Privacy policy

Last updated: April 7, 2023


At Brain Gain Recruiting, LLC d/b/a Sourcing Certification (“Sourcing Certification”) we take your privacy rights, and your expectation of privacy, very seriously.

This Privacy Policy describes Sourcing Certification’s policies and procedures regarding the collection, use and disclosure of information, which you provide when you use Sourcing Certification’s (the “Site”), when you use the related services and features offered on the Site, and when you subscribe to, register for Sourcing Certification’s classes and programs (the Site, the related services and features, including Sourcing Certification’s classes, webinars, programs, and any other products and/or services offered by Sourcing Certification are collectively referred to as the “Sourcing Certification Products”).

Sourcing Certification will not use or share your information obtained through your use of the Sourcing Certification Products for any purpose or with anyone except as described in this Privacy Policy. However, please note that this Privacy Policy does not apply to information we collect by other means or from other sources.


Information You Provide. When you access the Site, subscribe to, register for or participate in classes, programs or webinars, view recordings thereof, or make purchases of any Sourcing Certification Products, or at other times, we collect and store personally identifiable information (generally defined to mean information that can be used on its own or with other information to identify, contact or locate a single person, or identify an individual in context) about you that may include, your name, postal and e-mail addresses, professional affiliation, information regarding your computer system, and other information.

We request certain information from you if you make a payment from the Site. You must provide contact information, such as your e-mail address, and payment information, such as a credit/debit card number and the expiration date. Payment information is used for payment processing purposes only. We use a credit/debit card processing company to process credit/debit card charges for Sourcing Certification Products. We do not retain, share, store or use credit/debit card information for any secondary purposes (subject to Federal, state law including the California Public Records Act, and applicable non-US law such as the European Union’s General Data Privacy Regulation, or “GDPR”) and will exercise reasonable care, but no less than the care required by applicable laws, to prevent disclosure or use of credit/debit card information.

Information Provided By Third Parties. We may from time to time obtain information about you from third-parties such as business partners, mobile carriers or other companies. If you use your login credentials from a social networking site (“SNS”) to use a Sourcing Certification Product, we may receive information from such SNS in accordance with the terms and conditions of the SNS. We may use any information about you, which we receive from a third party to include in our database(s) or append to existing user data to add more detail to the information we have about you.

Cookies. For each visitor to our Site, our web server may automatically attempt to identify the user through a cookie placed within the user’s web browser (a cookie is a message given to a web browser by a web server; the browser stores the message in a text file; the message is then sent back to the server each time the browser requests a page from the server). This is done to provide users with more relevant access to the Site. From time to time we may also track information, in aggregate, on pages and features that users access or view. The activity is collected and stored in our server’s log files. We may log Internet Protocol (IP) addresses, or the location of your computer on the Internet, for systems administration and troubleshooting purposes. We use this information in an aggregate fashion to track access to the Site. Our email alerts utilize tracking technology that allows us to see how many newsletter e-mails are opened and the e-mail address of users who have clicked on a given story, feature or advertisement. We use this information for internal purposes, to measure the aggregate number of people who view a given newsletter item.

We may also place cookies on users’ computers to allow users to store login information, personalize their user experience and navigate easily through the Site. Through the use of additional cookies or technology, we will have the ability to track users by their behavior profile and geographic location for the purpose of pushing advertising that matches their interests and/or specific location. We, or the service provider, will inform you of such collection at the time you use the service. By giving your consent, you agree to our collection, use and disclosure of your location information as described.

Third Party Advertisements. We may use third-party advertising service vendors to serve advertisements on the Sourcing Certification Products. These vendors may use cookies, web beacons or similar technologies to serve you advertisements tailored to interests you have shown by browsing on this and other sites you have visited. In doing so, these vendors may collect non-personal information such as your browser type, your operating system, Web pages visited, time of visits, content viewed, ads viewed, and other clickstream data. The use of cookies, web beacons or similar technologies by these advertising service vendors is subject to their own privacy policies, not ours, and we disclaim all liability in connection therewith. For more information about third-party ad networks that use these technologies, and to opt-out of their collection of information, see and You may have additional rights regarding opt-out of third party advertising services, including those set forth below, if you reside in a jurisdiction such as the European Economic Area or the State of California, which provide for enhanced user rights.


The following sets forth the ways we process your personal information.

(a) We may process information about your use of the Sourcing Certification Products (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of the Sourcing Certification Products. We use this usage data for the purposes of analyzing your use of the Sourcing Certification Products.

(b) We may process your account information (“account data”). The account data may include your name and email address. We use this account data to provide the Sourcing Certification Products to you, maintain back-ups of our databases and communicate with you.

(c) We may process your information, which you have included in your personal profile on our websites (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, date of birth, educational details and employment details. We use this profile data to enable and monitor your use of the Sourcing Certification Products.

