Version 1- October, 2020
1 OBJECTIVE, SCOPE AND APPLICABILITY
Any Third Parties working with or for the Company, and who have or may have access to the Personal Data, will be expected to have read, understand and comply with this Policy.
By accessing and / or using our Platform, the Services and providing the information as explained in this Policy, You understand that We will collect and use Your Personal Data as described in this Policy and You expressly consent to the terms of this Policy. We encourage You to read this Policy regarding the collection, use, and disclosure of Your Personal Data. If You are not comfortable with any of the terms or policies described in this Policy, You may choose to discontinue usage of the Platform and the Services.
The Company may act as data processor or as a separate data controller depending on the Service being provided and the amount of control the Company has over the purpose(s) and means of the data processing.
If You are a job applicant for employment with Our clients (“Applicant”) You understand that ANSR provides a suite of talent acquisition products, to:
- Help our clients find their next hires: when You apply, Our client (the recruiter or hiring manager) can consider You for any job opportunities they have and can use any talent acquisition or productivity tools to track, manage and make a decision.
- Help job seekers manage Your job applications: when You sign up, You have access to the Talent500 job search portal, where You can find Your profile information and information on the jobs You have applied to and can receive job suggestions.
You understand that when You apply for a job for recruitment with a client, for the purposes of GDPR, the client is the data controller and is responsible for the processing of Your Personal Data and the Company is the data processor processing the data on behalf of the client and any “Third Party” that may be engaged by Us, is a “sub-processor”. It may also happen that We act as the controllers, when You enrol with our Platform generally to use other features of our Platform other than applying for jobs with the client, or joint controllers with a third party of certain information and decide the purposes and means of the processing of such Personal Data. The use of such information shall be as per the terms of this Policy.
If You or Your organization is Our client and have a separate agreement with Us, that agreement may have privacy terms that also apply to the Personal Data You provide to Us under that agreement. You are requested to review the terms of that agreement as well.
Our clients or any other third party may either collect Your Personal Data and transfer the same to Us or require Us or any third party, to collect such Personal Data on behalf of them. The Personal Data provided to the Company by Our clients is collected by those clients under their own privacy policies. This Policy does not apply to practices that the Company does not own and accordingly, in such case, the Company will only process the Personal Data provided by or collected on behalf of such clients and will only act for and on behalf of such clients. To such an extent, the Company will qualify as a processor.
If You are a current or former employee or applicant for employment with the Company, We will act as a “controller” for the purpose of GDPR and this Policy describes the Personal Data that We may collect from or about You, and how We use and to whom We disclose that Personal Data. We collect the types of Personal Data that We require in order to manage our relationship with You, from the point at which You make an application to work with Us (e.g. in your application) and throughout Your employment with Us (e.g., through on-boarding, using our systems, and signing up for benefits).
Notwithstanding anything contained herein, if You breach the terms of the Policy, the Company reserves the right to take any legal or other action against you, including but not limited to, denying or revoking access to the Platform and the Services and referral to the appropriate authorities.
For the purpose of this Policy, the following terms used herein shall have the meaning ascribed to it below:
- Data Principal: The natural person to whom the Personal Data relates to.
- GDPR: GDPR shall mean the General Data Protection Regulations, applicable as of May 25, 2018 in all member states of European Union (EU) to harmonize data privacy laws across Europe.
- Personal Data: It refers any information about an individual (the Data Principal) which can be used to distinguish or trace an individual’s identity or any other information that is linked or linkable to an individual. Examples included but not limited to name, an identification number, an online identifier, location data, or one or more factors specific to the physical, physiological, mental, genetic, economic, cultural or social identity of that natural person and any other information that is so categorized by applicable laws. Personal Data includes the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- Third Party: All external parties contractors, interns, summer trainees, vendors, etc. who have access to the Company’s information assets or information systems.
2 PURPOSE OF COLLECTING AND KINDS OF PERSONAL DATA COLLECTED
2.1 The use and the collection of the Personal Data by the Company is dependent upon how the User interacts and/or avails the Services of the Company.
