Effective date: 25 May 2018
1. Scope and Consent
2. Information that we collect
a) Registration, product and account information: You can browse the Site without telling us who you are or revealing any Personal Information (e.g. name, email address, phone number, mobile telephone number, credit card information or physical contact information) about yourself. If you register for an account with us, post a CV, create an email account using our platform or use some of our products and services (e.g. Site email account(s), CV Builder, CV-Check, CV Guide, Covering Letter Builder, Covering Letter Tips, My Perfect CV, CV Review, CV Writing, CV Services, Search Jobs), you choose to give us your Personal Information and are not anonymous to us. When you register an account or use certain products and services, create a profile, create a CV, search for or purchase products, create an email account on our Site or otherwise engage with our Site, you can provide certain Personal Information (e.g. username and email address). You can also provide payment information (e.g. credit or debit card information, name and billing address) to purchase products and services. Personal Information is only associated with your account/profile when you sign in as a registered user.
b) Information to respond to your requests: You can give us your Personal Information so that we can respond to your questions and requests, as well as send you newsletters and other communications that you request. Details of how you can opt out of receiving any communications from us are provided in the section headed Accessing, reviewing and changing your Personal Information
c) Social media information: We can offer sign-on services that allow you to use third-party login credentials to access the Site. We also can offer services that allow you to share information with third-party social media websites such as Facebook, Google Plus, Twitter and others.
When you link your account or engage with our Site through third-party social media sites, you understand that you are allowing us to have ongoing access to certain information stored on these social media sites (e.g. your social networking credentials, your public profile, friends list, people you follow or who follow you, pictures, your email address, date of birth, work history, education history, interests, current city, religious and political views, website, personal description and likes, and your friends' dates of birth, education histories, personal descriptions and likes).
We can also receive other information (e.g. content viewed and information about the advertisements within the content that you have been shown or have clicked, etc.) from your interaction with our Site. You agree that we can share your video viewing with, or obtain information about your video viewing from, analytics providers and advertising partners, and third-party partners and social media sites, for two years or until you withdraw your consent.
d) Information from other sources: The information that we collect can be combined with information from outside public records (e.g. demographic information, navigation information and additional contact information) that we have acquired in accordance with the law.
e) Mobile information: With your consent, we can collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, device's operating system, mobile operator, location or GPS/geo-location, mobile number, your text messages, emails or email address, username, contacts/address book, financial or payment information, web browsing history, photos, your phone's name, passwords, political interests, sexual orientation, racial or ethnic origin, religious and philosophical beliefs, and trade union membership.
f) Technical usage information: When you visit our Site, we collect usage information sent to us by your computer, mobile or other access device that tells us how you are using the Site, including video viewing, site views, key-stroke data, mouse movement, scrolling, clicks and typing ('usage information'). We use tracking technology (including cookies, flash cookies, unique device identifiers, web beacons/GIFs, embedded scripts, e-tags/cache browsers and cross-device tracking) to collect usage information. We can use tracking technology for a variety of purposes, including:
Operationally necessary We can use tracking technology required for systems administration, to prevent fraudulent activity, improve security or allow you to make use of shopping-basket functionality. We are not required to obtain your consent to tracking technology that is operationally necessary.
Functionality related We can use tracking technology to tell us, for example, whether you have visited the Site before or if you are a new visitor, and to help us identify the features in which you have the greatest interest.
Targeting related We can use tracking technology to deliver content, including ads, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content, as well as track the content that you access (including video viewing). Further information on this and your opting-out choices are shown below.
