Personal data is any information relating to an identified or identifiable natural person. It includes things like email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. These are just examples and there are many other types of information that would be considered personal data.

This Policy describes our collection and use practices. To make this easier for you to navigate, please use the links below:

A. WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSES

  • Personal data you disclose to us
  • Data automatically collected by us
  • Data collected from other sources
  • Other Purposes For Which We May Use The Personal Data We Collect

B. DO WE COLLECT DATA FROM MINORS?

C. HOW WE HANDLE YOUR SOCIAL LOGINS

D. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

E. HOW YOUR PERSONAL DATA IS SHARED

F. PROCESSORS AND INTERNATIONAL DATA TRANSFERS

G. HOW LONG WE KEEP YOUR INFORMATION

H. HOW WE KEEP YOUR INFORMATION SAFE

I. DE-IDENTIFIED (ANONYMIZED) AND AGGREGATE DATA

J. YOUR PRIVACY RIGHTS AND CHOICES

  • How to Submit a Request to Exercise Your Rights
  • Your Account and Communication Choices

K. UPDATES TO THIS POLICY

L. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

ANNEX 1 – ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

We hope you take some time to read through this Policy carefully, because it is important. If there are any terms in this Policy that you do not agree with, please immediately discontinue use of the Platform and our services. If you have any questions or concerns about our collection or use of your information, please contact us at legal@hiring.day

A. WHAT PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSES

Hiring Day uses personal data it collects directly from you, automatically from your device, or from third-party providers. Below we describe the personal data that we collect from the various sources and the purposes we use the data for. We also describe the legal bases. Please note, that those laws that apply to the processing of personal data (including regulations, guidelines, government-issued rules, and court opinions interpreting laws) (hereinafter collectively referred to as “data protection laws”) may require us to describe our processing using certain terms or in a specific way. Although we have tried to use terms consistent with data protection laws, we aren’t always able to use terms that may be used in your jurisdiction. If you have any questions about this Policy, please contact us at legal@hiring.day.

Personal data you disclose to us

We collect personal data that you provide to us when registering to use the Platform, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Platform or otherwise contacting us.

The personal data that we collect depends on the context of your interactions with us and the Platform, the choices you make and the products and features you use, including for the following purposes:

  • To facilitate account creation and logon process. We use the personal data you provide to create an account with us, including: your first and last name, email address, mailing address, phone number, and other similar contact data; usernames, passwords, password hints, and similar security information used for authentication and account access; and employment, resume or CV, cover letter and other job-related data (e.g. nationality, date of birth, education) that you submit to us or provide us access to in connection with the Platform. Processing is necessary in order to enter into a contract with you or for the performance of the contract with you. Without providing your personal data, you cannot create an account with us.
  • To provide the services. We may use the personal data you decide to share with us in order to create a resume, cover letter or other type of document available on our Platform, including: your first and last name, employment history, resume, cover letter, country, social media handles, education history, employment history, licenses and certificates, biography, industry, phone number, and other job-related data. Please note that without providing your personal data, we would not be able to create a resume, cover letter or other type of document available on our Platform. Additionally, you may decide which data you wish to share with us relevant to your job search. Processing is necessary for the performance of the contract with you.
  • To send administrative information to you. We may use your personal data to send you information about products or services you have purchased or information about changes to our terms, conditions, and policies, including: first and last name, email address, mailing address, phone number, and other similar contact data. Processing is necessary for the performance of the contract with you or in order to fulfil our legal obligations.
  • To fulfil and manage your orders for services. We may use your personal data to fulfil and manage your orders for services, subscriptions, and payments, and to address any issues with services provided through the Platform, including: your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our third-party payment providers as set forth below. You should review its privacy policies and contact the payment provider directly to respond to your questions. Processing is necessary for the performance of the contract with you.
  • To deliver job alerts via email. We may use your email address and job- related preferences to provide you with email job alerts when you sign up for such service. Therefore, the processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To post testimonials. We post testimonials on the Platform that may contain personal data. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences. These communications may include information about our new products, services, or features. The personal data collected for these purposes. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness. The personal data collected for these purposes. We will ask for your consent to use your personal data for this purpose. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To request feedback. We may use your personal data to request feedback and to contact you about your use of our Platform so that we can improve our products and services and develop additional products and services to better serve our users. The personal data collected for these purposes. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. We always carry out a legitimate interest assessment in such cases. If you have any questions about this, please contact us.
  • Interview Recordings – where you voluntarily record yourself, we may collect recordings of you through certain features, such as the Event Video Interview Questions. In addition, we may choose to record certain group or 1:1 sessions, in which case you will be presented with an on-screen notification that such a recording has started. If you do not wish to be recorded, please turn off your camera at such time. Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

Data automatically collected by us

We automatically collect certain information when you visit, use or navigate the Platform. For more information about the use of Cookies on our platform and the choices you have, please see our cookies policies.

