Privacy Policy

Last updated: 7/18/2024

This is the Privacy Policy for the Kirby Bates Associates, LLC (“Company”, “we”, “us”, “our”) By using this website, you acknowledge the terms of this Privacy Policy.

California residents should also review the California Privacy Rights section below.

This Privacy Policy supports our privacy principles and informs you about our practices for gathering, storing and using the personal information of individuals who use our websites, or who apply for, register to use or use our staffing and recruitment placement services (“Services”).  We reserve the right to make changes to this Privacy Policy from time to time, and we encourage you to read it periodically.

This Privacy Policy applies to our website and other applications where this Privacy Policy is posted.  Please remember that if you post any of your personal information in the public areas of our website, that information could be collected and used by third parties over whom we have no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of our website. You are responsible for informing yourself of the privacy policies of the websites provided by third parties accessible through a link on this website.  

Information We Collect

When you visit and interact with this website, we collect information about you, including Personal Information. “Personal Information” means information that identifies (whether directly or indirectly) you or otherwise relates to you, as well as information required to be defined as Personal Information under the law. We may also collect information externally from this website, such as information regarding candidates who secure placements through the Company, information regarding clients who post opportunities on our job board and information regarding clients who secure candidates through the Company.  This information enables us to profile the interests and needs of candidates and clients, post and solicit applications for staffing opportunities and track the status of job openings.

The following identifies the categories of Personal Information we collect directly from you (or about you) and how we collect such data:

  • Staffing and Career Opportunities : If you are a candidate and apply for a staffing  opportunity with us through us or for a career opportunity, we may collect Personal Information and other information from you, which may include your contact information (your name, physical address, telephone number, e-mail address), qualifications (education, training courses and internships, and work experience), skill sets (for example, foreign language skills) and any other information you listed on your resume or CV, including but not limited to licensure. 
  • Online Forms and Accounts: When you complete an online form or create an account on our website, we may collect identifiers such as your name (first and last), e-mail address, telephone number, physical address, professional or employment-related information, and online user account details.  You are also able to import and store resumes, CVs, cover letters, transcripts and work samples on our website.
  • Communications with Us Online: We will collect any Personal Information you provide to us when you use our contact forms for example “Contact Us”.  Providing us with your Personal Information via our contact forms is not required; however, please note that fields marked with an asterisk (*) are mandatory fields, because we have determined we need this information to comply with or respond to your request, or to improve your future experiences with us and our website. Other information or Personal Information you share with us when completing our contact forms is at your sole discretion. If you contact us, we will keep a record of that correspondence in accordance with our established retention protocol.
  • Client Staffing and Recruitment Needs: If you are a representative of a facility or client interested in our Services, we may collect Personal Information and other information about you in connection with your facility’s staffing and recruitment needs, including without limitation, your name (first and last), company name, job title, job function, job level, industry, staffing challenges, current recruitment model, your location, experience working with our industry, purpose of attendance (at an event), size of opportunity, and type of staffing or recruitment needs.
  • Marketing: We also may collect information for marketing purposes and analysis, including information on how you respond to email, SMS, phone and other marketing campaigns as well as feedback you provide about us and our Services through our satisfaction surveys.  Messaging and data rates may apply for any SMS, MMS, and other electronic communications (typically, this is based on your carrier and service plan).   
  • Social Media, Online Forums, Blogs, Message Boards: We also may collect Personal Information and other information about you when you choose to interact with us through social media platforms on which we are active. In addition, we may collect the Personal Information you make available on your public social network profiles and on other public locations, including, without limitation, on Facebook, LinkedIn, Twitter, Instagram, or other websites and/or job boards of other companies. The Personal Information we collect in this manner may include identifiers (name, first and last, contact information, and location) and qualifications (education, training courses and internships, and work experience), skill sets (for example, foreign language skills), professional or employment-related information (education and work experience), and any other information you make available on social media platforms and other public locations.
  • Cookies and Automated Technology: Our website uses cookies and other similar technologies to collect and store information about you and your browsing history. These typically involve pieces of information or code that the website transmits to you and which are stored in your browser, on your computer’s hard drive or on your mobile device. Cookies and similar technologies sometimes track information in order to remember you and your browsing preferences. We use these cookies and other technologies on the basis that they are necessary for us to provide you with our Services, , and/or because using them is within our legitimate interests (described below) and, in some cases, where required by law or where you have consented to their use. If you would like to delete cookies or instruct your web browser to delete or refuse cookies, visit the help pages of your web browser. Please note, however, that if you delete cookies or decline acceptance of them, you may not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages may not display properly.