We can also collect password information from you when you log in, as well as computer and/or connection information. During some visits, we can use software tools to measure and collect session information, including page-response times, download errors, time spent on certain pages and page-interaction information.
g) Apply Tool Privacy Notice and information that we collect: We can automatically collect certain information (including Personal Information) from your device or web browser. We can automatically collect information from location storage associated with your web browser, including your browsing behaviour, for career searching activity. We can also automatically record your interaction with certain web pages by accessing local storage associated with your web browser. The Apply Tool was created to automatically interact with third-party websites, so we can also collect some non-personal data about you when you visit those websites, including, clickstream data, operating system being used, the URL of the site that you have come from and move to after your visit, data relating to your activities on third-party websites (including IP addresses and URLs) via tracking technology (such as cookies and measurement software), the date and time of your visit and your server's IP address, the geo-location of your device and the type of payment you use. We collect this information for statistical purposes to find out how our website and the Apply Tool are being used. We can use this information to evaluate and, hopefully, improve your experience. As an example, when you visit a web page that supports the auto-fill function, we can record metadata generated by your web browser that identifies one or more auto-fill fields that you interact with. In this example, we can also access local storage associated with your web browser to determine information (including Personal Information) which can be, or has been, entered into an auto-fill field. We use your information to facilitate your completion of job applications across the Internet, on our websites and third-party websites, and to provide advertising and/or other content that we believe may be of interest to you based upon your browsing behaviour on the Internet.
3. Uses, retention and storage
We process your Personal Information for the following purposes and legal bases:
a) Operate our site and provide you with our services: We use the Personal Information that we collect, including the email account that you can create on our platform using the Provider's email, to (i) respond to your questions and requests; (ii) provide customer service (e.g. to fulfil product and service orders made by you, give you information about your account to resolve disputes, problems with your account/profile or the Site, administer a competition, sweepstake or promotion, or to provide information to third parties at your request, such as potential employers, job-matching services or third-party websites, or other career-related services); (iii) personalise your experience by providing content on the Site, including targeted advertising or job-related advertising, that we believe can be of most interest to you; (iv) improve the Site; (and (v) provide you with a safe, efficient and customised experience.
b) Analyse and aggregate non-personal information: We use aggregate information about our users, as well as non-personal information, to analyse Site and user behaviour and to prepare aggregated reports.
d) Communicate with you and third parties at your request: We use your information to contact you to maintain the Site, your account or to comply with your stated communication preferences, or to provide other products or services requested by you, as described at the time when we collect the information from you, or to contact you for other purposes authorised by law. If you have chosen to participate in some of our career-building Services, the information that you share with us can be provided to third parties such as (i) CV editors, (ii) employers or recruiters, who can contact you about career opportunities, (iii) employers seeking candidates and/or (iii) other career service providers.
We retain Personal Information for as long as it is necessary to fulfil the purpose(s) for which it was collected, our business purposes and/or to comply with the applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you. You consent to our retention of your video-viewing tracking data for as long as permissible under applicable law – up to 12 months after you have closed your account or otherwise withdraw consent for video tracking.
Information that we collect can be shared with:
a) The Provider's corporate family and other third parties: We can share the information that we collect about you with the Provider's corporate family (our affiliates), as well as with third-party suppliers. The information can be disclosed (i) to provide joint content and our products and services (e.g. registration, transactions, employment or education opportunities, analytics and customer support); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our Provider or third party's products, sites, applications, services, tools and communications. Members of our corporate family will use this information to send you marketing communications, and you will have the opportunity to opt out of email communications.
b) Service providers and other third parties: We can disclose your information to service providers under contract, which help with our business operations (such as, but not limited to, fraud investigations, bill collection and payment processing, and site analytics and operations). Also, we share information with our third-party payment processors. With your authorisation, we can also share your information with potential employers and career/job-posting websites.
c) Other entities, with your consent: We can share your Personal Information with third parties to whom you explicitly ask us to send your information (such as CV editors, employers, recruiters or job-posting third-party websites, or others about whom you are otherwise explicitly notified and consent to when using a specific service). These third party services are governed by their own terms of service and privacy policies, as set forth by the third parties that provide them. We do not necessarily endorse, nor are we responsible or liable, directly or indirectly, for those services. On the Site, you have opportunities to express an interest in, or register for, other products and services. If you do, we will provide information about you to these third parties, or parties working on their behalf, to implement your request.
d) Legal and law enforcement: Law enforcement, governmental agencies or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity, or any other activity that can expose us, you or any other Provider user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, county, postcode, telephone number, email address, user ID history, IP address, fraud complaints and anything else that we deem relevant to the investigation.
g) Companies in the mobile app industry: If you access the Site through a mobile device or app, we can also share your information with operators, operating systems and platforms.