(d) We may process information that you post on our Site or through our services (“publication data”). We use this publication data enable the posts and to administer the Sourcing Certification Products.

(e) We may process information contained in any enquiry you submit to us regarding the Sourcing Certification Products (“enquiry data”). We use this enquiry date for the purposes of offering, marketing and selling relevant goods and/or services to you.

(f) We may process information relating to transactions, including purchases of goods and services, which you enter into with us and/or through Sourcing Certification (“transaction data”). The transaction data may include your contact details, your payment card details and the transaction details. We use this transaction data for the purpose of supplying the purchased goods and services to you and keeping proper records of those transactions.

(g) We may process information that you provide to us for the purpose of subscribing to our email notifications (“notification data”). We use this notification data for the purposes of sending you relevant notifications.

(h) We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our Site will generate the metadata associated with communications made using the website contact forms. We use this correspondence data for the purposes of communicating with you and record-keeping.

(i) We may process any of your personal information where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, and where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice.

(j) In addition to the specific purposes for which we may process your personal information set forth in this Privacy Policy, we may also process any of your personal information where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.


The following sets forth the ways we may disclose your personal information to others.

(a) We may disclose personal information to our suppliers or subcontractors insofar as reasonably necessary to maintain the Sourcing Certification Products.

(b) Financial transactions relating to Sourcing Certification Products may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. At your request we will inform you of the identity of our payment service providers and provide links to their privacy policies and practices.

(c) We may disclose your personal information to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

(d) We may transfer part or all of your information in the case of a merger, acquisition, bankruptcy, or other sale of all or a portion of Sourcing Certification’s assets or stock.

(e) In addition to the specific disclosures of personal information set out in this Section, we may disclose your personal information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal information where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.


We may store personal information in locations outside the direct control of Sourcing Certification (for instance, on servers or databases co-located with hosting providers).

As we develop our business, we may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution. In such cases we cannot control acquiring parties’ use of your information.

We may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Sourcing Certification’s rights or property.

Additional use of your personal information that is not described in this Privacy Policy will only take place as required by statute or when we have obtained your consent.


The Sourcing Certification Products may contain links to other websites or services that may be subject to less stringent privacy standards. Sourcing Certification cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites or services. We are not responsible for how such third parties collect, use or disclose your personal information. You should review their privacy policies before providing them with personal information.


We are committed to providing users of Sourcing Certification Products with the choice to receive or not receive e-mails, promotional materials and/or other communications from Sourcing Certification. We only send commercial emails to users who have requested or consented to receive emails about our services and products. We do not send unsolicited commercial emails (“spam”), buy or sell email lists, or use purchased or harvested email lists. We offer commercial email recipients the opportunity to opt-out of further communications in every email. If you want to stop receiving commercial emails, promotional or other marketing materials, you can do so at any time by contacting Sourcing Certification at


The Sourcing Certification Products are operated in and provided from the United States of America. If you are located in Canada, the European Union or elsewhere outside of the United States of America, please be aware that any information you provide to us will be transferred to the United States of America. By using the Sourcing Certification Products, participating in any of our services and/or providing us with your information, you consent to this transfer.


Canadian residents have certain rights to know how their information may be shared with third parties for direct marketing purposes. As detailed above, you may contact us for such information at any time by sending an e-mail stating this preference and including your full name and e-mail address to


The General Data Protection Regulation, effective May 25, 2018, gives requires that certain information and certain rights be provided to residents of the European Union, as follows.

Transferring Personal Information From The EU To The US. Sourcing Certification has its headquarters in the United States. Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Sourcing Certification relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Sourcing Certification collects and transfers to the U.S. personal information only (a) with your consent, (b) to perform a contract with you, or (c) to fulfill a compelling legitimate interest of Sourcing Certification in a manner that does not outweigh your rights and freedoms. Sourcing Certification endeavors to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with Sourcing Certification and the practices described in this Privacy Policy.

You May Elect Not To Provide Personal Information. You may choose not to provide Sourcing Certification with your personal information. However, if you choose not to provide your personal information, you may not be able to enjoy the full range of services, which Sourcing Certification offers.

How to Exercise Your Rights. If you reside in the European Economic Area, you have certain rights to the personal information that we have collected about you. To exercise your rights to your personal information, please contact Sourcing Certification at We will respond to reasonable requests as soon as practicable, and in any event, within the time limits prescribed by law. You have the following rights:

(a) Right Of Access To Your Personal Information: You have the right to ask us for confirmation on whether we are processing your personal information, and access to the personal information and related information on that processing (for example, the purposes of the processing, or the categories of personal information involved).

(b) Right to Correction: You have the right to have your personal information corrected.