You are not obliged to provide your personal information to us, but please note it is not possible for us to provide our Services to you or otherwise work with you if, if you do not provide us with the required minimum information. It may also limit the Services that you can receive from us if you choose to provide us with limited Personal Information.

How We Use Your Personal Information

We use a staffing candidate’s Personal Information to provide our Services to the candidate, including making the candidate aware of placement opportunities and other developments from time to time.  We use a client’s Personal Information to attempt to meet the client’s staffing and recruitment needs and to otherwise establish and/or strengthen our business relationship with the client, including by sharing with you how we can assist you with our Services.  We use a potential employee’s information to evaluate the employee’s application(s) for a position with our Company.  

We may use your Personal Information for commercial purposes such as for marketing and promotional purposes, statistical analysis of users’ behavior, product development, content improvement, or customization of the content and layout of our website.  Our Company may, on occasion, also send emails to you about our Services or information you requested from the website or third-party products.  If you do not want to receive email from us, visit the “unsubscribe” link at the bottom of any email from us to remove yourself from continued receipt of our email messages. 

We retain your Personal Information as long as necessary to fulfil the purposes set out in this Privacy Policy in accordance with applicable legal and regulatory requirements.

Legitimate Interests

We may use your Personal Information whenever is necessary for our legitimate interests (or those of a third party). This includes where use of your Personal Information is necessary to:

  • ensure effective administration and management of your placement, management of the business and business continuity;
  • comply with applicable laws and regulations;
  • ensure our assets are protected, kept confidential, and not used for inappropriate or unlawful purposes;
  • prevent, detect, or investigate unauthorized use of our systems and ensure we comply with law and our policies;
  • ensure that we can contact you or your family in case of an emergency;
  • check that you are legally entitled to work;
  • manage training and development requirements; 
  • maintain product development and enhancement, along with effective marketing through analytics and profiling for business intelligence;
  • handle disputes and accidents and obtain legal or other professional advice; 
  • prevent fraud and financial crime; and
  • ensure network and information security.

Sharing with Third Parties

Our Company may have occasion to share your information with third parties. We may do so to facilitate our efficient use of your information, including your Personal Information, and to provide you with content and/or resources, to fulfil a request you make of us, or to otherwise provide our Services. We disclose your information, including the Personal Information identified in the “Information We Collect” section above, to the following third parties:

  • Clients: If you are a staffing candidate, we will present your information, with your permission, to clients who are interested in your profile, in response to their placement opportunities.

  • Compliance Regulators: Once we establish and maintain an employment relationship with you, we may use the data you provided to comply with state and federal laws and regulations. For the purposes mentioned above, the Company may transfer your personal data to other affiliate entities that provide services on behalf of the Company.
    • Service Providers and Vendors: We may engage service providers to carry out administrative and operational work in support of our relationship with you. These vendors are subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and they will only have access to and use the data they need to perform their functions. For example, relevant vendors are typically IT vendors or back-office finance and accounting management providers. We prohibit third-party service providers from using your Personal Information for their own purposes We require them to utilize your Personal Information only for the specified purposes for which they are engaged, such as processing accounts payable or hosting and supporting our IT systems, and they are required to keep your Personal Information confidential.

  • Affiliates perform a range of services, including but not limited to temporary and direct hire placement services, vendor management services, information technology and consulting services. We may share your information with affiliates that provide IT, legal, marketing, or accounting and finance functions in furtherance of the Services we provide.
    • Government and Law Enforcement: We will share your data with government, regulators or law enforcement agencies if, at our sole discretion, we determine that we are legally obliged or authorized to do so or we believe it would be prudent to do so;
    • Corporate Reorganization Participants: As part of due diligence relating to or execution of a merger, acquisition or other business transaction, we may need to disclose your information to a prospective seller or buyer and their advisers.

Cookies and Similar Technologies

When you visit our Services, we may obtain certain information by automated means, such as cookies, web beacons, and other similar technologies and techniques. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information that we and our third party service providers may track with cookies, web beacons, and similar technologies may include the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Services, your IP address, your home domain or Internet service provider, your referrer URL (the URL for the website that you were viewing prior to visiting the Services), how you were directed to the Services, which specific pages you access on the Services, how long you view each page, the time and date you access our Services, and the total number of visitors to the Services and any portions thereof.  

