Article 1. Introduction
Last updated: September 26, 2022
Article 2. Informed consent
- Information gathered through the Services may be transferred, used, and stored in Europe, the United States, and other foreign jurisdictions in which CoRecruit, our partners, customers, and other users of the Services are located. If you access the Services, you consent to transferring, using, and storing your information in those jurisdictions.
Article 3. Personal information
- Depending on where you are residing, you may have certain legal rights over the personal data we hold about you, subject to local privacy laws. These may include the right to:
- Access the personal data we hold about you
- Have incorrect personal data updated or deleted
- Have your personal data deleted
- Restrict the processing of your personal data
- Object to the processing of your personal data carried out based on our legitimate interests or for direct marketing purposes
- Receive a copy of your personal data in an electronic and machine-readable format
- Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects or otherwise significantly affects you (“Automated Decision-Making”). CoRecruit does not perform Automated Decision-Making as part of the processing activities covered by this Privacy Statement.
- Receive the categories of sources from whom we collected your personal data
- Opt out of marketing communications at any time by clicking on the “Unsubscribe” or “Opt out” link in marketing emails we send you or by contacting us
- Complain to a regulator or data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
- CoRecruit will not discriminate against you for exercising your rights.
- You, or an authorized individual that we can verify is acting on your behalf, can exercise the applicable rights by emailing email@example.com.
- If your personal data has been submitted to CoRecruit by or on behalf of a CoRecruit Client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly.
- The personal information that we may collect about you through the Services broadly falls into the following categories:
- Information you provide voluntarily
To access certain parts of our platform, our services, information, and websites, we may ask you to provide personal and business contact information voluntarily:
- We may ask you to provide your contact details to request a demo, register an account with us, subscribe to marketing communications from us, and/or submit inquiries to us. Typically, we will ask for your name and contact details and some basic information about the company you work for, the products you are interested in, and your role in the company. The Personal Data collected may include, but is not necessarily limited to name, username, company address, email address, phone number, IP address, use and browser information, knowledge, skills, abilities, resume data, and answers to employment, assessment-related questions (which may be captured via audio, video, and text).
- We may ask you to provide contact details and business contact information for account management purposes and to register an account with us to get access to the use of CoRecruit software-as-a-service applications or professional services. If you are a user of the CoRecruit platform, this includes your account registration information (for example, your name and email) and your profile information (for example, your company name, and billing information).
- If you invite a user to use our Services, their contact details will be automatically open to access our Service. We store this information to send this one-time invite to enable access to our Services and Platform. Your invitee may contact us at firstname.lastname@example.org to request that we remove this information from our database.
- If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, or you can contact us at email@example.com.
- You may post comments or questions on the CoRecruit support website, which allows you to provide your personal data. Personal data you submit in these public areas can be read and collected by others who access them. You should only post personal information with the awareness that the information will be available to others. Comments posted by individuals in an online forum reflect their own views and should not be considered to reflect the opinion of CoRecruit.
- CoRecruit collects names, company details, and email addresses to manage CoRecruit registrations for support and partners.
- Information CoRecruit collects automatically
When you visit our website or use our platform, we may collect certain information automatically from your device using cookies and similar tracking technology. This information may be considered personal under applicable data protection laws in some countries:
- The information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g., country or city-level location), and other technical information.
- We may also collect information about how your device has interacted with our website or Platform, including the pages accessed and links clicked. Collecting this information enables us to understand better the visitors who come to our website or Platform, where they come from, and what content on our website or Platform is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website or platform to our visitors.
- CoRecruit may use log files, cookies, and similar technologies, such as web beacons, HTML5 Local Storage, local shared objects, tags, and scripts on our websites, platform, and email communications. We use these technologies to augment convenience for our Users and to enhance Users’ experience using the CoRecruit Services. We may use these technologies in emails we send to track their effectiveness. CoRecruit can deliver a more efficient and personalized service for each user by relying on cookies, web beacons, and similar technology. Additionally, these technologies may allow CoRecruit to monitor traffic patterns, Services usage, and session information to make the Services more useful and effective.
- We may collect and store this data and combine this data with other personal data provided to CoRecruit.
