ERECRUIT
Erecruit Holdings, LLC is committed to safeguarding the privacy of our existing or potential clients and suppliers (Associated Entities), and website users (Website User) (collectively you/your) who visit www.erecruit.com (the Website) and/or to clients that we provide the software products and services to (Service). We use commercially reasonable physical, electronic and procedural measures to protect personal information in accordance with data protection legislative requirements. This Privacy Policy sets out our personal information collection and sharing practices for use of this Website and the Service.
With respect to the Service, please note that we are only data controllers with respect to any Associated Entities’ personal information for the purposes set out in this Privacy Policy. For all other purposes relating to the Service, we operate as data processors for our clients and our clients act as data controllers. Our clients have their own privacy policies and we do not accept any responsibility or liability for their policies or processing of personal information. This Privacy Policy and the rights and obligations set out below only apply where we are acting as data controllers.
By providing your information to us (either via this website, in person or over the phone), you understand and acknowledge the processing set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your personal information together with the ability to opt in or out of selected uses may also be provided to you when we collect personal information from you.
The Website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
EU-U.S. Privacy Shield
Erecruit Holdings LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Erecruit Holdings LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Erecruit Holdings LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Erecruit Holdings LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Erecruit Holdings LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Erecruit Holdings LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
EU Privacy Shield HR dispute resolution language
Erecruit Holdings LLC has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of Erecruit Holdings LLC’s HR Data.
This Privacy Policy is intended to explain our privacy practices and covers the following areas:
US POLICY
US Policy
Information we may collect about you
We may collect and process the following personal information about you whether you are a Website User or Representative:
Information you provide to us ► personal information that you provide to us either via the Website or as part of your/your company’s use of our Service, such as your name, address (and/or proof of address), other contact details (e.g. phone number, email address), your financial details;
Credit and Anti-Fraud information ► information relating to your financial situation, your creditworthiness or any criminal or fraudulent activities provided to us by you or third parties including information which establishes your identity, such as driving licences, passports and utility bills; information about transactions, credit ratings from credit reference agencies; fraud, offences, suspicious transactions, politically exposed person and sanctions lists where your details are included;
Our correspondence ► if you contact us, we may keep a record of that correspondence;
Survey information ► we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
Your transactions ► details of transactions you carry out through the Website or through other channels and of the fulfilment of the Service we provide; and
Website and communication usage ► details of your visits to the Website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
For Erecruit as a processor, we collect information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
How we may use your personal information
We may use your personal information in the following ways. For each use, we note the grounds we use to justify each use of your personal information:
We may use your personal information in the following ways. For each use, we note the grounds we use to justify each use of your personal information:
Where you are a Website User only
To provide you with information ► to provide you with information about the Service and other market insight which you have chosen to download from the Website
Use justification: legitimate interests (to enable us to fulfil your request and understand what type of market information you are interested in)
To ensure the Website content is relevant ► to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers
Use justification: contract performance, legitimate interests (to allow us to provide you with the content and services on the websites)
Where you are a Representative only
To provide and manage the Service effectively and conduct our business ► to administer our services, including to manage our relationship with your company, to ensure that we are paid and to carry out our obligations arising from any agreements entered into © 2018 Erecruit Holdings, LLC. Confidential & Proprietary. All Rights Reserved. Page 3 between your company and us, which may include passing your data to third parties such as agents or contractors or to our advisors (e.g. legal, financial, business or other advisors)
Use justification: contract performance, legitimate interests (to enable us to perform our obligations and to provide our services to you. Where you are either a Website User or a Representative
To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own and our third-party integration partners’ products and services to you by post, email, SMS, phone, remoting meetings and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out below.
Use justification: express and implied consent
To allow you to participate in interactive features of the Website and promote our Service ► to enable you to use bulletin boards, blogs, or chat rooms on the Website where available Please note that if you use such interactive features, any personal information you submit can be read, collected, or used by other users of these forums. We are not responsible for the actions of such other users.
Use justification: legitimate interests (to facilitate discussion)
To promote our Service ► We may post testimonials and references on our Website which may contain personally identifiable information such as your name. We will ask for your consent before doing so
Use justification: consent
For research and development purposes ► to analyse it in order to better understand your services and marketing requirements, to better understand our business and develop our products and services
Use justification: legitimate interests (to allow us to improve our services)
To monitor certain activities ► to monitor calls and transactions to ensure service quality, compliance with procedures and to combat fraud;
Use justifications: legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services)
To inform you of changes ► to notify you about changes to our services and products
Use justification: legitimate interests (to notify you about changes to our service).