Most popular Internet browser applications will allow you to adjust the browser so as not to accept cookies. For mobile devices, you can manage how your device and browser share certain data by adjusting the privacy and security settings on your mobile device. However, making such adjustments may, in certain instances, prevent you from taking full advantage of the Services (or some portion thereof) and its capabilities, or cause some features of the Services to function improperly or more slowly. 

Google Analytics

Our Company may use Google Analytics, a web analysis service provided by Google, together with other analytics services, in order to better understand your use of the Services and how we can improve them. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other directly identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a persistent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google Analytics uses its cookie(s) and the information Google Analytics collects to track your online activities over time and across different websites when you use our Services, and other websites. Google’s ability to use and share information collected by Google Analytics about your visits to the Services are governed by the Google Analytics Terms of Service and the Google Privacy Policy. Google may utilize the data collected to track and examine the use of the Services, to prepare reports on its activities, and share them with other Google services. To more fully understand how Google may use the data it collects through the Services, please review “How Google Uses Information From Sites or Apps That Use Our Services” (located here). 

Except as defined under California law and explained below, we do not sell your Personal Information to third parties. 

Your Choices Regarding Your Personal Information

Disabling Cookies and Managing the Collection of Your Personal Information. Some computer browsers permit you to disable or uninstall cookies and you may do so by following the instructions provided by your hardware or software vendors.  Please note that by disabling cookies you may not be able to take full advantage of the Services offered by our website and may adversely affect your user experience on our website. 

Do Not Track. We respond to widely recognized consent preference signals that you may send through your browser, such as Do not Track signals or the Global Privacy Control. Our recipient of these signals will disable certain cookies and other online trackers. 

Commercial E-mails, Newsletters, and Other Communications.  When we send marketing or other communications to you, you may opt out of receiving any further communications by contacting us or using the ‘unsubscribe’ or ‘opt-out’ function when available. You can also exercise your opt-out right at any time by contacting us using the information listed in the “Contact” section below and providing the following information: your name, your email address, a contact telephone number, and the marketing communications you would like to opt out of receiving.

International Users

By accessing and using our website, you acknowledge and agree that our Company controls and operates all parts of its website from its offices in the United States of America and that the website is intended for use by users located in the United States of America.  Unless expressly stated to the contrary, the Company makes no representation that the website is appropriate or will be available for use in other countries.  If you access the website from outside the United States, you acknowledge and agree that your information may be transferred to and maintained on computers and servers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may be different from those in your jurisdiction.  Your consent to the terms of this Privacy Policy and other applicable terms, rules or policies represents your agreement to the transfer of such information to the United States and the collection, use and potential disclosure of such information in accordance with United States law and our Privacy Policy.  

Data Security

We maintain commercially reasonable security safeguards designed to protect the Personal Information we collect against unauthorized use, disclosure, alteration or destruction. Please be aware that no security solutions are infallible.  Although we aim to protect the security and integrity of the Personal Information we collect, we cannot guarantee or warrant that any information, during transmission through the Internet or while stored on our system or otherwise in any case, is 100% secure from intrusion by others. If you have reason to believe that your interaction with us is not secure or that data has been compromised, please immediately notify us of the problem by contacting us using the contact information below.

California  Privacy Rights

You have certain legal rights with respect to the Personal Information that you provide and/or which we obtain about you. These rights are dependent upon the state and/or country where you reside.  For example, if you are a resident of California, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100, et seq.) provides you with specific rights regarding your Personal Information depending on the nature of your relationship with us.   All terms not defined in this portion shall have the meanings as defined under the CCPA.

In the 12-month period before the effective date of this Privacy Policy, we may have collected the following categories of personal information about consumers:

  • Identifiers such as real name, , postal address, Internet Protocol address, email address, 
  • Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
  • Geolocation data.
  • Professional or employment-related information.
  • Education information
  • Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Categories of Sources from Which Personal Information is Collected

We may have collected personal information about you form the following categories of sources: 

  • Directly from you.
  • From your devices.
  • Other companies, such as our service providers and vendors.
  • Government entities.
  • Social networks (but only if our Company is mentioned).
  • Data analytics providers. 
  • Other available sources, such as public records. 

