We, ZHired, explain in this Privacy and Cookie Policy (the "Policy") how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the "Platform") that link to this Policy, as amended from time to time. This Policy describes how ZHired collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.

Unless we specify otherwise, this Policy applies only to information we collect, process and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us, unless we notify you at the time of collection that this privacy policy applies.

Information We Collect

We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. If you are a registered user of the Platform the data collection is largely necessary for fulfilling our contractual obligations towards you and, where neither of those is the case, alternative legal grounds serve as our legal basis for processing (i.e., consent, legal obligation, and legitimate interests—see details below).

Information You Give Us

When you fill out registration forms, submit your resume, or provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:

  • Creating an account
  • Signing up for email alerts
  • Completing a form related to one of our products or services
  • Uploading a CV
  • Completing your Profile or preferences
  • Sending messages through ZHired
  • Contacting us for technical support or customer service

Depending on how you interact with our Platform, the personal information we collect from you may vary. For example, to create an account we may ask only for an email address and password. In other circumstances, such as when you complete a form related to a particular service offering, we may ask you to provide other information, which may include your name, phone number, and/or postal address. We also collect and store certain information associated with actions you take. For example, when you search for jobs, we store the titles, locations and general salary range (if available) of jobs you search for and click on. We also store information about the job postings that you apply to, the time and duration of your activity on our Platform, and other information about your behavior on our Platform. Because much of this information is necessary for us to provide you with our service, if you don't share this information you may not be able to use some features of the ZHired platform.

If you connect to the Platform using Facebook, Google, or another social networking site (each a "Social Networking Site"), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, birthday, current city work, school, and email address. When we receive this information, it becomes ZHired account information for purposes of your use of the Platform. This information also constitutes personal information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site's privacy and data practices. You have the ability to disconnect your Social Networking Site account from your ZHired account by adapting the privacy settings in your Social Networking Site account. If you come to the Platform through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.

On certain ZHired domains, when you set up an individual user account on the Platform, you may create a profile (a "Profile") that will include personal information you provide. At your request, we will create your Profile with information we extract from a resume you have uploaded on the Platform. When you fill out and save your Profile, your saved Profile can be viewed by prospective employers, subject to visibility settings you control.

We process, monitor, review, store and analyze such content and other materials, including via automated means, for data analysis, quality control, enforcement of our Terms, and improvement of our services. Examples of such improvements would be optimizing our search results, improving job postings, matching you with a job posting or employer, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. ZHired may (but is not obligated to) notify you in such an event.

If you enter credit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.

When you submit personal information to a third party and are informed at the time of collection that your information may be shared with us, we may collect that information for lawful marketing purposes.

Information We Collect Automatically

When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.

Automated means of data collection include Cookies And Tracking Technologies, Log File Information, Device Information.

How We Use Information

We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy.

As a registered user of our Platform, ZHired processes your information in accordance with our contractual obligations based on the Terms of Use and, where this is not the case, alternative legal grounds serve as our legal basis for processing (i.e., consent, legal obligation, and legitimate interests) including personal information to:

  • provide you with personalized content, services and offers of services offered by ZHired, as well as other promotional content and services (for example, ZHired and its affiliates may use your previous search and browsing history (e.g. the jobs you click on), or your resume, Profile, application information, and responses to screener questions to determine relevant search results and provide you with recommended jobs on ZHired or on sites of ZHired affiliates, or ZHired may reach out to you about jobs or companies you may be interested in; we also use your IP address and mobile device for these purposes); For the purposes of this Policy, "affiliates" means any entity that directly or indirectly, controls, is controlled by, or is under common control of or with ZHired, Inc., now or in the future. "Control" for these purposes means having a majority of shares or the right and ability to direct management;
  • moderate and display the employer reviews, interview reviews, salary reports and other content you have submitted for the benefit of our other users;
  • customize and improve the features, performance, and support of the ZHired site and sites of ZHired affiliates;
  • communicate with you or initiate communication with you (for marketing or service-related purposes) on behalf of third parties through your ZHired account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you provide to us or (where it is lawful for us to do so) that we otherwise obtain from third-party resources;
  • permit ZHired or a ZHired affiliate to recommend a ZHired user (and that user's resume or resume extract) to an employer hosted by ZHired or to an employer hosted by a ZHired affiliate, subject to visibility settings you control (for example, ZHired may use application materials—including resumes and responses to screener questions—to determine whether the words of any job seeker's resume and answers to screener questions match the words of a job posting or resume query, and vice-versa, we may then differentiate matching resumes and screener questions from those that do not match, and present them to employers as matches or not matches);
  • permit ZHired to contact ZHired users with respect to such recommendations, subject to visibility settings you control;
  • provide relevant advertising, including interest-based advertising from us and third parties, which may mean that we share non-personally identifiable information, such as your job title, to third-party advertisers;
  • transmit your application and save your application materials;
  • share your saved Profile or resume with employers, subject to visibility settings you control;
  • allow ZHired and ZHired affiliates to process your personal data for the purpose of improving for internal operations, including detecting and preventing fraud and spam, troubleshooting, data analysis, testing, research, and service improvement (this includes use of your IP address and mobile device information to help diagnose problems with our service and to administer the Platform);
  • create aggregated statistical data that does not identify you individually and that we can commercialize (for example, we use mobile device data and IP addresses to create anonymized, aggregate demographic information);
  • for other purposes that you separately authorise as you interact with ZHired.

