Last updated July 28, 2020
- INFORMATION WE COLLECT
- Information that is lawfully made available from federal, state or local government records.
- Deidentified or aggregated information.
- Information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Information about our data collection during the prior 12 months is further described below.
You can access, delete and control certain uses of your information as set form in the “Data Access Rights, Opt-Out Rights, Data Retention” section below.
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 information including:
- Contact information including name, company name, email address, phone number, physical address which we use to provide you with requested services, reply to any correspondence you send us, identify you as a user of our Sites or Platform, and send you information and marketing related to the services we provide you;
- Content of any communications you may send us which we use to answer your questions or address your concerns;
- Registration information including user ID, password and other contact information listed above which we use to create and maintain your account, provide you with requested services and identify you as a user of our Sites or Platform;
- Survey information received from our Clients and prospective Clients which we use to run the survey, provide you with access to the Platform and to manage and maintain your Client account; and
- Job search related information including job openings, job ads and performance media targets (e.g., cost per click) that you are willing to pay, which we use in order to manage Client accounts and to better serve our Clients.
We also automatically collect information from visitors to the Sites including information that cannot by itself directly identify a particular person or entity, such as:
- Online identifiers such as IP hosting address and cookies which we use to improve an enable our services we offer you.
- Browsing history including the pages you 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 which we use to improve and enable our services we offer you.
See “How we use information we collect” below for more detail on how we use the above categories of personal information.
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 are a service provider to our Clients when they use our Platform to collect data on their websites. 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:
- Internet Protocol (IP) address (which may be used to obtain your geolocation such as your zip code or city);
- Operating System (O/S) running on your device, access times, browser type, language, and the website you visited prior to your visit to our Sites and/or Client websites; and
- 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 Platform is not intended to collect information that, by itself, can directly identify you 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.
See “How we use the information we collect” below for more detail on how we use the above categories of personal information.
- 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 de-identified, 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, subject to your opt-out rights as described in “Data Access Rights, Opt-out Rights, Data Retention” below.
- HOW WE SHARE INFORMATION WE COLLECT
We do not share your personal information listed in “Information we collect” above with third parties without your consent other than with the following parties for the following purposes or if it has been de-identified and/or aggregated:
- 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.
- SALES OF INFORMATION
Except for transfers described in this Policy, we do not sell your personal information to third parties.
- 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.
- THIRD PARTY WEBSITES, AD CHOICES
We use non-personally identifying information to facilitate cross device association. We or our third party vendors analyze device activity data using a mathematical tool known as a “probabilistic algorithm” to determine if you have interacted with content across multiple devices and to match such devices. In connection with this analysis, we may rely on non-personally identifiable information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies or we may use the non-personally identifiable information we collect in conjunction with such third party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website or mobile applications are used and to further enable the display of targeted advertisements to you, including across your devices. Our advertisers may also provide us with deterministic data about you that may be used to supplement our probabilistic data. Based on this data, we may then display targeted advertisements across devices that we believe are associated and may provide other services to our advertisers such as tools, analyses, data and insights to see how their website or mobile applications are used and to further enable cross-device targeting and analysis. In order to restrict our use of certain cross-device data, you may opt out in accordance with this section or the “Data Access Rights, Opt-out Rights, Data Retention” section below.
- 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.
Certain jurisdictions provide you with certain rights regarding your personal information, including the following rights to:
- access your personal information that we maintain about you;
- correct or amend inaccurate data;
- erase your personal information;
- limit the use and disclosure of your personal information;
- object to the use of your personal information;
- not be subject to a decision based solely on automated processing, including profiling, which produces legal effects;
- receive your personal information in a usable electronic format and transmit it to a third party (also known as the right to data portability);
- lodge a complaint with your local data protection authority; and
- withdraw any consent you have given to uses of your personal information (such as in relation to cookies or our direct marketing activities).
If you reside in California or in a jurisdiction that provides similar rights, under CCPA or applicable law, you have specific rights regarding your personal information in addition to the erasure and portability rights mentioned above, including:
- Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:
- The categories of personal information we collected about you.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting or selling 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
To exercise the right to know about personal information described above (or the right to erasure or portability under CCPA), please submit a request to us by:
Emailing us at email@example.com.
Only you, a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”) in regards to rights under CCPA, may make the requests set forth above. You may also make a request on behalf of your minor child.
The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information including First Name, Last Name and Email that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative.
We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing.
In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We are not obligated to provide the information set forth above more than twice in a 12-month period.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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.
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.
- 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.
Our servers are maintained in the United States of America. By using our Sites, Platforms, or Services you freely and specifically give us your consent to export your personal information to the USA. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.
- 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.
- 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
40 Danbury Road, Floor 1
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.