  • To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences, including: 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 the Platform and other technical information. We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including: 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 the Platform and other technical information. We will ask your consent to use your personal data for this purpose. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To protect the Platform, us, and others. We may use your personal data as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse, including: 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 the Platform and other technical information. The processing of your personal data for this purpose is based on our legitimate interest
  • To improve the Platform. We may use your personal data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience, including: 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 the Platform and other technical information. The processing of your personal data for this purpose is based on our legitimate interest or the processing is necessary to comply with legal and regulatory obligations.

Please refer to our cookie polices for more information on how we use cookies.

Data collected from other sources

We may use third party service providers to help us with our day-to-day business activities. Where we use third parties, they may share personal data about you with us

  • 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, LinkedIn or Facebook account), we use the personal data you allowed us to collect from those third parties to facilitate account creation and logon process. Personal data we may receive from your social media provider include: including: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public). Processing is necessary to enter into a contract with you, or for the performance of the contract with you or the processing is based on our legitimate interest.
  • To send administrative information to you. We may use third parties to send you administrative information about products or services you have purchased. We may receive personal data about you from the third party. Processing is necessary for the performance of the contract with you or the processing is based on our legitimate interest.
  • To fulfil and manage your orders for services. All payment data is stored by our third-party payment provider when we fulfil and manage your orders for services, subscriptions, and payments. When you make a purchase our third-party payment provider may share transaction information, such as: name, email address, billing address, transaction ID, time, amount, and payment type. Processing is necessary for the performance of the contract with you. Third-party payment providers act as independent controllers over your personal data when you conduct a transaction with them. For more information on how your personal data is processed by our third-party payment providers, please review their relevant privacy policies:
    1. Adyen - https://www.adyen.com/policies-and-disclaimer/privacy-policy
    2. Apple Pay - https://www.apple.com/legal/privacy/
    3. Braintree (a service of PayPal, Inc.) - https://www.paypal.com/us/legalhub/privacy-ful
    4. dLocal - https://www.dlocal.com/legal/privacy-hub
    5. Google Pay - https://payments.google.com/payments/apis- secure/get_legal_document?ldo=0&ldt=privacynotice
    6. Mollie - https://www.mollie.com/privacy
    7. Paypal - https://www.paypal.com/us/legalhub/privacy-full
    8. Stripe - https://stripe.com/privacy
  • To send you marketing and promotional communications. Our third- party marketing partners may share your personal data for our marketing purposes, depending on your marketing preferences, including marketing leads and search results and links, including paid listings (such as sponsored links). We have a legitimate interest in doing this if you are our customer, otherwise we ask for your consent. You can opt out of our marketing emails at any time (see the section Your Account and Communication Choices below). You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
  • To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including: marketing leads and search results and links, including paid listings (such as sponsored links). We will ask your consent to use your personal data for this purpose. You can opt out of our marketing emails at any time see the section Your Account and Communication Choices

Other Purposes For Which We May Use The Personal Data We Collect

We may use any personal data we collect as described above for the following business purposes: 

  • To develop our products and services. We may use your personal data to further develop our existing products and services, including artificial intelligence tools and features, or to develop new products and services. 
  • To protect the Platform, us, and others. We may use your personal data as part of our efforts to keep the Platform safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.
  • To enforce our terms, conditions and policies.  We may use your personal data to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.
  • To respond to legal requests and comply with applicable law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your personal data and potentially provide your personal data in response to the request.  We may also need to use your personal data as needed to comply with applicable laws and regulations.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Platform, products, services, and your experience.

We have a legitimate interest in using your personal data for these purposes if you are our customer, otherwise we will obtain your consent. You also have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.

B. DO WE COLLECT DATA FROM MINORS?

Our Platform is not directed to minors under the age of 16 (or under the age of majority as determined by applicable, local law) and we do not intend to collect personal data from minors under the age of majority. Therefore, we recommend that parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal data without parental consent. If you believe that we inadvertently have collected personal data about your child, please contact us at legal@hiring.day and we will promptly delete or de-identify this information.

C. HOW WE HANDLE YOUR SOCIAL LOGINS

The Platform, one of our websites or mobile applications may offer you the ability to register and login using your third-party social media account details (like your Facebook, LinkedIn, Instagram, Google or Twitter logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive for the purposes that are described in this Policy.

Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

D. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to collect or store information. Specific information about how we use such technologies and how you can refuse or disable certain cookies is set out in our cookie policies. The use of cookies other than essential cookies, including for the purposes of targeted advertising, is performed on the basis of your consent.

Do-Not-Track Features (U.S., Canada and EU Residents only) Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do-not-track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will update this Policy if that changes in the future. These features are not an alternative to the settings you choose in our cookie banner.