Business or Commercial Purpose for Collecting Personal Information from Consumers

We may have collected personal information for any of the business or commercial purposes set forth in the “How We Use Your Personal Information” section of this Privacy Policy. 

We retain the personal information that we collect to achieve the purposes for which the personal information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law.

Categories of Personal Information Sold or Shared to Third Parties


Category of Personal Information Category of Third Party
  • Advertising providers, data analytics providers
Commercial Information
  • Advertising providers, data analytics providers
Online Activity and Geolocation Data
  • Advertising providers, data analytics providers


We do not knowingly sell or share the personal information of consumers under 16 years of age.

CCPA Rights

If you are a California resident, you have the following rights regarding your personal information: 

Where applicable, your rights include, among others:

  • Right to be Informed About Collection, Sale or Disclosure:  You have the right to be informed of the categories of Personal Information that we collect about you as well as the categories of sources from which the Personal Information was collected. You also have the right to be informed of the business or commercial purposes for which we use, disclose, or sell, your Personal Information as well as the categories of third parties with whom we share that Personal Information, as set forth in this Privacy Policy.
  • Right to Access and to Obtain a Copy of Your Personal Information:  You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your Personal Information over the past 12 months. Once we have verified your identity, we will disclose the specific pieces of Personal Information we collected about you in a portable and, to the extent technically feasible, in a readily useable format.  
  • Right to Delete:  In certain circumstances, you may have the right to request that your Personal Information is deleted, subject to legal rights or obligations where we need to retain the data.  For situations where, in accordance with law, we determine that your request to delete must be granted, we will do so without undue delay.  Please bear in mind, once your data is deleted, our Company may not be able to provide you with Services anymore.  If you wish to re-register with our Company again, you will need to re-enter your data.
  • Right to Opt-Out of the Sale or Share of Personal Information: We do not sell your information. You may opt out of “sharing” or “selling” (as described above) by setting a browser-level opt-out, the Global Privacy Control, sent by California consumers. You may learn how to set that signal by going to this website:
  • Right to Equal Service for Exercising Your Privacy Rights:  Unless permitted by applicable law, we will not discriminate against you when you exercise your privacy rights under the California Consumer Privacy Act or other applicable law, including by: denying you goods or Services; charging you different prices or rates for goods or Services, including through the use of discounts or other benefits or by imposing penalties; providing you with a different level of quality of good or Services; or suggesting that you will receive a different price or rate for goods or Services or a different level of quality of goods or Services.
  • Sensitive Personal Information: We may still use your sensitive personal information for certain limited purposes, such as the following (so no right to limit our use of such information applies): (1) performing our service or providing goods, (2) detecting security incidents, (3) resisting malicious, deceptive, fraudulent, or illegal actions, (4) ensuring physical safety, (4) for short-term transient use, including certain non-personalized advertising, (5) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services, and (6) to verify and maintain the quality or safety of a service or product to improve, upgrade, or enhance a service or product. 

To exercise your CCPA rights, please use the contact information listed in the “Contact” section below.  You may also opt out of sharing of selling by setting the Global Privacy Control.

Verifying Your Identity

In order for you to exercise the rights described above, it may be necessary for us to verify your identity or verify your authority to make the request and confirm that the Personal Information relates to you (by, for example, requesting that you provide us with valid identification to confirm your identity). 

For residents of California only, you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.  Making a verifiable consumer request does not require you to create an account with us.

Shine the Light

California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the information listed in the “Contact” section below.

Children’s Privacy

Our website is designed and intended for adults. By accessing and/or using our website, you represent that you are a legal adult.  

Our website is not intended for, and we do not knowingly collect information from or otherwise market our website or other materials to children under thirteen (13) years of age. If you are a parent or guardian of a child under the age of thirteen (13) and believe that he or she has disclosed Personal Information to us, please contact us using the information listed in the “Contact” section below. You may review and request the deletion of your child’s Personal Information or prohibit the further use of such information. 

Changes to This Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time. We shall publish any material changes to this Privacy Policy through appropriate notices on our website. The date this Privacy Policy was last revised is identified at the top of the Privacy Policy.

Reporting Suspicious Activity

If you become aware of any potentially fraudulent activity on our website or via other communication methods (e.g., email) please contact us at, so that we can follow up with appropriate actions.  We take these matters very seriously.


If you have any questions, comments or concerns regarding this Privacy Policy, please contact us.