Last Updated : Jul 27, 2019
We urge you to read this Policy thoroughly. By accessing our website/mobile app and using our Service, you will have represented your agreement to this policy and bound by its terms. This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully.
Scope of the Policy
Our privacy and security practices in connection with the access and use of our Services are governed by the Master Subscription Agreement, which is a binding contract between the Subscriber (sole proprietor or legal entity which has subscribed to our Platform) and us.
When we collect and process information under the directions of our Subscribers, we act as mere Data Processors and have no direct rapport with individuals whose Personal Information we processes. All Candidates or applicants who interact with our Subscribers through our Service are directed to solicit their requests regarding their Personal Information (to amend, rectify, erase, and so forth,) to our Subscribers i.e. the employers who have posted the job vacancy. We are not responsible, and our Subscribers are wholly and solely responsible for their policies and compliances with all the applicable laws and regulations, and other duties relating to the collection and retaining Personal Information from individuals (known as data subjects) in connection with the use of our Platform.
We employ third parties to perform certain tasks to facilitate our Service and to assist us in analyzing its usage. We may transfer certain Personal Information to these third parties, but this transfer will be subject to your explicit consent and the Terms of Service. These third parties have access to your Personal Information albeit only to perform specific tasks on our behalf and are contractually and otherwise obligated not to disclose or use your information for any other purpose.
What information we collect
Any personal information voluntarily entered by a user
We collect the Personal Information that you enter into our system voluntarily. We Process this Information and create your identity at Recooty and also to facilitate your use of our Service. This information is required to create your Account, identify and communicate with you, respond to your requests/inquiries, servicing your purchase orders, and improving our Platform.
The information you give when you sign up for a Free Account includes your name, company name, contact number and email. This Personal Information is used to allow you to create your Account and utilize the Service. We do not need your credit card information for a Free Account. In case you opt to subscribe to our Paid Account, we require your credit card/debit card information to process your payments but we neither transmit nor save the information on our servers. We use a third-party intermediary for processing such payments, Paypal.com, which is PCI DSS compliant. Paypal has been audited by an independent PCI Qualified Security Assessor (QSA) and is certified as a PCI Level 1 Service Provider. This is the most stringent level of certification available in the payments industry. If You are located in the EEA or Switzerland, Paypal complies with applicable laws to provide an adequate level of data protection for the transfer of Personal Information and is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework.
We do not collect any sensitive personal information such as racial/ethnic origin, political opinions, religious or philosophical beliefs, trade union affiliation, genetic, biometric data, health data or data concerning sexual orientation from our Subscribers. Any candidate who discloses such information to our Subscriber, with whom he directly interacts with should do so at his own will and on careful reading of the Subscriber’s privacy policies.
You may also enter some personal information on our Contact Us form, which we use to contact you. You can sign up for providing information about upcoming developments at Recooty by checking the box while on the page. You may opt out of receiving any, or all, of these communications from us by clicking on the unsubscribe link or by following the instructions provided in our emails or by contacting us at [email protected].
You may enter other information on our website such as comments on our blog which information is publicly visible and accessible. In case you wish to remove this information, you may contact us on [email protected].
If you choose to post information through our Service or engage in email, regular mail, telephone or other contact with us, we may retain information disclosed thereby as well.
Information that our system collects
Logs and Analytics
We accumulate information that your browser sends whenever you visit our Website or use our Service (known as ‘Log Data’). This Log Data includes information such as your computer’s Internet Protocol (IP) address, browser type, browser version, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, the information you search for, local and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information, the time spent on those pages usage information, and other statistics.
We use third-party service providers of analytics service (view our list of sub-processors), that collect, monitor and analyze anonymous Log Data to assist us to increase our Platform’s functionality and market.
Cookies and other Tracking Technologies
As a Subscriber, you have an option to restrict the placement of cookies on your browser or remove them from your browser by changing your browser settings. Google, Facebook, and AdRoll provide an opt-out option for their visitors on their respective websites. The Help feature on most standard browsers offers information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.
Kindly note that in case you opt to decline cookies and flush out the cookies from your computer, it will reduce the functionality of our Platform.
Information collected for identity verification
To help create and maintain a trusted environment, we may collect information related to you or your organisation which is normally listed on public forums and from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may use to supplement the information that we collect directly from you.
Information collected from other sources
In order to provide a hassle-free experience to our Subscribers, We give them an option to integrate with third parties (e.g. Google, Facebook, linkedin) such as service providers of social media or authentication services. When our Subscriber opts for this service, he allows access to us of his information including personal information which is entrusted such third parties. Using these features will authenticate your identity, provide you with the option to share specific personal information with us, and pre-populate our sign up form. This information varies and is controlled by that third party service or as authorized by you via your privacy settings at that service. Authorisation procedures of the third party social media or authentication service determine the extent of access to your information. Subscribers are encouraged to examine their privacy settings to change any information sent to us through these third parties.
How we use/process information that we collect
Provide, Improve and Develop Recooty Platform:
- Providing, operating, maintaining, improving, and promoting our Service;
- Enabling access and use of our Services;
- Processing and completion of transactions, and sending related information, including intimations of purchase and invoices;
- Sending transactional messages, including responses to your comments, questions, and requests; providing customer service and support; and sending technical notices, updates, security alerts, and support and administrative messages;
Create and Maintain a Trusted and Safe Environment:
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you (such as to verify your identity)
- Comply with our legal obligations.
- Enforce our Terms of Service and other policies.