(c) Right to Erasure: You have the right to ask us to delete your personal information. This right may be exercised, among other times: when your personal information is no longer necessary for the purposes for which it was collected or otherwise processed; when you withdraw consent on which processing is based and where there is no other legal ground for processing; when you object to processing and there are no overriding legitimate grounds for the processing; or when your personal information has been unlawfully processed.

(d) Right To Restriction Of Processing: You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your personal information is contested; when the processing is unlawful and you oppose the erasure of your personal information and request the restriction of the use of your personal information instead; or when you have objected to processing pending the verification whether the legitimate grounds of Sourcing Certification override your grounds.

(e) Right To Data Portability: You have the right to receive the personal information that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.

(f) Right To Object: You have the right to object to our processing of your personal information, as permitted by law. This right is limited to processing based on GDPR Art. 6(1)(e) or (f), and includes profiling based on those provisions, and processing for direct marketing purposes, after which we will no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Right To Lodge A Complaint Before The Data Protection Authority. We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of personal information relating to you infringes applicable data protection laws.


These California Privacy Rights supplement the other information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). This notice is to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. We may update these California Privacy Rights as necessary and in the event of changes in the CCPA. These terms apply only to California residents.

Categories Of Personal Information Sourcing Confirmation Collects. As described in more detail in other areas of our Privacy Policy, we collect and/or disclose personal information about you when you visit use our Site, including information about you that you provide to us, and information that we automatically collect from you or your computer or device as you use our Site.

Information We Collect About You And How We Collect It. Personal information does not include information that is: (a) publicly available information from government records; or (b) de-identified or aggregated consumer information

Categories Of Sources From Which We Collect Personal Information. We collect personal information directly from you, for example when you provide it to us to when you contact us to our Site or purchase Sourcing Certification Products; and indirectly from you automatically through your computer or device as you use our Site. We may also collect personal information about you from our advertising partners and service providers.

Use Of Personal Information. We do not sell your personal information. We may use or disclose the personal information we collect for our business purposes described elsewhere in this Privacy Policy.

Sharing Personal Information. We may disclose your personal information to a third party for one or more business purposes. When we disclose personal information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for Business Purposes. We may disclose your personal information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising.

Access Request Rights. California residents have the right to request that Sourcing Confirmation disclose certain information to you about our collection and use of your personal information over the past 12 months for the above business and commercial purposes. To submit an access request, please see below. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  1. sales, identifying the personal information categories that each category of recipient purchased; and
  2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights.
California residents have the right to request that Sourcing Confirmation delete your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless certain exceptions apply.

Exercising Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by emailing us at

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. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Site that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g. requests made in 2023 will receive information regarding such activities in 2022). You may request this information once per calendar year. To make such a request, please contact us by email at


The security of the Sourcing Certification Products and your information is of great importance to Sourcing Certification. Sourcing Certification has reasonable security measures in place to protect the loss, misuse and alteration of your information under Sourcing Certification’s control, but we make no assurances about our ability to prevent any such loss, misuse or alteration, and we shall have no liability to you or any third party from any loss, misuse or alteration. We do not warrant that your access to the Sourcing Certification Products is completely secure. You should promptly notify Sourcing Certification if your account, username or password have been lost or stolen. Sourcing Certification will never ask you for your password. If you need a new user name and/or password, Sourcing Certification will generate a new username and password automatically through its computers and send it to your e-mail.

Sourcing Certification shall notify any user whose information is suspected of being accessed, disclosed, altered or deleted by an unauthorized person, so that the user can take appropriate measures to minimize the adverse effect of such a data security breach (a “Breach Notification”). Sourcing Certification will make such Breach Notification soon after it learns of a breach, unless it deems, at its sole discretion, that such Notification might hinder and prevent ongoing efforts to detect the source of the breach. For the avoidance of doubt, a Breach Notification does NOT constitute an admission by Sourcing Certification that the breach occurred as a result of malpractice, failure, bad faith or negligence on behalf of Sourcing Certification or that the breach even occurred in Sourcing Certification’s systems.


Protecting the privacy of children is especially important. Sourcing Certification does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use the Sourcing Certification Products. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we take steps to remove that information.


This Privacy Policy shall be governed by the laws of the State of California, without regard to its conflict of laws provisions. Any dispute arising under or in relation to this Policy shall be resolved in accordance with the terms and procedures set forth in our Terms of Use, located here:


If we change our privacy policies and procedures, we will post those changes on this page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. Please check this page on a consistent basis.


Please contact Sourcing Certification if you have any questions about this Privacy Policy, the practices of Sourcing Certification or your dealings with the Site. You can contact us by email to or by postal mail to Brain Gain Recruiting, LLC d/b/a Sourcing Certification, 201 Vista Heights Road, El Cerrito, CA 94530.