5. Your choices
a) Opting out of promotional messages: You can choose not to receive our promotional communications by clicking the 'My account' tab and clicking the 'My settings' and 'Preferences' tabs. You can also click the Unsubscribe link in the footer of any email or newsletter that you receive. You can also email us at email@example.com.
b) Update/delete or change your CV or covering letter: To change or delete your CVs or covering letters, log in to your Provider account, click the 'CV' and 'Covering letter' tabs and select Edit or Delete.
c) Site privacy settings: Information that you disclose while participating on the Site can be public and subject to redistribution by us and any third party that reviews your profile or the information that you post. You can change preferences for other Provider services as set forth in section 8 or by contacting us as set forth in Section 16. Please be aware that the Provider is not responsible for the use, disclosure or copies of your public postings on or through the Site that you make public and that are downloaded by third parties.
d) Administrative messages cannot be turned off: As the Provider provides an online service, you cannot opt out of administrative emails (for example, emails about your transactions or policy changes) for your registered account.
e) Deletion of your user content/account: You can request that we delete your account by logging in to your account and clicking the 'My settings' and 'Overview' tabs. You can also email us at firstname.lastname@example.org. When you request that your account be deleted, your Personal Information, including your CV and profiles, will be deleted and no longer available to you or visible to users from Provider applications. However, if any of your information, including your Personal Information, was previously accessed by others using Provider applications, we are unable to delete the information from their systems. When you delete your information on Provider applications, we will retain logs and non-personally identifiable information about you, along with an archival copy of your information, which is not accessible by you or third parties on Provider applications, but which might be used by us for record keeping and internal purposes, including enforcing this Policy and demographic, reporting and research purposes.
f) Timing and third parties: We will endeavour to comply with your requests as soon as reasonably possible, but please note that changes requested of us are not always effective immediately. Unless required by law, we are not responsible for informing third parties (including, without limitation, our third-party service providers, potential employers, job-posting sites that you authorise us to contact on your behalf, or strategic or marketing partners) with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from, or causing information to be removed from, the databases or records of such entities.
6. Information that you share on the site.
a) Other services: If you use the Site, the Provider can create a universal application derived from the information you provide on the Site that will be visible to potential employers who have immediate needs for prospects, as well as visitors to the Site. Therefore, your Site Profile can be publicly viewable. You can elect to have your Profile restricted to registered users only by following the instructions on the Site for that particular setting. You agree that employers and the Provider will use the contact information you have provided to contact you by email and/or SMS text, and you understand that this consent is not a condition to having access to the Site or the Provider's services. Messaging and data rates can apply. If you opt in to our SMS alert service, you acknowledge that message or data charges may apply. If you do not wish to continue with the SMS alert service, you may opt out by replying 'STOP' to the SMS text that you have received, or you may contact our customer service. Please allow three to five working days for us to process your request. The Provider reserves the right to terminate the SMS alert service, at its sole discretion, for any reason and at any time.
7. Tracking technology (cookies)
When you visit the Site, we and our business partners can use tracking technology to enhance your online experience or customise our offerings. Here are a few additional important things that you should know about our use of tracking technology (cookies):
- We can offer certain features that are available only through the use of tracking technology.
- We use both session and persistent tracking technology. Tracking technology (e.g. cookies) can either be persistent (i.e. they remain on your computer until you delete them) or temporary (i.e. they last only until you close your browser). You are always free to decline tracking technology if your browser permits this, although doing so can interfere with your use of the Site. Refer to the Help section of your browser, browser extensions or installed applications for instructions on blocking, deleting or disabling tracking technology such as cookies.
- We encode and protect the types of tracking technology that the Provider sets so that only we can interpret the information stored in them. You can encounter tracking technology/cookies from the third-party service providers allowed on our Site, such as Google Analytics, which assist us with various aspects of our Site operations and services.