- Information CoRecruit obtains from Third-Party Sources
- CoRecruit Services may contain links to third-party sites. CoRecruit is not responsible for the privacy policies, practices, or content of sites owned by others that you may link to or that may be linked from the Services. Any Personal Information you provide directly on third-party sites or services (including communications between Candidates or Employees, Employers through the Service, Proctor) is provided directly to that third party and is subject to that third party’s policies governing privacy and security.
- We are not responsible for the content, privacy, security practices, or policies of third-party sites or services to which links are displayed on the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with your personal information.
- We may receive personal information about you from third-party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
- The information we collect from third parties includes general geo-location information to identify the state and country you reside in or contacted the third-party source. We use the information we receive from these third parties to ensure inquiries and other requests are routed to the appropriate team for processing as promptly as possible.
- CoRecruit may also collect business contact information about you from third parties from whom we have purchased business contact information and from publicly accessible websites, such as your company’s website, professional network services, or press releases.
- CoRecruit may combine the personal data you provided to us with data collected from other sources as described above. We process this data to update, expand, and analyze our existing marketing records, identify new customers, create more tailored advertising or website experiences and send marketing emails.
- If CoRecruit collects any other personal data from you, we will explain the purposes at the time we collect it.
- Information you provide voluntarily
Article 4. Non-personal information
- Non-Personal Information (“NPI”) is the information CoRecruit collects through our website or platform that does not identify you by name or as an individual person. It may include information like the type of web browser software your computer uses, pages your computer visited, date and time your computer accessed our pages, and personal information that has been de-identified.
Article 5. Use of information
- CoRecruit uses the data we collect about you to provide you with CoRecruit websites, services, and support. For example, if you provide data to us in a “Contact Us” form, we will use your data to respond to the request.
- CoRecruit uses your personal data and information about your activity on our websites to contact you for marketing purposes in accordance with your marketing preferences, including telemarketing calls, and to send marketing emails that we believe may be of interest to you, such as product announcements, newsletters, educational materials, and details on upcoming events. We also use it to send administrative information, such as notices related to products, services, or policy changes.
- CoRecruit uses the data we collect to understand how our websites and services are being used and to make improvements. For example, we may solicit your feedback about your experience using our services, and ways that we can improve those services. Additionally, we use questions or comments posted on CoRecruit Support to enrich the content or help guide future enhancements to our products and services.
- Similarly, the CoRecruit Platform gathers information for troubleshooting and improvement. We use third-party services to view aggregated information about end-user usage and interactions. CoRecruit minimizes or masks the information sent to third parties (such as encoding the data).
- CoRecruit may use your information to diagnose website technical problems, as well as to prevent, detect, mitigate, and investigate potential security issues, as well as a fraudulent or illegal activity.
- CoRecruit also may use your data to personalize your experience on our websites and platform. CoRecruit or our service providers use website tracking technologies to display products, features, or content that are tailored to your interests and to present advertising on other sites.
- We use your information to provide the services you have requested to create and maintain your accounts and keep a check for unauthorized activity on your accounts. We also use it to communicate with you about the products you are currently using, your customer support requests, updates and new products you may like, chances for you to give us feedback, and policy updates. We analyze the information we collect to understand user needs and to improve our websites and services. We limit access to your personal information to our employees and contractors who have a legitimate need to use it.
- We collect Candidate’s Personal Information to provide Services to Employers to assist them in evaluating such Candidates for employment.
- CoRecruit collects the Personal Information of the person authorized by the Enterprises. This information is collected to facilitate CoRecruit’s platform or services to such persons. In general, CoRecruit collects such User information to provide the following services:
- Create and administer accounts
- Provide access to the Users
- Record keeping
- Improving products and services
- Meeting legal and regulatory requirements
- Understanding and analyzing our users’ needs and preferences
- Sending information that CoRecruit believes a User may find helpful
- Develop new products, services, features, and functionality
- Preventing any kind of cyber-crimes or fraudulent activities
- Provide, operate and maintain Our Website, Platform, and Services.
- You can decline certain kinds of information usage by not providing the information in the first place or opting out later. You can also disable cookies to prevent your browser from giving us information, but certain website features may not work properly if you do so.
- CoRecruit keeps your Personal Information for as long as it is required and permitted for the purposes according to applicable Privacy Regulations. When we no longer have a legitimate need to process your information, we will delete, anonymize, or isolate your information, whichever is appropriate.
