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CANDIDATE PRIVACY POLICY

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Paying Customers
 * Master Subscription Agreement
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 * Privacy policy for our own candidates
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 * GDPR Toolkit
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 * As of today's date, SmartRecruiters has not received a request for customer
   data from the United States Government.

Last reviewed: August 13, 2020

California residents please also see CCPA Privacy Notice.


WHAT PERSONAL DATA (“YOUR PERSONAL DATA”) ARE WE COLLECTING?

 * Data that you (“You”, “Your”) input during the application process or job
   alert creation (contact information, experience and education, attachments,
   screening questions answers).
 * Your IP Address.
 * Your login information (email address and encrypted password) for your
   Candidate Portal.
 * Cookies, which allow us to know how our services are accessed and used

For more details, click here.


WHAT IS THE PURPOSE OF COLLECTING YOUR PERSONAL DATA?

 * Help You manage Your job opportunities within the Candidate Portal: when You
   apply to one of our Customers, You have access to a Candidate Portal, where
   You can find Your profile information and applications information.
 * Receive jobs suggestions available from and through SmartRecruiters.
 * Conduct surveys: SmartRecruiters may also contact You via surveys to conduct
   research about Your opinion of current or future SmartRecruiters
   functionalities and user experience.
 * Improve and develop services and products: SmartRecruiters may use the
   Personal Data to improve and develop its services and products to the extent
   this is necessary.

In this case, we are the data controller.

Please remind : when You apply to one of our Customers’ jobs, 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.
In this case, the Customer is the data controller and is responsible for the
process of Your Personal Data and SmartRecruiters is the data processor
processing the data on behalf of the Customer.

SmartRecruiters is not a headhunting company. We only provide a talent
acquisition technology to our customers and the services to You as mentioned
above.

Because SmartRecruiters and its affiliates (“SmartRecruiters”) offer You real
choice and control over how You use Your Personal Data, and wants to build trust
and engagement with You, consent is the legitimate basis for processing Your
Personal Data.

You can withdraw your consent at any time by deleting your Candidate Portal
account.


HOW YOUR PERSONAL DATA FOR CANDIDATE PORTAL WILL BE USED

 * You can set up a personal account (“Candidate Portal”) which allows You to
   manage Your job opportunities and track your different applications of
   several Customers.
 * In Your Candidate Portal, which is accessible on
   https://my.smartrecruiters.com/, You may register through the email you
   received after applying, or if your consent was requested. This is operated
   by SmartRecruiters under its own responsibility. The registration requires
   your email address and a password.
 * Your profile will be made available and visible to the Customer to which you
   applied. You will receive job alerts from the Customers to which You applied.
 * In order to provide world-class services to You and the Customer,
   SmartRecruiters uses third-party providers to help perform statistical
   analysis, technical support and data hosting. To learn more, click here
 * Your application information will be collected by SmartRecruiters and be made
   available to You through the Candidate Portal.
 * You can find more details here. SmartRecruiters will never sell, rent, or
   lease the collected Personal Data.


HOW CAN YOU SELF-MANAGE YOUR PERSONAL DATA?

 * Candidate Portal: You can see all Your profile and applications You’ve made
   * Right to rectification: You can modify Your profile by going to the “My
     SmartProfile” section
   * Right to be forgotten: You can withdraw and delete Your profile at each
     company You applied for:
     Please note that SmartRecruiters will transmit your request to the
     Customers You applied. In some cases, they may decide to keep your
     application data in compliance with their own legal obligations. To find
     more about these obligations, we encourage you to contact them directly.
     Contact information should be found in each company’s privacy policy linked
     at the bottom of your application or via their corporate website.
   * Right to data portability: You can export Your profile in a machine
     readable format
   * Right to object to processing: You can decide whether or not you wish to
     create a Candidate Portal and to delete it as mentioned above. You will
     still be able to apply to the job of Your choice without creating a
     Candidate Portal.
   * Right to restriction of processing: Your Personal Data will be used solely
     for the purposes mentioned above and You can decide whether or not to
     create a Candidate Portal .You will still be able to apply to the job of
     Your choice without creating a Candidate Portal.
 * If You have any questions on how Your Personal Data is used or how You can
   self-manage Your Personal Data, feel free to contact
   supportfeedback@smartrecruiters.com


USE OF YOUR PERSONAL DATA

 * Help You manage Your job opportunities within the Candidate Portal: when You
   apply to one of our Customers, You have access to a Candidate Portal, where
   You can find Your profile information and applications information.
 * Receive jobs suggestions available from and through SmartRecruiters.
 * Conduct surveys: SmartRecruiters may also contact You via surveys to conduct
   research about Your opinion of current or future SmartRecruiters
   functionalities and user experience.
 * Improve and develop services and products: SmartRecruiters may use the
   Personal Data to improve and develop its services and products to the extent
   this is necessary.

In this case, we are the data controller.

Please remind : when You apply to one of our Customers’ jobs, 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.
In this case, the Customer is the data controller and is responsible for the
process of Your Personal Data and SmartRecruiters is the data processor
processing the data on behalf of the Customer.

SmartRecruiters does not sell, rent or lease the collected Personal Data to
third parties.

SmartRecruiters may share Your Personal Data with trusted partners in order to
perform usage statistical analysis, customer support, technical operations and
provide data hosting services. Our trusted partners are prohibited from using
Your Personal Data except to provide these services to SmartRecruiters, and they
are required to maintain the confidentiality of Your Personal Data. For more
information, please click here.




TRACKING COOKIES

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


RETENTION OF YOUR PERSONAL DATA

SmartRecruiters will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy.