- You can also encounter tracking technology from third parties on certain pages of the websites that we do not control and have not authorised. (For example, if you view a web page created by another user, there can be a cookie placed by that web page).
- We can target and track the videos that you view on the Site. You consent to our tracking of your video viewing through the Site, or on third-party social media, for up to two years or as permitted by applicable law.
8. Accessing, reviewing and changing your Personal Information
We will endeavour to comply with your requests as soon as reasonably possible, but please note that changes requested of us are not always effective immediately. Unless required by law, we are not responsible for informing third parties (including, without limitation, our third-party service providers, potential employers, job-posting sites that you authorise us to contact on your behalf, or strategic or marketing partners) with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from, or causing information to be removed from, the databases or records of such entities.
9. Notice to residents of California
a) California Civil Code Section 1798.83, known as the 'Shine the light' law, permits those of our customers who are residents of California to request and obtain from us a list of what Personal Information (if any) we have disclosed to third parties for direct-marketing purposes in the preceding calendar year, and the names and addresses of these third parties. Requests can be made only once a year and are free of charge. To make such a request, please contact us at email@example.com. For all requests, you must put the statement 'Your California privacy rights' in the body of your request, as well as your name, street address, city, state and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a resident of California and provide a current address in California for our response. Please note that we will not accept requests via the telephone, by post or via facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not contain complete information.
b) California Business & Professions Code Section 22575 (b) provides that California residents are entitled to know how the Provider responds to 'Do not track' browser settings. The Provider does not currently take action to respond to Do not track signals because a uniform technological standard has not yet been adopted. We continue to review new technology and may adopt a standard once one is universally accepted.
10. Notice to residents of the European Union
a) The Provider complies with the General Data Protection Regulation ('GDPR'). As such, the Provider affords to all European data subjects their respective data privacy rights to the extent that they are applicable, including: (i) the right to rectify inaccurate data; (ii) the right to erasure (deletion of your Personal Information); (iii) the right to restrict processing of your Personal Information; (iv) the right of data portability; and (v) the right to object. You can exercise any of these rights by contacting us at firstname.lastname@example.org or Contact us. In order to safeguard your Personal Information from unauthorised access, we can ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.
b) In certain situations, and subject to applicable law, the Provider will not be able or obliged to comply with part or all of your individual requests. Please note that we have the right to refuse and/or charge a monetary fee for requests that are manifestly unfounded or excessive, for example due to their repetitive character. If you have unresolved concerns, you have the right to complain to an EU supervisory authority.
c) Providing your information to us is optional, but it can affect our ability to offer you the Service. For example, if you do not provide your complete Personal Information, we will not always be able to respond to your request in a timely manner.
11. Third parties
Our Site can contain links to other third-party websites, and the Provider can provide products and services that share information with third-party sites for your job search. We are not responsible for the privacy practices or the content of these third-party sites, so it is important to familiarise yourself with their privacy policies before providing your Personal Information.
12. Information security
We maintain technical, physical and administrative security measures designed to protect the security of your Personal Information against loss, misuse, unauthorised or accidental access, disclosure, copying, use or alteration. Some of the safeguards that we use are firewalls, data encryption, physical access controls to our data centres, information access authorisation controls and other measures in accordance with industry standards. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, we cannot guarantee its absolute security.
13. Children's privacy
The Site is a general-audience site and it is not intended for children under the age of 16. We do not knowingly collect Personal Information via our websites, applications, services or tools from users in this age group.
If you are a minor and want to remove the information that you have posted to the Site, please contact us via the email or postal address listed in Section 16 below. Removal of the information that you have posted does not ensure its complete or comprehensive removal.
14. Storage and international transfer
15. Notification regarding updates
16. Contact us
If your questions are not answered online, you can email us at email@example.com, write to us at Auxiliant sarl, 1A, rue Thomas Edison, L-445 Strassen, Luxembourg, or BOLD LLC, City View Plaza II, 48 Road 165, Suite 6000, Guaynabo, PR 00968, or use the contact us form on the Site.