used your personal information correctly or met your rights in compliance with relevant data protection law. You can find the contact information for the EU Data Protection Authorities here: 


16.  Questions and Contacts 

We hope this Privacy Notice has been helpful in setting out the way we handle your personal information and your rights to control it. For any questions or comments in relation to this privacy notice and our privacy practices, please contact at: 
LevelUP HCS Headquarters
90 Broad Street, Suite 901
New York, NY 10004


17.  Changes to Our Privacy Notice 

We will review and may make updates to our privacy practices from time to time. If we review and/or make any material changes to our privacy practices, we will update this privacy notice and change the effective date of the notice.