We collect certain information pertaining to You and/or Your usage of the Platform or our Services, to provide better services and offerings. We collect the following categories of Personal Data in the following ways:
- name, age, gender, email address, password, country, city, contact number, current status of job search, company/organization that You are associated with, company/organization(s) that You’ve been associated with in the past, Your educational background (degrees, diplomas or certifications) and other information related to Your professional career when You sign up for alerts on the Platform;
- information that one would usually include in a resume, including name, contact details including e-mail address and contact number, work experience, educational qualifications, data relating to Your current and past remuneration or salary, a copy of Your resume, etc. when You register on the Platform;
- information about Your current salary, Your expected salary and Your preferred job location(s);
- information about the Services that You use and how You use them, including log information and location information, when You are a user of the Services through the Platform;
- We may collect Your information such as name, age, contact details, preferences, etc. through surveys and forms, when You choose to participate in these surveys etc.;
- when You communicate with or use the Platform to communicate with other Users (such as partners), We collect information about Your communication and any information You choose to provide;
- Job search behaviour and preferences, and a record of the searches that You make on our sites;
- Your educational details as You sign up with us;
- Other details that You may submit to Us or that may be included in the information provided to Us by clients or Third Parties;
- Technical information about Your use of our Platform;
- when You use a device to access the Platform, the Company may collect technical or other related information from the device as well as the device location;
- to the extent permitted by law, the Company may record and monitor Your communications with Us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations;
- publicly available data about You from Third Party sites and sources, including profiles created by You on other websites, or other information you have publicly shared for the purpose of advertising or informing others about Your background;
2.2 We shall use Your Personal Data in a fair and reasonable manner, and where We have a lawful reason to do so. Our use of Your Personal Data depends on the purpose for which You interact with us. We may process Your Personal Data for the following purposes:
- Creating Your account and send You job alerts or other promotional materials;
- give You relevant search results and job recommendations;
- facilitate communication as part of the job search, application and interview process;
- make Your resume / profile available to Third-Parties which shall be informed to You;
- as applicable, match You with job-listings;
- facilitate payment, in connection with chargeable Services;
- carry out automated processing in order to provide many of Our Services;
- enhance and optimize Our Services and security for employees and employers by data sharing with our affiliated entities and websites;
- providing our Services and products to You including to send You job alerts, calendar alerts, relevant search results, recommended jobs and/or candidates (as the case may be), and other social media communication facilities;
- Protecting our Users and providing You with customer support;
- We use information collected from cookies and other technologies, to improve Your experience and the overall quality of our Services (for more information please refer to paragraph on cookies below). When showing You tailored ads, We will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
- Improving the Platform and its content to provide better features and Services.
- Conducting market research and surveys with the aim of improving Our products and Services.
- Sending You information about Our products and Services for marketing purposes and promotions;
- To the extent required for identity verification, government sanctions screening and due diligence checks.
- Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.
- Meet any applicable law, regulation, legal process or enforceable governmental request.
- Internal employment requirements
2.3 We may also collect and/or generate anonymized and aggregated information from Your use of the Platform. The anonymized or aggregated information is not Personal Data since We are not able to re-identify You using any means available to Us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help Us identify and remediate any bugs, and to improve the performance of Our Platform. The Company may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with Third Parties for Our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying You.
2.4 The legal basis on which We collect Your Personal Data:
- Performance of a Contract: some of the Personal data processed is performed on the basis that it is necessary for the performance of Our agreement with You, or in order to take steps at the request of the User prior to entering such an agreement. An example of this would be where We send a job seeker’s application to a hiring entity.
- Legitimate Interest : legitimate interests will include where We send You marketing about Our products and Services, where We believe You have a reasonable expectation that We will perform a particular type of processing on Your behalf, where such processing is strictly necessary for fraud detection and prevention. A further example would be where We share Your Personal Data with the Company’s affiliates. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our Services, products and features to You.
- Compliance with a Legal Obligation – A third ground relied upon for certain types of processing is that it is necessary in order to allow Us to comply with a legal obligation. An example of this would be where We are required to retain business records for fixed periods of time in order to comply with local legal requirements.
- Consent – Finally, in certain limited situations, We rely on Your consent in order to process Your Personal Data. Where We require Your consent in order to collect and process certain Personal Data, We seek Your consent at the time of provision, and such processing will only be performed where consent is secured. For example, Your consent will be sought where You provide Your location when You provide it yourself on our Platform, to help You find more relevant job listings, when You submit a photo that includes the provision of the location data of where the photo was taken, or in certain instances where You initiate a marketing message such as a job alert with Us. You can withdraw Your consent, as per this Policy where applicable, by sending an email to firstname.lastname@example.org.
