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PRIVACY POLICY

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Paying Customers
 * Master Subscription Agreement
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 * Data Processing Addendum
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Archived Master Subscription Agreements
 * SmartRecruiters MSA - May 12 2021
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 * SmartRecruiters MSA - April 24 2020
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 * SmartRecruiters MSA - May 16 2019
 * SmartRecruiters MSA - January 31 2018
 * SmartRecruiters MSA - December 1 2017

Policies
 * Candidate Privacy policy
 * Candidate Privacy Policy (California Residents)
 * Privacy policy for our own candidates
 * Terms of Use
 * Cookie policy
 * Website Privacy Policy
 * jobpal Privacy Policy

Trust Center
 * GDPR Toolkit
 * FAQ - US Government Surveillance
 * SmartRecruiters Sustainability
 * As of today's date, SmartRecruiters has not received a request for customer
   data from the United States Government.

Last revised: November 16, 2021

California residents please also see CCPA Privacy Notice.

For SmartRecruiters and its affiliates (“SmartRecruiters”), protecting your
personal information (“Personal Information” or “Personal Data” as defined
below)  is our priority.

We have prepared this privacy policy (“Privacy Policy”) to describe to you
(“you” or the “candidate”) our practices regarding the Personal Information we
collect from you as candidate (of our website, located at smartrecruiters.com,
our mobile application (“Application(s)”), and our widgets (collectively, the
“Site”) and all online services of SmartRecruiters Inc. and its affiliates
(“Services”).

For the purposes of this Privacy Policy, unless otherwise noted, all references
to SmartRecruiters include smartrecruiters.com, SmartRecruiters, Inc. and its
affiliates.

We respect each individual’s right to personal privacy. We will collect and use
information we receive directly from you through our website only in the ways
disclosed in this Privacy Policy. Information provided to SmartRecruiters by our
customers is collected by those customers under their own privacy policies. This
policy does not apply to practices that SmartRecruiters does not own or control,
or to individuals that SmartRecruiters does not employ or manage. By using
smartrecruiters.com, you agree to the data practices described in this statement
and you expressly consent to the collection, use and disclosure of your Personal
Information in accordance with this Privacy Policy. You can withdraw your
consent at any time. Learn more here.


WHAT IS THE PURPOSE OF COLLECTING YOUR PERSONAL INFORMATION?

For website visitors, SmartRecruiters collects information about you to operate
this website and deliver the services you have requested. Please see our Cookie
Policy for more information.

For the candidates applying to a job

 * Help our customers (“Customers”) find their next hires : when you apply, our
   customer (the recruiter or hiring manager) can consider you for any job
   opportunities they have and can use any SmartRecruiters tools to track,
   manage and make a decision.
 * Help you manage your job applications : when you apply, you have access to a
   Candidate Portal, where you can find your profile information and
   applications information. You can receive jobs suggestions.

SmartRecruiters is not a headhunting company, we only provide a talent
acquisition technology and SaaS services to our Customers.

Information about your computer hardware and software may be automatically
collected by SmartRecruiters. This information can include: your IP address,
browser type, domain names, access times and referring website addresses. This
information is used for the operation of the services, to maintain and the
improve quality of the services, and to provide general statistics regarding use
of smartrecruiters.com.

SmartRecruiters encourages you to review the privacy statements of websites to
which you choose to link from smartrecruiters.com so that you can understand how
those websites collect, use and share your information. SmartRecruiters is not
responsible for the privacy statements or other content on websites outside of
smartrecruiters.com.


HOW YOUR DATA WILL BE USED?

SmartRecruiters collects your Personal Information to operate its website and
deliver the Services you have requested as set forth above. SmartRecruiters may
also contact you via surveys to conduct research about your opinion of current
Services or of potential new services that may be offered.

SmartRecruiters does not sell, rent or lease the collected Personal Information
and its customer lists to third parties.

SmartRecruiters may share usage data with trusted partners to help to perform
usage statistical analysis, customer support and technical operations and
provide data hosting services. All such third parties are required to maintain
the confidentiality of your information.

SmartRecruiters may keep track of the websites and pages our users visit within
SmartRecruiters, in order to improve your user experience.

SmartRecruiters may use the Personal Data to improve and develop its website,
its services and products to the extent this is necessary for its legitimate
interests. SmartRecruiters may also use your Personal Information to inform you
of other products, services or job opportunities available from and through
SmartRecruiters.

Our Customer may opt in to use features that assist them in the recruitment
process through automated means. For you as a candidate, it means that your
application is processed and analyzed to identify relevant aspects from your
work history such as previous positions and employers, education history,
demonstrated skills, and duration of work. These aspects are then compared
against the job published by our Customer to indicate how your application
corresponds with the requirements outlined in the job listing.

These findings help our Customer highlight existing information in your
application. The automated capabilities are used to facilitate the recruitment
process, however, any conclusive hiring decisions are ultimately at the
Customer’s discretion.