E. HOW YOUR PERSONAL DATA IS SHARED

Hiring Day Affiliates and Subsidiaries may generally share personal data with each other so that
we can provide our services to you, in so far as there is a legal basis. In addition, we may share
your personal data with the following categories of third parties for one or more of the purposes
described above and if there is a legal basis:

  • Service Providers (or Processors) subject to written agreement to process your
    personal data consistent with our instructions, including:
    1. SMS and other messaging service providers
    2. Content optimization service providers
    3. Invoice and billing service providers
    4. Social media companies to which you enable access
    5. Software service providers that parse and match resumes with job postings
    6. Email job alert providers
    7. Website and application analytics providers
    8. Website hosting providers
    9. Website testing and optimization service providers
  • In addition, where permitted by law, and this Policy, we may share your personal data
    with the following types of Marketing and Advertising Partners:
    1. Advertising, direct marketing, and lead generation providers
    2. Social media site advertising providers
    3. Targeted advertising platforms

SMS Originator Opt-in Data and Consent (US & Canada Residents)Hiring day does not sell or share mobile phone information with third parties for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Where we believe it necessary or appropriate to do so, we may share your personal data with: law enforcement; government agencies or regulators; courts; and parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive. In those circumstances, we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible.

Our services may also include distributing your resume, CV, Cover Letter and other related information to third-party job sites with your consent and at your request. Should you elect to receive such services, your information shall be governed by and subject to the privacy policy on the respective sites to which your information is sent. We are unable to effectuate any changes or deletions to your information on such sites once your information has been sent and any communications regarding your information on such sites must be made with those sites directly.

Finally, we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

F. PROCESSORS AND INTERNATIONAL DATA TRANSFERS

We will only engage processors who adequately implement appropriate technical and organizational measures and who guarantee the protection of your rights. In order to ensure this, we enter into data processing agreements with our processors. This is compulsory under the data protection laws. The data processing agreement regulates, among other things, data security, confidentiality and your rights.

If your personal data are transferred to ‘third countries’ – i.e., countries outside the European Economic Area (“EEA”) – we will only do so if the third country offers an adequate level of protection. In some countries outside the EEA – which as at the date of the last update of this Policy include Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland , the United Kingdom under the GDPR and Directive (EU) 2016/680, the United States (commercial organizations participating in the EU-US Data Privacy Framework) and Uruguay– your personal data are sufficiently protected in accordance with European data protection laws and regulations. Where this is not the case, we provide appropriate safeguards to ensure adequate data protection, such as the most recent standard contractual clauses as approved by the European Commission and by additional safeguards, a copy of which can be obtained by sending an e-mail to legal@hiring.day. If no appropriate safeguards are in place, we will only transfer your personal data if a legal exception applies. An example of a legal exception is explicit consent.

G. HOW LONG WE KEEP YOUR INFORMATION

We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements). In determining data retention periods, we take into consideration the applicable law, contractual obligations, and your expectations.

When there is/are an indication(s) of potential legal claim(s) or liability, the retention period will be extended accordingly.

When we have no ongoing legitimate business need to process your personal data, i.e. when we no longer have a legal basis in accordance with applicable law, we will either delete or anonymize it and we will make such determination based on applicable laws. When the processing of personal data is based on your consent, the data will be stored for as long as there is valid consent for the processing.

H. HOW WE KEEP YOUR INFORMATION SAFE

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store, including measures designed to protect data transferred to different countries for use or processing in accordance with this Privacy Policy. We will do our best to protect your personal data taking into account the state of art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing. You should however access the Platform within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at legal@hiring.day.

H. DE-IDENTIFIED (ANONYMIZED) AND AGGREGATE DATA

Hiring Day may de-identify (as also referred to as “anonymize”) and aggregate data for its business purposes, including but not limited to, to improve the products and features of its Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. De-identified Data includes anonymized data and is no longer “personal data” under applicable data protection laws. Where we process De-identified Data, we commit to maintain and use the information in de- identified form and not attempt to reidentify the information, except where permitted by law. Hiring Day may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in anonymized form and not attempt to re-identify the data for any business purpose.

J. YOUR PRIVACY RIGHTS AND CHOICES

The rights described in this section apply to all users. Note: Some data protection laws may use other terms to describe these rights differently. If you have any questions about these rights please contact us at legal@hiring.day.

Right to Access and to Know — You have the right to access the personal data collected about you. You also may request to know the categories of personal data collected about you, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information. However, there are certain exemptions, meaning that data subjects may not always receive all of the information we process.

Right of Complaint — If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at legal@hiring.day. We will always try to find a solution together. Should this not be possible, you have the right to complain to a Data Protection Authority about our processing of your personal data. If you are in the EEA, please contact your local Data Protection Authority in the EEA.

Right to Correct — Without prejudice to your right to review or change the information in your account to make sure it is accurate and up-to-date, you also have the right to request rectification of any other of your personal data, provided to us if you consider it to be inaccurate or incomplete.