2.5 Additional Uses and Disclosures of Non-Personal Data:
In addition to the other uses and disclosures of information set forth in this Policy, and notwithstanding anything in this Policy to the contrary, We may use and disclose, for any purpose, any non-personal data, except where We are required to do otherwise under applicable law. If We combine any non-personal data with personal data, then We will only use and disclose such combined information for the purposes described above while it is so combined.
2.6 Limitations of Use:
- Where Our customer / client wants to close any Applicant’s account and the customer / client shall no longer have access to any of the data We make available under that account.
- Where Our customer / client wants to close their own account.
- Where a client / customer wants to stop using a Service.
- Where details provided to Us are incorrect
- Where minimum age of Users is under the age of sixteen. However, if local laws provide for an alternative minimum age for Us to lawfully provide the Services in the Platform to You, then that shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if You are under the age of eighteen or the age of majority in Your jurisdiction, You must use Our Platform under the supervision of Your parent, legal guardian or responsible adult.
3. WHO IS THIS PERSONAL DATA SHARED WITH
We share Personal Data with certain Third Parties, such as suppliers, clients and advisers that perform certain services on Our behalf or that receive Services from Us. Sometimes sharing Your Personal Data with these Third Parties is necessary for them to perform their services or for Us to provide our Services to them.
We will only share Your Personal Data with Third Parties for the purposes identified above in accordance with the Policy, or with Your consent. We will endeavor to obtain assurances from each Third Party with whom We share Your Personal Data for purposes of maintaining our relationship with You (e.g., benefits providers) that it will safeguard Your Personal Data consistently with this Policy and will notify the Company if it makes a determination it can no longer meet this obligation. If We have knowledge that a Third Party is using or disclosing the Personal Data in a manner contrary to this Policy, We will take reasonable steps to prevent or stop the use or disclosure.
Your Personal Data may be also disclosed or transferred to a third party in the event of any proposed or actual reorganization, sale, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our Company or of any Company assets (including should the Company become insolvent, enter into receivership or any similar event occur). Should such an event take place, We will endeavor to direct the transferee to use the Personal Data in a manner that is consistent with this Policy.
We may also disclose Your Personal Data to third parties if necessary, to comply with legal obligations, for example to cooperate with regulatory authorities, law enforcement bodies, or courts, or if We believe that disclosure is necessary to protect Our rights or those of a Third Party.
4. HOW WE STORE DATA
We may store Your personal data using Our own secure on-site servers or other internally hosted technology. Your Personal Data may also be stored by Third Parties, via cloud services or other technology, with whom the Company has contracted, to support the Company’s business operations.
These Third Parties do not use or have access to Your Personal Data other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that We use to protect Your Personal Data.
5. HOW LONG DO WE STORE YOUR PERSONAL DATA
We store Your Personal Data until it is no longer necessary to provide our Services, or until You ask Us to delete Your Personal Data. We may also be required to retain certain information in order to comply with local laws. If You wish to delete Your Personal Data, You should submit a delete request to email@example.com. However, if You are a job applicant, please log-in to Your account and make a formal request to delete Your Personal Data.
6. TRANSFER OF PERSONAL DATA ACROSS BORDERS
The Company is a global company, with offices located in many countries. As a result, Your data may be transferred to other Company’s offices for the purposes identified above. Any such transfer shall take place only in accordance with and as permitted by the law of your jurisdiction, but please be aware that the laws and practices relating to the protection of the Personal Data are likely to be different and, in some cases, may be weaker than those within Your home jurisdiction. Regardless, in all events, We shall apply the provisions of this Policy to Your Personal Data wherever it is located.
7. CUSTOMER COMMENTS AND CONTENT
We use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under our control. No method of transmission over the internet, or method of electronic storage, is completely secure, however. In addition, please note that emails, messages sent via Your web browser, and other similar means of communication with other Users, are not encrypted. Therefore, while We strive to protect Your information, We cannot guarantee its security.