GDPR COMPLIANCE

SmartRecruiters is committed to full compliance with the GDPR, including GDPR
Article 13. Below is where we comply with Article 13 in this policy:

GDPR Article 13 Section 1

 * Section 1(a): See “Data Protection Questions” section below for the name of
   the controller, and SmartRecruiters address.
 * Section 1(b): See “Data Protection Questions” section below for the email of
   our data protection officer.
 * Section 1(c): See section the introduction to this section for the purposes
   which SmartRecruiters collects personal data as well as the legal basis.
 * Section 1(d): This section is not applicable to SmartRecruiters because we
   process personal data based on consent.
 * Section 1(e): See our Cookie Policy for the categories of recipients of
   personal data for website visitors.
 * Section 1(f): for website visitors, SmartRecruiters does not collect personal
   data.

GDPR Article 13 Section 2

 * Section 2(a): See our Cookie Policy for website visitors who simply visit our
   website.
 * Section 2(b): See our Cookie Policy for website visitors who simply visit our
   website.
 * Section 2(c): See our Cookie Policy for website visitors who simply visit our
   website.
 * Section 2(d): See our Cookie Policy for website visitors who simply visit our
   website.
 * Section 2(e): This is not applicable to SmartRecruiters.


ONWARD TRANSFERS

SmartRecruiters uses a limited number of third-party providers in the USA and in
Europe to provide data hosting services (Amazon Web Services) and to help to
perform usage statistical analysis, customer support and technical operations.

SmartRecruiters ensures that all personal data is handled, processed,
transferred and stored in accordance with relevant EU data protection law, and
that adequate safeguards and procedures providing protection to Users’ personal
data are in place.

SmartRecruiters shall remain responsible in case of onward transfers to third
parties. SmartRecruiters shares the Personal Information with these third-party
providers to support SmartRecruiters’ Services only. Any other use of the
Personal Data by third-party providers is prohibited.

All third-party providers receiving Personal Data from the European Union and/or
Switzerland agree to (i) process the Personal Data only to the extent required
by SmartRecruiters’ Services and in accordance with SmartRecruiters’
instructions and (ii) comply with the data protection laws for transfer and
processing of personal data and (iii) provide adequate technical and
organization measures to protect the Personal Information.

To this end, SmartRecruiters, Inc. has also implemented and signed the Standard
Contractual Clauses (“SCCs”) with its subcontractors to ensure its compliance
with the GDPR. The SCCs have also been signed between SmartRecruiters’ European
affiliates and SmartRecruiters, Inc.


HOW CAN YOU ACCESS TO YOUR PERSONAL INFORMATION?

SmartRecruiters acknowledges that individuals have a right to access to,
correct, amend and delete their Personal Information. Because SmartRecruiters is
the data processor of the Personal Information and collects Personal Information
under the instructions of its Customers, SmartRecruiters shall follow its
Customers’ instructions. Therefore, SmartRecruiters encourages the individuals
to contact these Customers. This can be done by replying to the last email that
was sent via the SmartRecruiters system.


USE OF COOKIES

Please visit https://www.smartrecruiters.com/legal/cookie-policy/ for all cookie
information as it relates to SmartRecruiters.


SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION

SmartRecruiters is ISO 27001 certified.

SmartRecruiters uses industry-standard technologies when transferring and
receiving data exchanged between SmartRecruiters and third parties to help
ensure its security. SmartRecruiters’ website has security measures in place to
protect the loss, misuse and alteration of information.

Personal Information are stored on servers maintained by Amazon Web Services and
subject to their security safeguards which are continuously audited, with
certifications from accreditation bodies across geographies and verticals. You
can read more about Amazon Web Services’ security and compliance at
https://aws.amazon.com/compliance/.

SmartRecruiters will retain your Personal Information for as long as is
necessary for the purposes set out in this Privacy Policy.


CHILDREN UNDER THIRTEEN

SmartRecruiters does not knowingly collect Personal Information from children
under the age of thirteen. If you are under the age of thirteen, you must ask
your parent or guardian for permission to use smartrecruiters.com. If a child
under 13 submits Personal Information to Company and we learn that the Personal
Information is the information of a child under 13, we will attempt to delete
the information as soon as possible. If you believe that we might have any
Personal Information from a child under 13, please contact us at
supportfeedback@smartrecruiters.com .


OPT-OUT & UNSUBSCRIBE

We respect your privacy and give you an opportunity to opt-out of receiving
announcements of certain information. Users may opt-out of receiving any or all
communications from SmartRecruiters by following the “unsubscribe” link on
communication received from SmartRecruiters or otherwise by contacting us at:

– Email: supportfeedback@smartrecruiters.com


DISCLOSURE OF YOUR PERSONAL DATA

SmartRecruiters may disclose your Personal Information, without notice, only if
required to do so by law or in the good faith belief that such action is
necessary to: (a) conform to the edicts of the law or comply with legal process
served on SmartRecruiters or the site; (b) protect and defend the rights or
property of SmartRecruiters; and, (c) act under exigent circumstances to protect
the personal safety of users of SmartRecruiters, or the public.


DATA PROTECTION QUESTIONS

If you have any inquiries or complaints regarding the processing of your data,
you should first contact SmartRecruiters at: dpo@smartrecruiters.com .
SmartRecruiters will respond in a timely manner.

In case of unresolved privacy or data use concern, you have the right to lodge a
complaint with your data protection supervisory authority.


HOW TO CONTACT US

225 Bush Street, Suite #300
San Francisco CA 94104 US
Telephone: +1 415-508-3755
Email: info@smartrecruiters.com

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