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 email to
   contact SmartRecruiters, 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 “What is the purpose of collecting your personal
   data?” for the purposes 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 “Onward Transfer” section for the categories of recipients
   of personal data.
 * Section 1(f): See “Onward Transfer” section for third country and
   international organization transfers, and our transfer mechanism in
   accordance with Article 46(2)(c).

GDPR Article 13 Section 2

 * Section 2(a): See the “How Can You Self-Manage Your Personal Data” section
   for how SmartRecruiters determines the criteria used to determine how long we
   retain personal data.
 * Section 2(b): See the “How Can You Self-Manage Your Personal Data” section
   for the right of a data subject to access, rectify, erase, or move personal
   data.
 * Section 2(c): See the “How Can You Self-Manage Your Personal Data” section
   for the right to withdraw consent.
 * Section 2(d): See “Data Protection Questions” section for the notice of the
   right to lodge a complaint with a supervisory authority.
 * Section 2(e): This is not applicable to SmartRecruiters.
 * Section 2(f): SmartRecruiters does not make automated profiling decisions.


ONWARD TRANSFER

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

Our Sub-processors for the Candidate Portal (i.e. your personal account with
SmartRecruiters) are:

 * SmartRecruiters (SPOLKA AKCYJNA) Oddzial w Polsce (Poland): our branch in
   Poland is used for operation, maintenance, support and testing of the
   Candidate Portal and our platform;
 * Amazon Web Services, Inc. is used for hosting of the data. Hosting location
   is the cluster AWS Germany.
 * SendGrid, Inc. (US) is used to power the sending and receiving of emails from
   Your Candidate Portal.
 * Textkernel B.V. (The Netherlands) is used to parse the Candidate’s CV and
   documents and parse the data into the database field.
 * Google Analytics by Google LLC (US) is used to gather behavioral analytics on
   how candidates use the My SmartRecruiters Candidate Portal. SmartRecruiters
   will not use the data to identify individual users and will not merge the
   data with other data to identify individual users.
 * Hotjar LTD (Malta) is used to gather behavioral analytics on how candidates
   use the My SmartRecruiters Candidate Portal, NPS and surveys answers.
   SmartRecruiters will not use the data to identify individual users and will
   not merge the data with other data to identify individual users.

For Your complete information, when You apply to one of our Customers’ jobs,
SmartRecruiters as data processor uses the following third-party providers for
the services provided to our Customers:

 * SmartRecruiters (SPOLKA AKCYJNA) Oddzial w Polsce (Poland): our branch in
   Poland is used for operation, maintenance, support and testing of our talent
   acquisition platform;
 * Amazon Web Services, Inc. is used for hosting of the data. Hosting location
   is the cluster AWS Germany.
 * SendGrid, Inc. (US) is used to power the sending and receiving of emails from
   our talent acquisition platform to You and our Customer.
 * Textkernel B.V. (The Netherlands) is used to parse the Candidate’s CV and
   documents and parse the data into the database field.
 * Jitterbit, Inc. (US, service optional) is the cloud connector hosted in our
   hosting location in Germany and used to host and maintain any custom
   integrations between Customer’s system and SmartRecruiters platform.
 * ClickBoarding, LLC (US, service optional) is used by our Customers
   subscribing to the onboarding add-on.
 * Google Analytics by Google LLC (US) is used to gather behavioral analytics on
   how candidates apply to the customers’ job offers. SmartRecruiters will not
   use the data to identify individual users and will not merge the data with
   other data to identify individual users.

SmartRecruiters shall remain responsible in case of onward transfers to third
parties.

SmartRecruiters shares the Personal Data with these third-party providers to
support SmartRecruiters’ Services only. Any other use of the Personal Data by
third-party providers is prohibited.

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.

All third-party providers receiving Personal Data from the European Union, the
United Kingdom 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 applicable data
protection laws for transfer and processing of Personal Data and (iii) provide
adequate technical and organization measures to protect the Personal Data.

To this end, we use the European Standard Contract clauses
(http://ec.europa.eu/justice/data-protection/international-transfers/index_en.htm)
with our sub processors in order to guarantee the privacy and the security of
Your Personal Data.

When You submit Your application, You agree to this Privacy Policy and, in
particular, You expressly agree to the transfer of Your Personal Data for the
purposes described in that Privacy Policy.




SECURITY OF YOUR PERSONAL DATA

SmartRecruiters is ISO 27001 certified.

SmartRecruiters uses industry-standard technologies when transferring and
receiving consumer 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 Data may be hosted 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/.


CHILDREN UNDER THIRTEEN

SmartRecruiters does not knowingly collect Personal Data 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 Data to Company and we learn that the Personal Data 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 Data from a
child under 13, please contact us at supportfeedback@smartrecruiters.com


CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy and our Terms of Use at any
time. We will notify You of significant changes to our Privacy Policy by sending
a notice to the primary email address specified in Your account or by placing a
prominent notice on our site. Significant changes will go into effect following
such notification. Non-material changes or clarifications will take effect
immediately. We encourage You to check our site and this Privacy Policy for
updates.


DISCLOSURE OF YOUR PERSONAL DATA

SmartRecruiters may disclose Your Personal Data, 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.


INQUIRIES – HOW TO CONTACT US ?

If You have any queries related to one of Your applications for our Customer,
please contact them directly. You will find the Customer’s contact showed in the
Candidate Portal.


DATA PROTECTION QUESTIONS

If You have any further queries, please send an email to our Data Protection
Officer 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.

******
SmartRecruiters, Inc.
225 Bush Street
Suite #300
San Francisco CA 94104
USA

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