Please also be aware that We may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed Us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, We will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
9. AUTOMATED PROCESSING
Our clients may opt in to use features that assist them in the recruitment process through automated means. For You as a candidate, it means that Your application is processed and analyzed to identify relevant aspects from Your work history such as previous positions and employers, education history, demonstrated skills, and duration of work. These aspects are then compared against the job published by Our client to indicate how Your application corresponds with the requirements outlined in the job listing.
These findings help Our client highlight existing information in Your application. The automated capabilities are used to facilitate the recruitment process; however, any conclusive hiring decisions are ultimately at the client’s discretion.
10. EXERCISING RIGHTS WITH RESPECT TO PERSONAL DATA
As a User, You may avail Yourself of the rights explained below. Please note, We may attempt to verify Your identity through the email address or telephone number associated with Your use of our Platform prior to fulfilling any such request and reserve the right to deny a request where We are unable to satisfactorily complete this process. If You authorize someone to make a request on Your behalf, We may also deny Your request if We are unable to verify with You that the individual making the request is authorized to act on Your behalf.
In cases where We are data processors, We will forward any requests, inquiries or claims concerning these processing activities to the respective data controller for further assessment and necessary action.
10.1 The Right to Rectify Your Personal Data
The Users are able to edit and update most of their Personal Data held by Us on the Platform, and if You have any queries or complaints, We encourage You to contact Us at firstname.lastname@example.org.
Alternatively, if You do not wish to do this You may make a formal request to have Us rectify any inaccurate Personal Data on Your behalf by sending an email to email@example.com from the email address associated with Your account.
10.2 The Right to Object to or Restrict the Processing of Your Personal Data
If You have any queries or complaints about how We process Your Personal Data, We encourage You to contact Us at firstname.lastname@example.org.
Alternatively, if You do not wish to do this You may make a formal request to object to, or restrict, processing of Your Personal Data. For example, You have the right to object to the legitimate interest processing of Your Personal Data for marketing purposes. In order to do so, please write to Us on email@example.com for doing so.
10.3 Opting Out of Marketing Messages and Withdrawing Consent
If You no longer want to receive marketing materials from Us based upon Your Personal Data, You may opt-out by following the procedures specified below:
If You wish to opt out of a particular marketing email, You may do so by clicking “unsubscribe” (or an equivalent action) where applicable. Please note that this will only opt You out of that particular marketing message.
In addition, You may opt out of all marketing messages by sending an email to firstname.lastname@example.org. We will comply with Your request as soon as reasonably practicable, and in accordance with applicable laws.
Finally, please note that We may still send other messages to You, such as administrative and transactional messages.
10.4 The Rights of Access to and Portability of Your Personal Data
The Users shall be able to access most of their Personal Data held by Us on the Platform, and if You have any queries or complaints, We encourage You to contact Us at email@example.com. If You are a job applicant and wish to see the Personal Data that We have stored, You may log-in to Your account and click on the ‘profile’ tab to view Your Personal Data stored with Us.
Alternatively, if You do not wish to do this, You may make a formal request to access Your Personal Data held by us. We will provide Your Personal Data to You in a portable format to allow it to be transmitted to third parties. This right only applies to Personal Data that You have provided to the Company as the data controller.
If You have interacted with Us using more than one email address, please submit a subsequent request with the additional email addresses so that We may provide this Personal Data as well.
10.5 The Right to Delete Your Personal Data
The Users shall be able to edit and update most of their Personal Data held by Us on the Platform, and if You have any queries or complaints, We encourage You to contact Us at firstname.lastname@example.org.
If You wish to delete Your Personal Data, You may log-in to Your account and make a formal request under the ‘delete’ tab to delete Your Personal Data. Once Your request has been confirmed, We will initiate the necessary steps to execute this exercise. Where the deletion request relates to the Personal Data that You previously requested be made public on Our Platform (e.g. a job seeker posting a public resume), We will make reasonable efforts to inform any other controllers of this request. If You have interacted with Us using more than one email address, please submit a subsequent request from the account associated with such additional email addresses so that We may delete this Personal Data as well.