To reorganise or make changes to our business ► In the event that we are (i) subject to negotiations for the sale of our business or part thereof to a third party, (ii) is sold to a third party or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process or transfer to that re-organised entity or third party and used for the same purposes as set out in this policy or for the purpose of analysing any proposed sale or re-organisation © 2018 Erecruit Holdings, LLC. Confidential & Proprietary. All Rights Reserved. Page 4
Use justification: legitimate interests (in order to allow us to change our business)
In connection with legal or regulatory obligations ► Law enforcement, regulators and the court service ► We may process your personal information to comply with our regulatory requirements or dialogue with its regulators as applicable which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Use justification: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities) We justify our use under one of a number of that are generally accepted across the globe.
These are the principal legal grounds that justify our use of your information:
Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent by contacting us in accordance with the Privacy Policy).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
Transmission, storage and security of your personal information
Security over the internet
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.
All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website and/or Service, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone. Export outside the EEA
To the extent personal information is subject to the EEA General Data Privacy Regulation (the “GDPR”) and EEA data protection laws, and may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA. © 2018 Erecruit Holdings, LLC. Confidential & Proprietary. All Rights Reserved. Page 5
Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions . In countries which have not had these approvals, (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm). We will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.
Please contact us as set out below if you would like to see a copy of the specific safeguards applied to the export of your personal information Storage limits
We will retain your personal information for as long as is necessary for the processing purpose(s) for which they were collected and any other permitted linked purpose (for example certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). So if information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period one that period expires.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
Third Party Service Providers/Vendors
We share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements, and are not allowed ot use PI they receive from us for any other purpose. Representative business processes that our service providers/vendors assist US with include: [providing customer service, sending marketing communications] – Please feel free to tailor this disclosure.
As described in this Privacy Notice, Customer and third parties on our digital propert(ies) may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests. To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit: -Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices) -European Interactive Digital Advertising Alliiance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu) -Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).
Cookies Policy
We use cookies on the Website. To find out more about how we use cookies, please see our Cookies Policy located on the Website.
Erecruit and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.
Changes to our Privacy Policy and/or Cookies Policy
We may change the content of our Website and how we use cookies without notice, and consequently our Privacy Policy and our Cookie Policy may change from time to time in the future. We therefore encourage you to review them when you visit the website from time to time to stay informed of how we are using personal information.
This Privacy Policy was last updated on September 10, 2019. © 2019 Erecruit Holdings, LLC. Confidential & Proprietary. All Rights Reserved
Further notices highlighting particular uses (such as direct marketing) we wish to make of your personal information together with the ability to opt in or out may also be provided to you when we collect certain personal information from you. If you have any questions in relation to our use of your personal information, you should first contact us as per below. Under certain conditions, you may have the right to require us to:
- provide you with further details on the use we make of your information;
- provide you with a copy of the information that you have provided to us;
- update any inaccuracies in the personal information we hold (we will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set below;
- delete any personal information the we no longer have a lawful ground to use;
- where processing is based on consent, to withdraw your consent so that we stop that particular processing;
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to any regulatory authority having jurisdiction over said complaints.
Your rights & contacting us
Please note that these rights only apply to data subjects covered by this Privacy Policy for whom we are acting as data controllers. When we collect personal information on behalf of our clients as data processors, please contact the relevant client to exercise your rights.
Marketing
You have the right to ask us not to process your personal information for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us as set out below.
Your rights If you have any questions in relation to our use of your personal information, you should first contact us as per below. Under certain conditions, you may have the right to require us to:
- provide you with further details on the use we make of your information;
- provide you with a copy of the information that you have provided to us;
- update any inaccuracies in the personal information we hold (we will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out below);
- delete any personal information the we no longer have a lawful ground to use; © 2018 Erecruit Holdings, LLC. Confidential & Proprietary. All Rights Reserved. Page 6
- where processing is based on consent, to withdraw your consent so that we stop that particular processing;
- object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
- restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office.
Data protection legislation gives you the right (subject to various exceptions) to access certain personal information held about you, correct any inaccuracies and prevent the processing of your personal information that is likely to cause unwarranted substantial damage or distress to you or anyone else and to object to any decision that significantly affects you being taken solely by a computer or other automated process. Any access request (subject to various exceptions) may be subject to a modest administration fee.
Updating information
Upon request,We will provide you with information about whether we hold any of your personal information and we will use reasonable endeavours to ensure that your personal information is accurate, you may access, correct, or request deletion of our personal information and in order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out below. We will respond to your request within a reasonable timeframe.
Upon using our service, We acknowledge that you have the right to access your personal information. Erecruit has no direct relatioship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inacurate data should diret his/her query to Erecruit’s client (the Data Controller). If requested to remove data we will respond within a reasonable timeframe.
Contacting us
Erecruit Holdings, LLC is the data controller of your personal information processed by us under this Privacy Policy. If you have questions or concerns regarding this Privacy Policy, you should contact our Data Privacy Officer at security@erecruit.com or our General Counsel at (617) 535- 3786. 2 Oliver Street, Fourth Floor, Boston, MA. 02109