When we collect any information that does not identify you as a specific natural person ("Non-Personal Information"), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, including gender, dates of birth, ZIP codes, etc.; or any personal information that has been anonymized, aggregated or de-identified. If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.

How We Share Information/Recipients

We only disclose your personal information to third parties as follows:

  • We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business subject to strict confidentiality agreements. These companies are authorized to use your personal information only as necessary to provide these services to us;
  • We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business subject to strict confidentiality agreements. These companies are authorized to use your personal information only as necessary to provide these services to us; We may also share your information with ZHired affiliates, namely any entity that directly or indirectly controls, is controlled by, or is under common control with ZHired. Such affiliates shall process your personal data either (1) at our direction as a processor under a contractual relationship, (2) as a separate controller of your information where you are informed at the time of collection or processing of their relationship to you, or (3) where we believe it is necessary for the purposes of a legitimate interest, and where such purposes are aligned with those for which you provided your personal data to us. These instances and processing activities are outlined in the "How We Use Your Information" section above and will include data falling into the categories described in the section "Information You Give Us".
  • We will disclose data If we believe in good faith such disclosure is necessary (1) to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us (though we reserve the right to take action on behalf of our users to defend their right to anonymity when we believe there is a legitimate basis to do so, because candid, lawful, anonymous free speech is fundamental to ZHired's mission of workplace transparency); (2) to enforce our ZHired Terms of Use and Privacy Policy; (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (4) as we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of us, the users of our services, or third parties; or (5) as permitted under applicable laws to meet national security and similar requirements;
  • In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;
  • If you apply for a particular job through the Platform, we will disclose your personal information to the employer to whom you apply and any vendors they are working with to process your application;
  • We invite you to include your resume or other information in more generally available formats for us to share with employers (for example, a static image of your saved Profile), subject to visibility settings you control;
  • We share certain information that does not identify you personally, but which is unique to your use of the Platform, such as job titles that you have entered at the time of registration or on your profile. When we share such information, we do not link job titles with your name when we provide this information to others, such as advertisers, recruiters or employers;
  • We will otherwise share personal information with your consent.
  • As described in this section, ZHired may share your data with our affiliates. When we share this data, this may be considered a "sale" under applicable law. Once we begin sharing data you will be able to opt-out of this sharing by accessing the link in our footer titled "Do Not Sell My Personal Information"

The Legal Basis on Processes Your Personal Data

ZHired collects and processes your personal information on the basis of different legal grounds, depending on the nature of the personal information being provided and the type of processing involved.

Performance of a Contract

Most of the personal Data processed by ZHired is performed on the basis that it is necessary for the performance of our agreements with you (among them, your agreement to our Terms of Use and this Policy), 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 ZHired sends a job seeker's application to an employer.

Legitimate Interest

A second ground relied upon by ZHired for other types of processing of your personal information is that it is necessary for the purposes of legitimate interests pursued by ZHired. Such legitimate interests may include where ZHired sends you marketing about our products and services or where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf. A further example would be where ZHired shares your personal information with our affiliates as detailed in the "How We Share Information/Recipients" section above. ZHired 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 ZHired to comply with a legal obligation. An example of this would be where ZHired is required to retain business records for fixed periods of time or transmit them to a user in order to comply with local legal requirements. Another example is when ZHired collects Equal Employment Opportunity (or similar programs in your country) information on behalf of employers as part of the process of processing your applications to employers through the ZHired platform.

Consent

Finally, in certain limited situations, ZHired relies on your consent in order to process your personal information. Where ZHired requires your consent in order to collect and process certain personal information, we seek your consent at the time of provision, and such processing will only be performed where consent is secured unless ZHired has another lawful basis on which to rely. For example, your consent may be sought where you submit feedback to ZHired, or in certain instances where you initiate a marketing message or other communication with ZHired. You can withdraw your consent, as detailed in the "Other Important Privacy Information" section below, where applicable.

How Long We Keep Your Personal Information

We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we'll either remove it from our systems or depersonalize it so that we can't identify you.

Your Privacy Rights

ZHired operates globally and is therefore subject to a variety of data privacy laws that confer a range of privacy rights upon our users. We have chosen to provide all of these privacy rights to our users regardless of their location.

ZHired does not discriminate against users’ that exercise any of these privacy rights. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Updates to Our Privacy Policy

We may revise this Policy from time to time. The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately. However, they can object to the new Policy within thirty (30) days after the revision date. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy. If you object to the Policy after it becomes effective for you, you may no longer use the Platform.

last updated on: May 30, 2021

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