Article 6. Disclosure of data
- CoRecruit may disclose data and aggregate anonymous information to other users of the Services (e.g., information of Candidates to Employers) and with CoRecruit affiliates, third-party service providers, or vendors contracted to provide services on our behalf. These third-party service providers or vendors may use data we provide to them only as instructed by CoRecruit. In such cases, those third parties may have access to your Personal Information and will not use it for any other purposes.
- CoRecruit may offer the following solely or jointly with third parties or partners: job postings, webinars, events, whitepaper downloads, or other services related to CoRecruit offerings or services. We may share your contact information and interests in these offerings or services with these approved third parties to communicate with you about CoRecruit.
- CoRecruit may disclose aggregate anonymous information to business partners, merchants, advertisers, investors, potential buyers, and other third parties if we deem such disclosure, in our discretion, to have sound business reasons or justification, like (a) conform to legal requirements or comply with legal processes; (b) protect and defend our rights or property; (c) enforce the website Terms and Conditions; and/or (d) act to protect the interests of our users or others.
- If CoRecruit goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal data may be among the assets transferred. CoRecruit reserves the right to disclose and transfer user information, including Personal Information, in connection with a corporate sale, merger, dissolution, acquisition, or similar transaction. In such cases, you will be notified via email or a prominent notice on our website or Platform of any change in ownership or uses of your Personal Information and any choices you may have regarding your Personal Information.
- CoRecruit may cooperate with law enforcement authorities in investigating and prosecuting website or platform users who violate our rules or engage in harmful (or illegal) behavior toward other users.
- CoRecruit does not sell personal data that we collect or process under this Privacy Statement to third parties.
Article 7. Processing of information
- Informed Consent
In some cases, we ask you for your consent to process your personal data, such as when we need your consent for marketing purposes. You can withdraw your consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. If you would like to withdraw your consent, you can do so by sending an email to firstname.lastname@example.org.
- Legitimate Interest
We process certain data for the legitimate interests of CoRecruit, our Users, our affiliates, or our partners. These legitimate interests include, for example, contacting you to provide support or sending you marketing information (subject to applicable law); detecting, preventing, and investigating illegal activities and potential security issues; and maintaining and improving the Website and mobile applications. We will rely on our legitimate interests for processing personal data only after balancing our interests and rights against the impact of the processing on individuals.
- Performance of a Contract
Sometimes we process personal data to perform our obligations under an agreement with you. For example, we use the payment information you provide when you register for an event to process your payment.
- Other Legal Bases
In some cases, we may have a legal obligation to process your personal data, such as in response to a court or regulator order. We also may need to process your personal data to protect vital interests, or to exercise, establish, or defend legal claims.
We are committed to delivering the best data privacy practices for you by being in compliance with global privacy regulations such as GDPR, LGPD, CCPA, and PDPA for general users. The rights provided hereunder apply to you according to the Data Protection laws of the country in which you are based. We collect information under the direction of our Users and have no direct relationship with the individuals whose personal information it processes. Please contact the Recruiting Organization (CoRecruit Client) you were part of the recruitment if you would like to access, rectify, erase, restrict or object to processing, or exporting your Personal Data. We will extend our support to our Clients in responding to your request within a reasonable timeframe.
We will retain personal information we process on behalf of our Clients for as long as needed to provide Services to our Clients. We will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Article 8. General data protection regulation (GDPR)
- For Clients with accounts located in the European Economic Area, all processing of Personal Data, is performed in accordance with privacy rights and regulations following the regulations set forth in the General Data Protection Regulation (“GDPR”).
- GDPR defines Data Controllers as entities that determine the purposes for personal data processing (“Data Controllers”). Data Controllers decide ‘why’ and ‘how’ the personal data should be processed. The data processor processes personal data only on behalf of the Data Controller.
- CoRecruit is a data processor and processes data for its Client who are Data Controllers. The Data Controllers specify the kind of data required from the data subject. CoRecruit acts as a mediator between the Data Controller and the data subject by collecting the specified data before or during the assessment and then processing it as per Data Controller’s instructions.
- If you are in the European Economic Area (EEA), you have the following rights with respect to information that CoRecruit holds about you. CoRecruit undertakes to provide you the same rights no matter where you choose to live:
- Right to access:
You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose, and period of processing, and the persons to whom the information is shared.
- Right to rectification:
You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you to our database.