PLEASE NOTE: by requesting the deletion of Your Personal Data, You will no longer be able to create an account with the Company using the same email address. If You simply wish to close Your account, please click the “Delete” button in Your account page. If You use an application or take any other action on the Platform using the same email address associated with Your deletion request, You may not receive certain communications associated with those actions from Us or other Users. Additionally, by making a Personal Data deletion request, You acknowledge that You will be removed from consideration for all active sweepstakes, contests, prize draws, and other promotions.
10.6 Withdrawing Consent
There are certain activities where We ask for Your consent to use Your Personal Data. You have the right to withdraw this consent at any time by writing to Us at email@example.com. Where You are providing location information via a mobile app, You may turn off your location services on Your device at any time. For other services that rely on Your consent, You can withdraw your consent via the workflow for that given Service. Please note that any processing that We have carried out before the withdrawal of Your consent remains lawful.
10.7 Some Limitations
Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of the Company confirming Your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by the Company and only imposed to the extent permitted by applicable law.
11. CHILDREN UNDER EIGHTEEN
The Company does not knowingly collect data from children under the age of eighteen. If You are under the age of eighteen, You must ask Your parent or guardian for permission to use our Platform. If a child under eighteen (18) submits Personal Data to the Company and We learn that the Personal Data is the information of a child under eighteen, We will attempt to delete the information as soon as possible. If You believe that We might have any Personal Data from a child under eighteen (18), please contact Us at firstname.lastname@example.org.
12. EU RESIDENTS
If you’re not satisfied of how We process Your personal data and the processing of Your personal information is subject to the EU GDPR, You can lodge a complaint at any time to our Data Protection Officers or to the relevant data protection supervisory authority.
13. COOKIES INFORMATION:
We may send one or more cookies or other anonymous identifiers to Your device through the Platform to collect and store information when You visit the Platform.
- authenticate Users;
- personalize Your experience;
- analyze which portions of the Platform are visited or used most frequently; and
- measure and optimize advertising and promotional effectiveness.
If You do not want Us to deploy cookies in Your browser, You can opt out by setting Your browser to reject cookies or to notify You when a website tries to put a cookie in Your browser software. If You choose to disable cookies in Your browser, You can still use the Platform, although Your ability to use some of the features may be affected.
14. THIRD-PARTY ANALYTICS
At present, We work with the following analytic partners:
- Amazon RedShift(https://aws.amazon.com/redshift/)
For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if You opt out of any Services, You may not be able to use the full functionality of the Platform.
15. ADVERTISEMENT INFORMATION:
The Company or third-party advertisers or their advertising servers may also place or recognize unique cookies on devices or use other electronic tools in order to help display advertisements that the Customers see on the Platform. Information about visits to, and activity on, the Platform, an IP address, the number of times an advertisement has been viewed and other such usage information is used, alone or in combination with other information, to display on the device screen advertisements that may be of particular interest to You. We may use web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. The web beacons enable Us to recognize a browser’s cookie when a browser visits the website, and to learn which banner ads bring users to the website. The use and collection of the information by these third-party service providers, and third-party advertisers and their advertising servers is not covered by this Policy.
16.1 The owner for the Policy shall be the Data Privacy Officer. The Data Privacy Officer shall be responsible for maintenance and accuracy of this Policy. Any queries regarding the implementation of this Policy shall be directed to the Data Privacy Officer.
16.2 Notwithstanding, We currently keep Your Personal Data in a very secure manner and restrict who has access to it. We need Your Personal Data to be able to provide Services to You and to give You access to our Platform and You give Us your Personal Data at the time your register for Our Platform, download Our mobile app and/or use or buy Our products and Services.
16.3 We will notify as soon as possible but no later than 72 (seventy-two) hours if We determine that Our systems have been hacked and Your Personal Data disclosed as a result of such hacking or any other unauthorized breach of Your systems and databases.
17. POLICY REVIEW
Please note that We review and may make changes to this Policy from time to time and as required under applicable laws. We will not reduce Your rights under this Policy without Your explicit consent. When changes are made, the Policy link will include a notation “Revised (date).” indicating that You should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. By accessing the Platform after any changes have been made, You signify Your agreement on a prospective basis to the modified Policy and any changes contained therein. In case You miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.
18. PRIVACY CONCERNS
If You are concerned about the handling of your Personal Data, or if You have any complaints or queries related to Your Personal Data or our Policy, please contact:
The Data Protection Officer