Last updated October 10, 2017
1. INFORMATION WE COLLECT
We collect information, including personal information, in various ways when you use our Sites, and Services and when Clients leverage the Platform on their respective websites. As used in this Policy, “personal information” means any information which, either alone or in combination with other information, identifies you as an individual, such as your name, mailing address, and email address.
Information Collected via our Sites and from Clients
We do not require personal information in order to visit our Sites. However, you may choose to provide us with personal information. For example, you may send us an email in order to ask a question. We use the information provided to answer your question or address your concern. Similarly, when you register as a Client, and at other times, you may submit basic information such as your company name, email address, phone number and physical address and create a user ID and password. We also collect personal information in connection with surveys we conduct with Clients and prospective Clients. We will use that information to provide the Services, to run the survey, to provide you access to the Platform and to manage and maintain your Client account. In connection with using our Sites, Platform and Services, from time-to-time, you may provide us with job openings, job ads, and/or performance media targets (e.g., cost per click) that you are willing to pay. We use this information in order to manage Client accounts and to better serve our Clients.
We also collect non-personally identifiable Information from visitors to the Sites. Non-personally identifiable Information is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to the Sites, the referring URL and your computer’s operating system.
Information Collected Via our Technology Platform
Clients generally embed our technology Platform into their websites as an analytics plug-in that collects certain data that such Clients use to inform their employee recruitment strategy. Our Clients will have their own privacy policies on such websites, and we do not control their practices or disclosures. We automatically collect certain information via the Platform pursuant to providing the Services:
- When you visit our Sites or the website of one of our Clients who have enabled the Platform, some information is automatically collected during your visit. This may include information such as the Operating System (O/S) running on your device, Internet Protocol (IP) address (which may be used to obtain your geolocation such as your zip code or city), access times, browser type, language, and the website you visited prior to your visit to our Sites and/or Client websites. We also collect information about how you use our Sites and our Clients’ sites pursuant to providing the Services, including the site elements you have interacted with, metadata, and other details about these elements, clicks, change states, and other user actions. The type of information collected by our platform is not considered personal information in most jurisdictions.
The Platform is not intended to collect personal information such as name, postal address, or telephone number. Similarly, the Platform is not intended to collect sensitive personal information such as payment card information, social security numbers or personal information contained on a job application. If this type of information were discovered on the Platform, we would take reasonable steps to remove it from the Platform.
2. HOW WE USE INFORMATION WE COLLECT
In general, we use the information we collect via the Platform primarily to help our Clients to understand and optimize their recruitment marketing strategy. We use information collected through our Sites and Platform as described below and described elsewhere in this Policy to:
- Facilitate the creation of and securing of your Account on our network;
- Identify you as a Client and/or user of our system;
- Provide or improve our Services, Platform, Sites, and operation of our business;
- Understand and enhance your experience using our Sites, Platform and Services;
- Provide and deliver products and services you request;
- Respond to your comments or questions and for our support team;
- Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- Communicate with you about upcoming events and news about products and services offered by Recruitics.
Creation of anonymous data. We may create anonymous, non-identifiable, sanitized, and/or aggregated data records from personal information by excluding information (such as applicant name) that makes it commercially impractical to use the data to identify said applicant. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve the Platform and Sites. We reserve the right to use anonymous data for any purpose and disclose or sell anonymous data to third parties in our sole discretion.
3. HOW WE SHARE INFORMATION WE COLLECT
We do not share your personal information with third parties without your consent other than:
- Third Party Service Providers. With third party agents and service providers (e.g., email marketing providers, database vendors and survey vendors) who work on our behalf and use data only as directed by us, provided that such third parties subscribe to the Privacy Shield Principles (described below) or provide at least the same level of privacy protection as required by the Principles;
- Lawful Requests. To comply with laws or to respond to lawful requests and legal process. Note that we may be required to provide personal information in response to lawful requests from public authorities including to meet national security or law enforcement requirements.;
- Protection of Rights and Property. To protect the rights and property of Recruitics, our agents, customers and others including to enforce our agreements, policies and our terms of service.
- Emergency. In an emergency, including to protect the personal safety of any person; and
- Corporate Restructuring. For the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture or dissolution transaction or proceeding). In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.
We may transfer personal information to companies that help us provide our Services. Recruitics shall comply with the onward transfer to third parties of personal information of EU and Swiss individuals' obligations pursuant to the EU-US and Swiss-US Privacy Shield programs, respectively.
4. HOW WE PROTECT INFORMATION THAT WE COLLECT
Recruitics maintains commercially reasonable administrative, technical, and physical safeguards to help protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet is 100% secure. It is your responsibility to protect your usernames and passwords to help prevent anyone from accessing or abusing your accounts and services. You should not use or reuse the same passwords you use with other accounts as your password for our Services.
We do not intentionally gather personal information from visitors who are under the age of 13. If you are under the age of 13, you are not permitted to submit any personal information to us. If we learn that a child under 13 submits personal information to Recruitics we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at email@example.com.
6. THIRD PARTY WEBSITES, AD CHOICES
7. DATA ACCESS RIGHTS, OPT-OUT RIGHTS, DATA RETENTION
If you would like to access, change, suppress, delete or otherwise limit our use and disclosure of your personal information that has been previously provided to us, you may contact us by sending an email containing your request to firstname.lastname@example.org.
Recruitics acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, or who wishes to limit the use and disclosure of their personal information, should direct their request to email@example.com. For your protection, we will only implement such requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will also provide an individual located within the EU or Switzerland with choice before we share their personal information with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. In each event, you must clearly indicate the information that you wish to have changed or suppressed or clearly indicate the limitations you wish to put on our use of your personal information. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom.
Retention Period. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. You may request that we change or delete your Personal Information by following the instructions above.
8. PRIVACY SHIELD
Recruitics complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Recruitics has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page once it is available, please visit https://www.privacyshield.gov. Recruitics is subject to the investigatory and enforcement powers of the FTC.
9. CHANGES TO THIS POLICY
Recruitics may change this Policy from time to time. If we make any changes to this Policy, we will change the "Last Updated" date above. You agree that your continued use of our Sites, Platform or Services after such changes have been published to our Policy will constitute your acceptance of such revised Policy.
10. HOW TO CONTACT US WITH QUESTIONS OR COMPLAINTS
If you have any questions about this Policy, the practices of our Sites, Platform, or Services, or your dealings with our Sites, Platform or Services, please contact us at firstname.lastname@example.org, or send mail to:
ATTN: Business Affairs
187 Danbury Road, Floor 2
Wilton, CT 06897
Privacy Complaints by persons located in the European Union and Switzerland. In compliance with EU-US and Swiss-US Privacy Shield, Recruitics commits to resolve complaints about your privacy and our collection or use of your Personal Information. Persons located in the European Union and Switzerland who have inquiries or complaints regarding this Policy should first contact Recruitics at email@example.com or via the address provided above.
Recruitics has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.