Last updated January 8, 2020
Thank you for choosing to be part of our community at RecruitBot Inc. (“RecruitBot”, Company”, “we”, “us”, or “our”). If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com.
TABLE OF CONTENTS
- WHAT PERSONAL INFORMATION DO WE COLLECT?
- HOW DO WE USE PERSONAL INFORMATION?
- WILL PERSONAL INFORMATION BE SHARED WITH ANYONE?
- WHO WILL PERSONAL INFORMATION BE SHARED WITH?
- HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS?
- IS PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP PERSONAL INFORMATION?
- DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
- HOW DOES THIS POLICY APPLY TO OTHER SITES AND SERVICES?
- DOES THE COMPANY HAVE ANY SECURITY PRACTICES?
1. WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal information disclosed to us
In Short: We collect personal information that you provide to us when registering for the Services, using the Services, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Business and Personal Contact Data. We may collect your first and last name, email address, postal address, phone number, professional title, company name, and other similar contact data.
Content you choose to upload to the Services. We may collect information such as text, images, resumes, candidate profiles and decisions, along with the metadata associated with the files you upload.
Feedback or Correspondence. We may collection information such as when you contact us with questions, feedback, or otherwise correspond with us online.
Financial information. We may collect your payment card information.
Communications on Third-Party Platforms. If you have opted into the Gmail and Microsoft Outlook APIs as part of the Service, through automated means unless permissible in accordance with the third-party platforms’ terms, we may collect sender and recipient information, subject headings and email content.
Profile information and Credentials. We may collect your username, passwords, password hints, and similar security information used for authentication and account access.
Transaction information. We may collect information about payments to and from you, and other details of products or services you have purchased from us.
Usage information. We may collect information about how you use the Services and interact with us, including information you submit to us and information you provide when you use any interactive features of the Services.
Marketing information. We may collection information such as your preferences for receiving communications about our activities, events, publications, and details about how you engage with our communications.
Third-Party Platform Data. We provide you with the option to register using third-party platform account details, like your Google, Microsoft or other social media account. If you choose to register in this way, we will collect the Information described in the section called “HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS” below.
All personal information that you provide to us must be true, complete and accurate, you must have a valid legal basis for providing such information to us (if applicable) and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.
We, our service providers, and our business partners may automatically collect certain information when you visit, use or navigate the Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. Our service providers and business partners may collect this type of information over time and across-third party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons and similar technologies. Our emails may also contain web beacons.
Information collected from others
We may receive personal information from third-party sources. This may include information from publicly available sources (such as other published content), marketing partners and data providers, as well as information from other business partners.
2. HOW DO WE USE PERSONAL INFORMATION?
We may use the information we collect or receive:
- To operate the Services. Specifically,
- To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Microsoft accounts), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of our contract with you. See the section below headed “HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS” for further information.
- To provide our Services to our customers, including using search and machine learning to process decisions you have made about candidates to match other candidates to specific employment positions for prospective employers.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To respond to your requests, questions, and feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To send emails on your behalf and to review and track your emails for the purposes of tracking recruitment processes if you have authorized access to your Gmail or Microsoft Outlook as part of the Services.
- To provide information about our products and services.
- To understand your needs and interests, and personalize your experience with the Services and our communications.
- To provide support and maintenance for the Services.
- For research and development. We analyze use of the Services to improve the Services and to develop new products and services, including by studying user demographics and use of the Services.
- To send you marketing and promotional communications. We and/or our third-party marketing partners may use personal information for our marketing purposes. Our use of your personal information for marketing and promotional communications does not include personal information that we may obtain through any integration that you enable through Gmail or Microsoft Outlook as part of the Service. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
- To display advertisements. We work with advertising partners to display advertisements on the Services or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”
- To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
- For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
- To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
3. WILL PERSONAL INFORMATION BE SHARED WITH ANYONE?
More specifically, we may process data or share personal information in the following situations:
- Third Parties Designated by You. When you use the Services, the personal information we have collected (such as contact details, and employment) will be shared with the third parties that you designate to receive such information.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services on our behalf or help us operate the Services and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.
- Partners. Excluding personal information that we may collect from any integration with Gmail or Microsoft Outlook, we may sometimes share your personal information with partners or enable partners to collect information directly via our Services. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
- Third party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform (such as Gmail and Microsoft Outlook) or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
- Business Transfers. We may sell, share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, reorganization, financing, or acquisition of all or a portion of our business to another company or in the event of a bankruptcy or dissolution.
- Other Users and the Public. When we collect certain personal information from third-party sources or from users of the Service (other than for personal information collected through any third-party platform integration), such personal information may be viewed by all users and may be publicly distributed outside the Services.
- Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
6. HOW DO WE HANDLE YOUR THIRD-PARTY PLATFORM LOGINS?
In Short: If you choose to register or log in to our services using a third-party platform account, we may have access to certain information about you.
Our Services offer you the ability to register and login using your third-party platform account details (like your Google or Microsoft logins). If you choose to login to the Services via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Services, we may collect information from that platform or network. Where you choose to do this, we may collect certain information about you from your third-party platform provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, profile picture as well as other information you choose to make public.
7. IS PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process personal information in countries other than your own.
We are headquartered in the United States. If you are accessing our Services from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in the United States and other countries. Laws in these countries, provinces, or states regarding processing of personal information may be less stringent than the laws in your country, province or state. European Union users should read the information provided below about transfer of personal information outside of the European Union.
8. HOW LONG DO WE KEEP PERSONAL INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we achieve these purposes through other means, and the applicable legal requirements.
When we have no require the personal information we have collected, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. If we learn that personal information from individuals less than 18 years of age has been collected without the consent of the child’s parent or guardian, we will delete it. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
10. WHAT ARE YOUR PRIVACY CHOICES?
In Short: In this section, we describe the rights and choices to all individuals. Individuals who are located within the European Union can find additional information about their rights below.
Opting out of email marketing. You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us. You will then be removed from the marketing email list – however, we may still send you service-related emails for the administration and use of your account.
Access or update your account information. If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our systems to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Service and/or comply with legal requirements.
Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
Third-party platforms. If you choose to connect to the Services via a third-party platform, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Services using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform, that choice will not apply to information that we have already received from that third-party
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
13. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as we determine necessary or appropriate.
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at email@example.com or by post to:
5125 Louise Ave
Encino, CA 91316
15. HOW DOES THIS POLICY APPLY TO OTHER SITES AND SERVICES?
The Services may contain links to other websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
16. DOES THE COMPANY HAVE ANY SECURITY PRACTICES?
In short, yes.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information
In short, the information provided in this section applies only to individuals in Europe.
The contact information for our representative in Europe is:
Jeremy Schiff, firstname.lastname@example.org
We have appointed a Data Protection Officer, whose contact information is:
Jeremy Schiff, email@example.com
|Processing Purpose||Legal Basis|
|To operate the Services||Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.|
For research and development
To send you marketing and promotional communications
To display advertisements
For compliance, fraud prevention and safety
To create anonymous, aggregated or de-identified data
|These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with the law||Processing is necessary to comply with our legal obligations.|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.|
Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
Automated Decision-Making and Profiling. We may use automated decision-making and/or profiling in regard to your personal information for some services and products, for example, we may match certain candidates as eligible for employment or automatically reject candidates based upon our algorithm. Individuals can request a manual review of the accuracy of an automated decision or limit or object to such automated decision-making and/or profiling by contacting us at firstname.lastname@example.org.
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:
- Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules
- Pursuant to the consent of the individual to whom the personal information pertains
- As otherwise permitted by applicable European requirements.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.