- Right to erasure:
You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
- Right to restriction of processing:
You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Right to data portability:
You have the right to transfer your information to a third party in a structured, commonly used, and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
- Right to object:
You have the right to object to using your information in certain circumstances, such as using your personal information for direct marketing.
- Right to complain:
You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use, or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
- If you make a request or would like to exercise any of these rights, please contact us at email@example.com
- Right to access:
Article 9. California Consumer Privacy Act (CCPA)
- Under the California Consumer Privacy Act (“CCPA”), among other rights, California consumers have the right to:
- Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
- Request that a business deletes any personal data about the consumer that a business has collected.
- Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
- If you make a request or would like to exercise any of these rights, please contact us at firstname.lastname@example.org.
Article 10. Lei Geral de Proteção de Dados (LGPD)
- For users from Brazilian territory, we are committed to being in compliance with Lei Geral de Proteção de Dados (“LGPD”) regulations. The processing of personal data of such users will be in accordance with rules and regulations as provided in LGPD. The rights of users under this regulation can be obtained from the Data Controller as follows:
- Request confirmation of the existence of processing.
- Request to access the data provided by the user.
- Request to correct incomplete, inaccurate, or outdated data.
- Request for anonymization, blocking, or eliminating unnecessary or excessive data or data processed without compliance to the regulations of LGPD.
- Request to get information regarding how entities are sharing personal data.
- Request to revoke consent for sharing data.
- Request to get information shared by the controller to any public or private entities.
- Request to get information on the possibility of not providing consent and the consequences of denial.
- Request to delete processed personal data with consent.
- If you make a request or would like to exercise any of these rights, please mail us at email@example.com.
Article 11. Personal data protection act (PDPA)
- We comply with the Personal Data Protection Act (“PDPA”) for Singapore users accessing the platform. As a user from Singapore, you have the following rights:
- Keep your personal data up to date.
- Right to access your personal data.
- Right to withdraw consent on your personal data.
- Right to complain in case of breach of data.
- If you make a request or would exercise any of these rights, please contact us at firstname.lastname@example.org.
Article 12. Data integrity and security
- CoRecruit uses technical and organizational measures that provide a level of security appropriate to the risk of processing your personal data. However, the security of information transmitted through the internet can never be guaranteed. You are responsible for maintaining the security of your password or other forms of authentication involved in accessing password-protected or secured resources.
- CoRecruit maintains reasonable and appropriate security measures to maintain the accuracy and integrity of Personal Information.
- CoRecruit has implemented physical and technical safeguards to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
- CoRecruit restricts access to your Personal Data to those employees of ours, our affiliates, and third-party service providers who reasonably need it to provide products or services. We have implemented commercially reasonable electronic, physical and procedural safeguards designed to help protect against the loss, unauthorized access or disclosure, alteration or destruction of the information under our control. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
- Certain features of our Website or Platform may require you to use an access code, password, or similar unique identifier. You are responsible for protecting the secrecy of your account information. CoRecruit recommends that you use the latest browsers to take advantage of advances in security technology. Although we strive to protect your encrypted information, no data transmission over the Internet is completely secure. There is some risk associated with any data transmission, including the risk that personal information may be intercepted in transit. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at email@example.com.
Article 13. International data transfers
- CoRecruit operates as a global business and your personal information may be transferred to, stored, or processed in countries other than the country in which you reside or outside your jurisdiction. Your personal information may be transferred to and processed in different countries around the world where we, third-party service providers, and partners operate including in the USA, the European Union/European Economic Area, Africa, and Asia. This means that when we collect your personal information, we may process it in any of these locations.
Article 14. Data retention
- CoRecruit may retain your data longer for a legitimate business interest where the business benefit is not outweighed by your personal rights and freedoms, such as maintaining suppression lists, preventing abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. Data entered into a CoRecruit service is retained in accordance with any applicable agreement between CoRecruit and its Client.
- When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.
Article 15. Third-party certifications
- CoRecruit adheres to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, although CoRecruit no longer relies on the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks as a legal basis for transfers of personal data in light of the judgment of the Court of Justice of the European Union in Case C-311/18.
- CoRecruit may modify this Policy to reflect changes in the way we collect, use, or disclose information, or to reflect changes in privacy laws, regulations, and/or industry standards.
- We encourage our Clients to review this Policy when accessing the Services.
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