Provide, Personalise and Improve our Advertising and Marketing:
- Sending promotional communications, such as providing information about our products and services, features, surveys, newsletters, offers, promotions, contests, and events; and providing other news or information about our partners and us.
- Monitoring and analyzing usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
- Investigating and preventing fraudulent transactions, unauthorized access to the Services, and other illegal activities;
- Personalizing the Websites and Services,
- To contact you about changes to our site and Service, new Service, features or products we offer, or other information we think you might find valuable, as well as to provide or enhance features of our Site and Service.
Where you have provided consent, we use/process your information for any other purposes.
Legal Basis for Processing the information (In compliance with GDPR)
We process personal information only in the specific context in which we collect it. We usually collect information when we have your consent or to perform a contract with the Subscribers or in furtherance of a legal obligation.
If you need further clarification concerning the legal basis on which we collect and use your Personal Information, you may contact us at the addresses given further below.
Security: How we protect your information
The security of your Personal Information is important to us. Therefore, we have implemented and are continuously implementing and updating appropriate administrative, technical, organisational and physical security measures of commercially acceptable security standards to help protect your information against unauthorized access, loss, destruction, use, alteration or disclosure of any information we store. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Recooty Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Recooty Account, please contact us following the instructions in the Contact us section below.
Disclosure & Sharing of Information
Disclosure to third parties
We use third-party service providers for backup, storage, payment processing and other services (view our list of sub-processors). We share data which may include your Personal Information with such select third parties so that they can access and process the information for providing these services to us. These third parties are contractually and otherwise legally bound not to disclose or use your Personal Information for a purpose other than in connection with providing the service to us.
When you initiate a connection with a third-party integration through the Platform, we will share information about you that is required to enable your use of the third-party integration through the Platform.
Recooty makes it possible for you to upload and share comments or feedback publicly with others, such as on the Recooty blog. Any information that you submit through such public features is not confidential, and Recooty may use it for any purpose (including in testimonials or other Recooty marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Such information can be read, collected and/or used by other users, and it could be used to send you unsolicited messages. Accordingly, please take care when using these features of the Platform.
We may also disclose your information to third parties with your consent to do so. For example, we will display your Personal Information on your profile page and elsewhere on the Platform in accordance with the preferences you set in your account. You can review and revise your Profile information at any time.
Compliance With Laws
We are bound to disclose your Personal Information where required to do so by law or compelled by any legal process. We will disclose your Personal Information if we believe that the disclosure is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of Our Service.
How long we retain your Personal Information
We retain your personal information for as long as is needed to fulfill the objects outlined in this Policy unless a more extended retention period is mandatory or permitted by laws. When we have no ongoing legitimate business need to process your personal information, 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.
For personal information that we process on behalf of our Subscribers, we will retain such personal information by the terms of our agreement with them, subject to applicable law.
- Visitors, Subscribers and Candidates have a right to request their own Personal Information, that we hold or process on behalf of a third party and we will provide it to you.
- Subscribers have a right to request change/rectification of any Personal Information entrusted to us as Account Information or complete any incomplete Personal Information.
- Subscribers also have a right to have their personal information maintained by us removed from our systems or returned. Provided that, notwithstanding such request, this data may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.
Visitors and Subscribers may direct any of the above requests to [email protected], and we will handle such requests to access, change, or remove your information within thirty days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Candidates directly interact with our Subscribers and should direct their requests to access, change, remove or correct your Personal Information that we process/store on behalf of the Subscriber, through the concerned Subscriber. Upon receipt of the request from the Subscriber, we will respond to their request within thirty days.
Where you have provided your consent to the processing of your personal information by Recooty you may withdraw your consent at any time by changing your Account settings or by sending a communication to Recooty specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; or (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims.
Additional rights for EEA territories
- The right of erasure: You may have a broader right to erasure of personal information that we hold about you in certain circumstances. Such circumstances may include, for example, if the data is no longer necessary in connection to the purposes for which it was initially collected. However, we need to add that that we may need to retain certain information to keep records, to complete transactions or to comply with our legal obligations.
- The right to restrict processing: In certain circumstances, you may have the right to request that we should restricts processing of your personal information such as, where you contest the accuracy of your Personal Information, for a period enabling us to verify the accuracy of such Personal Information. You also have a right to be informed when such restriction is lifted.
- The right to data portability: You may have the right to be provided with your personal information in a structured, machine-readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance. You also have a right to request that your Personal Information be directly transferred to another controller where it is technically feasible.
- The right to object to processing: You may have the right to request that we should stop processing your personal information and to stop sending you marketing communications.
You also have the right to complain to a data protection authority about our collection and use of your personal information. Kindly contact your local data protection authority.
Personal Information of Children
We do not knowingly collect personally identifiable information from children under 13. If you are a child under the age of 13, do not submit any Personal Information to us. If you are a parent or guardian, we encourage you to instruct your children not to disclose any Personal Information without your consent. In case you have any reason to believe that a child has provided us his/her Personal Information, please bring it to our notice by emailing us at [email protected]. We will take immediate steps to remove that information from our servers.
Recooty as a data processor
We may collect, use and disclose certain Personal Information about candidates when acting as the Subscriber’s service provider. Our Subscribers are responsible for making sure that their candidate’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a Subscriber’s data processor, we will process all Personal Information in accordance with the terms of our agreement with the Subscriber and its lawful instructions.
Links To Other Sites
Changes to the Policy